EN l'liltlan] (411nm a 1m We 1mm Transcript and DCN: ng Information Filing Date 02/15/2012 Received Date 02/15/2012 Entry Date 02/17/2012 Submission Metnod Electronlc discrete lillng Subject Information SubjeCH cl1 TORNATORE HOLDING LIMITED Role Sumect lndividualmrganixation Drganizatlun Last (or Entity) Neme TDRNATDRE HOLDING LIMITED Address1es) Street Address City NICOSIA NICOSIA - Enhanced Country CV CV - Enhanced Occupatianl'l'yna or Business Corroborative statement to Filer N0 Relationsnip ta Reponing Institution 1m Relationship o1 Subject Other: Yes No RELATIONSHIP Continuing Relationsnip ta Reponing N0 Institution Suspi ous Activity Information Amount Involved 35.552885 Date or Date Range ol A ty 12/21/2011 - 12/22/2011 Money laundering Mane Amount o1 Loss Prior To Recovery $0 Recovery Amount $0 Company ed N0 ancial Soundness N0 Activity Location Flnanclal Insll Ilon Locallon 1 cl 1 Primary Regu ator Federal Reserve Legal Name DEUTSCHE BANK TRUST C0. AMERICAS Page 1 BSA: BSA: SAR-DI Transcript and DCN: Activity Location EIN Address(es) Street Address 60 WALL STREET 60 WALL ST - Enhanced City NEW YORK NEW YORK - Enhanced State NY NY - Enhanced ZIP Code 100052858 10005-2858 - Enhanced Country US - Enhanced Branch Office Location 1 of 1 Address Street Address 60 WALL STREET 60 WALL ST - Enhanced City NEW YORK NEW YORK - Enhanced State NY NY - Enhanced ZIP Code 100052858 10005-2858 - Enhanced Country US - Enhanced Filer Information Primary Regulator Federal Reserve Filer Name DEUTSCHE BANK TRUST CO. AMERICAS EIN Address(es) Street Address 60 WALL STREET 60 WALL ST - Enhanced City NEW YORK NEW YORK - Enhanced State NY NY - Enhanced ZIP Code 100052858 10005-2858 - Enhanced Country US - Enhanced Page 2 The enclosed information was collected and disseminated under provisions of the Bank Secrecy Act (the BSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311, et seq.; 31 CFR Chapter X. The information is sensitive in nature and is to be treated accordingly. The information may be used only for a purpose consistent with a criminal, tax, or regulatory investigation or proceeding, or in the conduct of intelligence or counterintelligence activities, including analysis, to protect against international terrorism. See 31 U.S.C. 5311. The information cannot be further released, disseminated, disclosed, or transmitted without prior approval of the Director of Financial Crimes Enforcement Network or his authorized delegate. Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of possible criminal activity, akin to confidential informant tips. Unauthorized release of information collected under the BSA may result in criminal or civil sanctions. SAR-DI TranSc/im and DON: Filer Information Contact lor Assistance Phone Number Type Work Number -- Law Enforcement Information N0 Law EnIarcemem InIarmaIIan Narrative INTERNAL REFERENCE THIS SAR SUPPLEMENTS A PREVIOUS SAR FILED ON 03/18/2011 CONCERNING TORNATORE HOLDING LIMITED WHICH IS THE SAME PARTY INVOLVED IN THE TRANSACTIONS DESCRIBED BELOW. THE CURRENT SAR CONTAINS TRANSACTIONS THAT WERE NOT REPORTED IN THE SAR PREVIOUSLY-FILED ON 03/13/2011. THIS SAR SUPPLEMENTS A PREVIOUS SAR FILED ON 05/13/2011 CONCERNING TORNATORE HOLDING LIMITED WHICH IS THE SAME PARTY INVOLVED IN THE TRANSACTIONS DESCRIBED BELOW THE CURRENT SAR CONTAINS TRANSACTIONS THAT WERE NOT REPORTED IN THE SAR PREVIOUSLY-FILED ON 05/13/2011 DURING AML DEUTSCHE BANK TRUST COMPANY AMERICAS WAS ORIGINALLY ALERTED TO WIRE TRANSFER ACTIVITY CONDUCTED DURING THE PERIOD