Bill Browder stuns MPs as he exposes Putin’s oil loopholes

I have the names of the refineries that refine Russian oil and sell it to us and I just want to publish it and put it on the record so that you know that we should think about applying sanctions to these refineries or creating some type of legislation where we are not allowed to buy oil from these refineries or get them and I'm just going to post it here for the record, we in India have the vinar. um refinery, which is 49% owned by the Russian state oil company Ros neft, receive Russian oil and sell us refined Russian oil products.

We have the Jam Nagar refinery in the Gulf of Coch on the western coast of India, which is a leading destination. For Russian crude oil coming to India, we have Barat Petroleum, which is a state-owned company, and then we have Hindustan Petroleum, another state-owned company in Turkey, we have Star Refin iny, which concluded an agreement with Russian Oil Company LC Oil and in China . We have the COPC and CNC group. I think they are all communications companies that buy Russian oil. When we talk about India, China and Türkiye, we are talking about specific companies. We do not have to sanction India, China and Türkiye.

We can just go after companies that are buying the oil, my name is Bill Browder, I am the CEO of Hermitage Capital Management and head of the global Magnitsky Justice campaign, since the murder of my lawyer Sergey Magnitsky in Russia in 2009, I have taken mission to get justice and that has resulted in the passage of something named after him called the Magnitsky ACT, which was passed in the United States in 2012 and was passed in Canada in 2017 here in the United Kingdom in 2018 in the EU 2020 in Australia in 2021 there are now 35 countries in the world that have magnite laws in place and through this process I have become an expert on sanctions and the implementation of sanctions, and it has led me to all kinds of discussions in all over the world with different policy makers and government officials. and others, I am pleased to be here today to address this very important question of whether or not sanctions are working and what we can do to improve them.

Thank you very much and I know you have worked absolutely, don't worry, LLY on this and I campaigned tirelessly and published a book about it which I had the pleasure of reading and I think you know clearly, since Putin's illegal invasion of Ukraine in 2022 , the lessons that have been learned through the implementation of Magnitsky. Sanctions are now very valuable in terms of looking at what needs to change for this much broader crime that has been committed and I was wondering if you could start, Mr. Browder, by simply saying what you would like to see change in terms of the current regime that the The United Kingdom is operating in response to the invasion of Ukraine.

Well, first of all, I should say something really important and clear, which is that Putin has stated on several occasions that sanctions are not working. He says the sanctions are not working, look how well we are doing, we have excellent economic statistics, everything is fine, so why are they suffering from having these sanctions because they are hurting them? So the first thing I want to say is that the sanctions are crippling Russia and I think this is really important and I want to back up and say that the numbers that you get about the quote The success of the Russian economy come from a Russian country the state committee of Russian statistics produces such figures that the Russians lie in all other areas.

I see no reason why we should believe those numbers coming out of Russia, and let me go over at a very broad level the effects of the sanctions. just to make everything clear and exposed um uh, a week after the war started, the West froze over $300

bill

ion of Russian Central Bank reserves, they had 650

bill

ion in their literal war chest, which was the chest of Putin's war, one of the reasons why he felt. The confidence in going to war was that it had 650 billion in Central Bank reserves and with a Fell Swoop we immobilized that money and that money is no longer usable.

We have also sanctioned, I think at this stage, of the 98 oligarchs who were listed by the US government as sort of influential oligarchs, here in the UK, I think we have sanctioned 57 of them and all their money has been effectively tied up wherever they have that money and that number could be the order of magnitude of the Central Bank's foreign money reserves that they can't access uh we've also um uh said to um uh or saying mentioned abroad the foreign borrowing capacity of the Russian government and Russian companies and they were borrowing many tens if not hundreds of billions of dollars before all this happened that reached zero, about 1500 Western companies have withdrawn from Russia and Russia has gone from plus 40 billion of foreign direct investment before the war started to minus 40 billion, so there has been 80 billion dollars. swing um, uh, the big one, the big big loophole, though is the sale of oil.

Russia continues to sell oil to us, not to us, the quantities of oil sold to us directly have decreased by 80% more, but any oil they sold to us is now sold to India, China and Turkey, and the problem is that there is two problems, one is that they continue to make a lot of money from that oil, that is, between 500 and 1 billion dollars a day, and Secondly, the oil that is sold to refineries in India, China and Turkey, part of that oil come back this way. About $23 billion of oil is refined petroleum products that are being sold again in this direction to the EU and I think last year.

