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Allister Crossley
ria
Oct 30, 2014, 7:44 AM
RE: Golden Star Aviation SA [IWOV-IM_CLIENT.FID348191]
1
Dear Igor
It is with regret that I had to deliver the below news however this is a group policy and not one I am able to
deviate from. I sincerely apologise for the inconvenience caused by this decision, it has been a pleasure
working with you in respect of the structure.
Once a new service provider has been identified, I will ensure that the handover takes place as smoothly as
possible.
With kind regards
Allister
Allister Crossley Manager -‐ Client Services
Appleby Trust (Isle of Man) Limited
Tel: +44 (0)1624 647 960
applebyglobal.com
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From: ria [mailto:ria@swgi.com]
Sent: 30 October 2014 11:35
To: Allister Crossley
Subject: RE: Golden Star Aviation SA [IWOV-‐IM_CLIENT.FID348191]
Dear Allister,
It's a pity to realize that you came to the below conclusion under the circumstances that:
1. even though on 17 July 2014 OAO NOVATEK got listed on OFAC's Sectoral Sanctions Identification
List under which all transactions in, provision of financing for, and other dealings in new debt of longer
than 90 days maturity of OAO NOVATEK by a U.S. person or within the United States are prohibited, all
other activities with OAO NOVATEK or involving its property or interests in property are permitted;
2.
OAO NOVATEK is not on any European Sanctions list;
3.
Mr. Mikhelson himself is not either on the OFAC's or any European Sanctions list.
We're currently in the process of negotiation with some other IoM service providers and I'll get back to you
with results of these negotiations shortly.
Regards,
Igor Ryaskov
From: Allister Crossley [mailto:ACrossley@applebyglobal.com]
Sent: Monday, October 27, 2014 4:14 PM
To: ria
Subject: FW: Golden Star Aviation SA [IWOV-‐IM_CLIENT.FID348191]
Dear Igor
Further to the below and our follow up telephone conversation in respect of the below, I undertook to
seek further clarification on our position regarding the issues highlighted.
I can advise that I have spoken with our management in respect of the below and the original decision that
was made. It is with regret that I must advise that the decision to exit structures that are directly or
indirectly connected to entities or persons named on OFAC remains the same.
Please find below an attachment that details the various Aviation Service Providers within the Isle of Man
that could potentially assist with providing services to the Isle of Man structure.
http://www.gov.im/lib/docs/ded/Aircraft/Approvals/iom_aviation_business_directory_2014.pdf
Once again I apologise for this and that we are unable to continue to assist with this structure.
With kind regards
Allister
Allister Crossley Manager -‐ Client Services
Appleby Trust (Isle of Man) Limited
Tel: +44 (0)1624 647 960
applebyglobal.com
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From: Allister Crossley
Sent: 25 July 2014 14:02
To: 'ria'
Subject: Golden Star Aviation SA
Dear Igor
As you are aware the ultimate client connected to the above structure is connected to an entity that is
named OFAC list. Due to the ongoing issues and increased risk, it is with regret that I must advise that we
will be looking to cease services in respect of these structures. Due to the ongoing matters in this respect,
our group policy is to cease services where there is a party that is listed on this list.
I will be away from the office for the next two weeks, however wanted to advise you of this discussion to
allow you to start to make alternative arrangements. I apologise for the inconvenience that this will cause.
With kind regards
Allister
Allister Crossley Manager -‐ Client Services
Appleby Trust (Isle of Man) Limited
Tel: +44 (0)1624 647 960
applebyglobal.com
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