FROM 11/22/2011 TO 12/27/2011. A SEARCHOF THE DBTCA WIRE TRANSFER DATABASE IDENTIFIED THREE 13) TRANSACTIONS TOTALING $562,885 37' SENT FROM 12/21/2011 TO 12/22/2011 BY THIRD-PARTY ORIGINATORIBENEFICIARY TORNATORE HOLDING LIMITED, THESE TRANSACTIONS WERE SENT FROM AN ACCOUNT AT A FINANCIAL INSTITUTION THAT DOES NOT MAINTAIN A CORRESPONDENT BANKING RELATIONSHIP WITH DBTCA, THE ORIGINATORS INVOLVED IN THE TRANSACTIONS WERE TORNATORE HOLDING LIMITED THE ORIGINATING BANKS INVOLVED IN THE TRANSACTIONS WERE -- -- GLOBEXBANK (RUSSIA) THE BENEFICIARIES INVOLVED IN THE TRANSACTIONS WERE TORNATORE HOLDING THE ADDRESS FOR TORNATORE HOLDING LTD. WAS LISTED IN THE TRANSACTION DETAILS AS-- --2 NO PHYSICAL PLACE OF INCORPORATION OR LINE OF BUSINESS WAS IDENTIFIED THROUGH EXTERNAL RESEARCH. A SEARCH OF INTERNAL AND EXTERNAL DATABASES CONDUCTED ON THE COUNTERPARTIES IDENTIFIED: 1, THE ADDRESS Page 3 -- :vsa Transcript and DON: Narrative FOR LLC GAZENERGOLIZING WAS LISTED IN THE TRANSACTION DETAILS AS-- - NO PHYSICAL LOCATION. PLACE OF INCORPORATION OR LINE OF BUSINESS WAS IDENTIFIED THROUGH EXTERNAL RESEARCH TRANSACTION DETAILS ACCORDI IDENTIFIED: 1, ON HOLDING LTD, RECEIVED TWO (2) LARGE. SAME DAV TRANSACTIONS TOTALING 35562891 37 FROM A SINGLE ORIGINATOR. LLC GAZENERGOLIZING, 2, ON HOLDING LTD SENT ONE (1) LARGE TRANSACTION IN THE AMOUNT OF $999,994 TO BENEFICIAR- - 3, ALTHOUGH THE TRANSACTION DETAILS INDICATE THAT THE PAYMENTS AS DESCRIBED ABOVE WERE FOR OF AND DBTCA WAS UNABLE TO CONFIRM THE COMMERCIAL PURPOSE OF THESE TRANSACTIONS THROUGH INDEPENDENT RESEARCH, IN CONNECTION WITH A PREVIOUS INVESTIGATION DBTCA ASKED GLOBEXBANK FOR INFORMATION ABOUT TORNATORE HOLDING LTD. AND THE BUSINESS PURPOSE OF SIX (5) OF THE TRANSACTIONS IN THAT INVESTIGATION GLOBEXBANK PROVIDED THE FOLLOWING RESPONSE TO THIS INQUIRV: CUSTOMER NAM CONTERPARTY NAME- TORNATORE HOLDING LTD, CUSTOMER INFORMATION: (BUSINESS) NAME THE MAIN BUSINESS ACTIVITV OF THE COMPANV IS LEASING ACTIVITV 2 BUSINESS. 9. THE COMPANV IS A CUSTOMER OF GLOBEXBANK SINCE 13.09.2009 (SEPTEMBER, 13TH. 2009). 10 THE LAST VISIT TO THE OFFICE WAS ON 11 THE CONTRACT 42-A DD 30 092010 LENGTH - 31 08 20151NCLUSIVE. PERCENT -10.9 PCT PER ANNUM. THE LOAN TARGET THE CONTRACT 43-A DD 30.09.2010: LENGTH - 01,09,2015 INCLUSIVE, PERCENT -10,9 PCT PER ANNUM, THE LOAN TARGET, THE CONTRACT 44-A DD 3009,2010: LENGTH - 01,09,2015 INCLUSIVE, PERCENT -10.9 PCT PER ANNUM. THE LOAN TARGET THE CONTRACT 45-A DD 30 09 2010 LENGTH - 01 09 2015 INCLUSIVE. PERCENT -10,9 PCT PER ANNUM, THE LOAN TARGET. 12. THE CLIENT MAKE SUSPICIOUS OPERATIONS INFORMATION- NAME- TORNATORE HOLDING LTD-- -- ADDITIONAL OUESTIONS IF THE ENTITIES ARE BUSINESS Page 4 -- :vsa I Financiml (2mm 'nfoI'crmem Network g1 Fm? EN mm .1, .W SAR- DI Transcriapls'd D:c~ Narrativa PARTNERS. HOWDO THEY KNOW EACH TRADE FAIRS. TV ADVERTISING, REFERRED BY OTHER CUSTOMERS INTERNET WEBPAGE (IF SO. PLEASE PROVIDE), AFFILIATED TO EACH OTHER. - NO INFORMATION. COULD YOU PLEASE PROVIDE US WITH THE LENGTH PRINCIPAL, AND INTEREST OF LOAN AGREEMENT N.44-A DD 30.09.2010? -THE CONTRACT 44-A DD 30.09.2010: LENGTH - 01.09.2015 INCLUSIVE, PERCENT, 10,9 PER ANNUM. THE LOAN TARGET. WHAT IS THE INTENDED USE FOR THE - THE LOAN TARGET. THANK YOU FOR THE INFORMATION WE REQUESTED INFORMATION INSTEAD. COULD YOU PLEASE PROVIDE THE BUSINESS INFORMATION FOR TORNATORE HOLDING LTD. NO INFORMATION. DO YOU HAVE ANY REASON TO BELIEVE THAT THE TRANSACTIONS LISTED ARE IN ANY WAY OF A - THE CLIENT MAKE SUSPICIOUS OPERATIONS. -- ivsa