The United Kingdom bought that refined product worth $2.2 billion and as long as Russia can sell the oil, Russia can use that hard currency to buy weapons and can use those weapons to kill Ukrainians, so on the one hand , we are financing or directly or indirectly we are financing Russia to carry out its war and, on the other hand, we are financing the Ukrainians to defend themselves and something that something has to give and what Putin hopes to give is that we We are going to run out of patience to finance the Ukrainians and we have seen evidence of this.

We saw this in the EU when the 50 billion euro package was being delayed, not from this Parliament, no, um, we saw it not from this country. but I'm only 61 billion US, so we need to find a way to continue tying up Russia's AB ability to carry out this war and the best way to do that is to work with this oil, so what I What I hear is that the sanctions are crippling the Russian economy, that the financial sanctions have been effective in catching the right people and some substantial amounts of money, but that the main loophole is through oil, which, being fungible, somehow it ends up in the in the UK it's a good summary of what I just heard exactly which I thank you very much, it's a really fascinating place to start Drew, yes, thank you, in February 2023, you wrote an article, but you continued with the seized opinion.

Russian assets say they should be used to finance war in Ukraine. What impact do you think that would have if that went ahead? If the seized assets could be used for that in the war in Ukraine, what impact would it have on Ukraine? Well, simply put, if the West, the UK, the US, the EU and other allies confiscated $300 billion, that would change the entire nature of war, this war, ultimately, when it comes to a resource, war, Russia has more resources than Ukraine Putin is confident in the fact that as the war drags on, we will have less appetite than him to carry out the war and that we will stop financing and we have seen evidence of That's when I say that I say that as a collective we, um, if this money were confiscated, this is five times what the United States had been holding up, five times the 61 billion um that the United States had been holding up and I think it would change completely the situation and, in particular, it would change the situation in a context in which we have been in this war for almost two and a half years and, whether we like it or not, some of our allies will be less likely. to finance this war and I am particularly worried about what could happen in the United States.

There are elections on November 5th in the United States if you read the opinion polls right now. It looks like Donald Trump is leading. the swing states that would result in his victory if he manages to become president, he made it very clear that, um, using his own words, this war would be over in 24 hours and what does he mean by that. I think he made it pretty clear too. that he would stop funding Ukraine if the United States stopped funding Ukraine. We provide about half of all financial aid to Ukraine, which means that Ukraine will probably lose the war or then we will have to double our bet and this money. 300 billion would solve that problem, it would basically be an insurance policy against that problem, there has been an institutional reluctance to take these measures, what impact do you think it would have on the market?

Market, um, I don't think it has any impact on The market is like that, one of the there are three or four big objections that are constantly dismissed and one of those objections is oh my God, if we confiscated this money that would totally destabilize the markets. international financial, um, that's it. It's just not true, the money that has been confiscated, I mean, I'm sorry that it's been frozen, if that money was confiscated by all the allies, if we didn't do it alone, if we did this together with the United States. States with the EU with Switzerland with Canada with Japan those are all the countries that have what are called reserve currencies, what is a reserve currency, it is a liquid currency in which people can store their money and the argument is that or the naysayers say if we were to confiscate this money then people wouldn't keep their money in our country or they wouldn't keep their money in the EU or they wouldn't keep their money in the US, but if everyone does it together, where Would people save their money?

I can guarantee you that they are not going to keep their money in RS Iranians are not going to keep their money in Argentine pesos and they are going to keep their money in stable economies there is the other word that is used in this This in this discussion are unexpected consequences, well , there really is a, I wouldn't say it's unexpected, an expected consequence, which is that the message here, if we do this, is that if you launch a war of aggression, an unprovoked war of aggression, eh. against a neighboring country that did nothing, its foreign exchange reserves are likely to be confiscated, well, who is it, who else is looking at a neighboring country that is considering a war of aggression, which has a lot of foreign exchange reserves, China and Um and China has a lot more to lose than Russia in this regard and I think we should think a lot about what we can do to deter China from disrupting the situation there with Taiwan and This is a pretty good example.

Just to boost the market situation a little more, the Royal United Services Institute has said that banks and central banks should commit to stabilizing the market in the event of the seizure of the release to Ukraine of seized Russian assets. What is their opinion about it? I don't think there is any need for stabilization. The main action. The main destabilizing action occurred a week after the war began. The action was us. froze the money, the money is no longer theirs, so, um, I mean, I can understand why the banks wouldn't want this to happen because it makes their lives difficult, if the money is being confiscated, by the way, I should point out.

I realized that all kinds of people told me for many years, while I was defending the Magnitsky ACT, that this would be completely impossible, would ruin everything, unexpected consequences, etc., and then, finally, the Magnitz ACT emerged and the only ones people who are now really unhappy with this are the people who are sanctioned. Basically, if you are not going to invade foreign neighbors, you have nothing to worry about and you know that 99.9% of the money is floating in the country. The international financial system has nothing to do with this type of action. I hear a strong opinion from you that actually the problem is simply the will to do this, unlike the problems in the market, everyone is afraid to do something different because it is different and there are many people who will cling to tradition because it's easier to do that, but let's also turn this around for a second.

Let's go back to the scenario that we have to continue funding this and maybe even double it. our financing because the United States takes a step back, so who finances it? The taxpayers of this country financed the taxpayers of the EU, so should Vladimir Putin's legal rights to your money be more important than the rights of the taxpayers of this country? I don't think so, and I don't think any of you would find any objection from your constituents if you hadn't had that conversation. I think we should think about ourselves before we think about him. You mentioned the EU a moment ago, on the 8th The EU announced plans to use the proceeds from seized Russian assets tohelp Ukraine.

What do you think of that action? Well, it seems to me a kind of typical EU compromise. There is no EU, there is no Mr or Mrs EU thinking about all the pros and cons when making decisions. You have 27 member states that are negotiating with each other about this with this argument and some arguments about why it shouldn't. do and then the arguments about why it should be done, which is right, is morally right, is financially right and is politically right and they had this argument between 27 people, 27 member states and and finally they came up with this kind of um uh fudge that it's um uh taking the prophets but not the capital and from my perspective first it's good to take something instead of nothing because because Ukraine needs the money, but from my perspective, um uh there's no difference. between taking the profits and taking the money and as far as you know, if we go to one of the other arguments about why this shouldn't be done, it's U, there's no legal way to do it which I don't agree with. and we can talk about how taking profits is different than taking the money, so I think this is in some ways unfortunate because it prolongs the inevitable, I mean, given your strong opinion that it's a hoax, but I think I think I heard you too to say that's at least something, um given that's at least something, do you think the UK should do the same at least in that move?

What I think the UK should do is what the US has done. Well, let me take a step back to the extent that there is any legal ambiguity about whether this money can be confiscated. The way you resolve legal ambiguity is to make laws, that's what you do for a living, you make laws and so the United States, um uh, to address potential legal ambiguity passed something called the repo law, the Repo Act was passed along with the $61 billion relief package and now they have resolved any legal ambiguities and the US government has the right to seize the money that What I would suggest be done here is some version of the repo law where, to the extent that there is any legal concern, you legislate to remove that legal concern so that it can be done properly here and the US and the UK get to that. decision, it puts more pressure on the EU to do the right thing in the end, maybe a very quick final question because you've talked about the idea of ​​bringing everyone together to take this action, given the, and I think you wrote about that. in your article, the US, Canada, Japan, the EU and Australia must unite around us.

What is the probability of that happening? Well, I mean, it ended up happening, so when I started, when I started the Magnitsky ACT campaign in 2012. Um, it was just the United States that did it and, by the way, what I mean by confiscating the stockpile shouldn't take us 10 years. like the Magnitsky Act, but I started with the United States and this is and I was just one guy, I wasn't, I wasn't, you know, the whole world consensus that we have now is that something has to be done, but we finally got Canada and then we got the UK and then we got the EU and Australia, all of them.

It will be the only morally logical and rational thing to do. Everyone will come to the right decision in the end, but it just takes a little international pressure. Diplomacy. Reality. The financial reality of the situation. So I think it's likely to happen, but it's not going to happen. This is going to happen unless we push it and that's what you know, fortunately in this fight over stockpile confiscation, it's not like just one guy pushing it, we have a lot of people who believe this is the right thing to do, okay? And just to clarify that you think it needs to be done multilaterally, it has to be done multilaterally because then you come back to the issue that you just raised, which is, if a country does it, it creates the perception that That's not a safe country if another country has not done so.

Thank you. I can only say that you are a complete inspiration to all of us campaigning for change. In all types of campaign spheres. So thank you very much. In your evidence, the committee. you talked about how we can confiscate Russian state assets, but I wanted to look at assets owned by sanctioned people. The UK has frozen assets worth £22.7 billion owned by private citizens and entities, but legally we do not have the tools to seize them. What measures would you suggest to confiscate those personal assets if we were to look at Canada's Special Economic Measures Act or something like that?

Well, I have a lot of experience in this area, going back to the Magnitsky case, so in the Magnitsky case my lawyer Sergey Magnitsky was killed for uncovering a 230 million dollar government corruption scheme. We traced the $230 million to many different countries. We then filed criminal complaints with the law enforcement authorities of those countries to freeze and confiscate that money and the crime took place in 2008. Sorry, 2007 and we are still involved in criminal cases or assisting different law enforcement authorities in criminal litigation in 2024, and What I have learned from this process is that EV every time you face an individual.

You know, using the legal system, which I think you have to do, is an extremely cumbersome process that takes a long time. I'm not saying it shouldn't be done, what I'm saying is that if we are seeking financial relief for Ukraine now um the Russian government has committed the crime they have committed a crime of aggression um we have custody of their money um and we can confiscate their money and everything is very clear when it reaches an individual, the big problem is that the individual has property rights and I don't think they have any. I don't think we should start confiscating people's money without going through the proper legal process.

And the problem with the property rights of those people is the first thing you should do. What I have to prove is that that individual, um, was somehow formally connected to the Russian government and therefore has some responsibility and then prove that and then you have to go through the rest of this process. I think that should be done. I don't believe it. Oligarchs who support the regime should have their money confiscated, but I think it is a longer-term process. I don't think we should unfreeze that money, but I think the resources needed to litigate will be uh. big and I think that's something that needs to be thought about separately, so I'm not saying it shouldn't be done, but I am saying that in terms of the emergency that we have on our hands right now, 80% of our efforts should be aimed at confiscate the state's money and then we can leave the other money frozen until we can figure out how to get it.

As of 23-Feb-17, two individuals and 298 entities have been subject to UK sanctions, but there are many companies and individuals supporting Russia's war in Ukraine that have not been sanctioned. These include both Russian officials and oligarchs if the government expanded the sanctions regime, who are the first people they should target? Well, so what I would say is we were looking at this and let me pull out the list, so yeah, so the US government had done a project in 2017, where they asked, I think it was The Treasury Department put together a list of who the Russian oligarchs closest to Putin were and it was a kind of official legal task.

The Treasury Department made a list of 96 people, it is a published list and from that list, in reality in the United Kingdom we have sanctioned 57, the United States has only sanctioned 30 and the EU has only sanctioned 25, so we've done better, which is good when I didn't know this until I got these numbers yesterday. um so that's good, but um uh that leaves us with 36 of these unsanctioned people, so what I would say is it's very easy, let's get the list that the United States has produced, I mean, we could produce our own own, but get the list that the U.S.

Treasury has put together, let's look at the list, let's say, look at all the um, the 36 people who have not been sanctioned and, um, uh, if based on the criteria that exist for the sanctions program, uh, for the invasion of Ukraine uh, then we should apply sanctions to them if the criteria are applied. I think that would be the simplest and most comprehensive way to do it. I don't want to mention individual names here today because I haven't. the investigation, but that's where it would start, let's hope 36 people are a little worried at the moment, well, yes, well on Parliament television, so, in 2000, in 2022, the government introduced a requirement for foreign companies who own land or property in the United Kingdom. reveal their true owners and foreign registered entities, this is how we found out that Igor uh shalof, a sanctioned member of Putin in a circle, owned two apartments in front of the Ministry of Defense that were worth about 1 million, but there are still a low legal loophole. because anyone who controls an offshore company can continue to hide the ownership of that trust, do you agree that we need to close the

loopholes

so that legislation also targets trusts?

There is absolutely no reason that transparency or sunlight should be the best disinfectant um and uh much better than any government regulation or anything like that, if everyone knows who owns what then we can know that the public can being upset about all this kind of stuff, any loophole that allows transparency to not exist should be closed and that's great. For example, there are probably some other types of

loopholes

like this where people can continue to hide their property and we shouldn't have any of that here as this should be a hostile environment for criminals, money launderers, dictators and other people.

No, there are many legitimate people in the world who can come here, spend their money, and bring good things to this country. We don't need criminals. I have another question, but I realize I've been talking for a while. So I sure have one last question: crack down on San individuals keeping money in the UK. Defense Think Tank Rusy has suggested we create tripwires. That is where a new crime is created for which these oligarchs would later be tried. Do you think it's a sensible way to go? Well, I'm not familiar with the details of the proposal, so I don't want to comment on that, but I do want to comment on one thing, which is really important, and that is, one of the things that I learned from all the work that we did in the Magnitsky case, is that there is a whole type of ecosystem of what we call facilitators, these are people who, um, lawyers, accountants, trustees, company. training agencies public relations firms that work on behalf of um bad people um to help them launder their money, hide their money and continue to manage their money when it's laundered and hidden and um one of the things that and and and I think that when we' We are talking about the amount of money that has been frozen in the UK, about 20.

I think the figure you mentioned was 23 billion, which is a drop in the bucket of how much money is actually in the UK and that belongs to people who have done bad things and The reason it is a lower number than the actual number is because a lot of the money is hidden, most of the money is still hidden. How can we show that money? I have an idea and I've been talking about this since the war started. that is, if we were to include a provision in the law in the next iteration of the sanctions law that said that any accountant, lawyer, trustee, etc., who worked for a sanction, a sanctioned individual would have a duty of law to come forward before the government and share the information about the ownership of the assets of the sanctioned individual if you take the poachers and turn them into game wardens, suddenly that 23 billion figure would probably increase to 230 billion and would probably make any future lawyer, accountant etc., wouldn't want to get involved in this unless they knew their clients were legitimate people, Angela, thank you very much.

I think we have talked about sanctioning state assets. But isn't it one of the features of the Putin regime that many state assets were actually taken out of Russia into the custody of particular oligarchs and there was a big battle between the old oligarchs and Putin-affiliated oligarchs? having control of a lot of these state assets that are essentially hidden in places like London, but so effectively that the individually owned assets aren't really individually owned at all, I mean, they're basically extensions of the state and Putin. you would expect them to be returned to you if you wanted to use them in any way, doesn't this for all intents and purposes dissolve the distinction between individually owned oligarch assets and state assets?

I think you're absolutely right, I mean, it's, it's um, I, we've done the work and we estimate that between the year 2000 and 2024, Putin and the top 1,000 officials have stolen a trillion dollars from the Russian state and Putin. he does not keep any of this money in his own name, the money is in the hands of trustees and oligarchs etc., and that is why that money should be tied up safely, there is no doubt, the only problem is that it is a much more legal case clear to pursue state moneygo after him. to unpack that and and I believe in property rights that youCan't you just know general terms and say that person is Russian, therefore his money should be confiscated?

No, I think that's wrong and you know we can't do that. That would be annoying, going back to your original question. It upset the financial markets because people thought they were in trouble just by having them, by being born in a country or by having a connection to a country that does something bad, that would put all their money at risk. I mean, everyone has property rights and the legal right to represent themselves, but I believe and completely agree with you that the majority of Russian oligarchs are trustees of Vladimir Putin and that the money being withheld is effectively the money that belongs to the Russian state and that and that The legal process should absolutely begin to try to take that money from them, but I'm just saying that it's going to be a very long and difficult road and, in terms of dealing with the current emergency, we shouldn't wait none any financial results, you know those financial results will come within a decade if properly litigated, not today property rights, human rights, the rule of law, very important for individuals, but what we have here is effectively a criminal enterprise that has um Stone in um. assets of you could call it the Russian State.

You could say that the Russian people use it in this network of arbitrary behavior and criminality of which the oligarchs are the most obvious examples. How do we overcome rights that are clearly there for a while? very good reason human rights property rights rule of law um to deal with this obvious OB washing that is going on and um yes we will respond to that and then there is another issue that I want to raise with you well I mean I think I think that um the laws are actually in place to do anything here, proceeds of crime, windfall wealth orders, etc., and again I have very, very direct experience in this area and a very unfortunate experience in this area which is, as I mentioned, the Magnitsky case. 230 million we traced all the money, most of the 230 million came to the United Kingdom and every time we discovered that the money was going to the country, we would file a criminal complaint with the relevant law enforcement authorities and, um, and in most countries , the police authorities.

The authorities opened criminal cases here in the UK, they did not. We filed a criminal complaint with the Serious Fraud Office. No case was opened before the economic crimes department or the Metropolitan Police. No cases of what used to be called serious organized fraud were opened. crime agency no case was opened with the hmrc no case was opened with the National Crime Agency no case was opened and um finally well, I'll tell you why finally one of the people I had written to afterwards that he retired from the National Crime Agency came to me and he and he said um, I, I thought a case should be opened and someone very high ranking in the National Crime Agency overruled me and put a lot of pressure on me to that he did not open a case, and what I have learned is that he did. t specific to our case um there are no cases there was not a single case of economic crimes um from Russia opened since Putin came to power in this country why um I don't think it's there I don't think it's malicious I think it is um the agencies This country's law enforcement agencies are poorly resourced.

I think per capita we spend much more than the United Kingdom on these issues, but also on the law. So, you start with a low budget at all these different agencies. and then you start and you have this thing where if a case goes to court and the government loses even on a minor procedural point in court, there is as you know a disclosure order that they issued, which was challenged and then the defendant wins. They have to pay like 50,000 to the other party for the costs of that particular request and these people don't even have the budget to start the case and therefore the incentives are so skewed against them.

What is the natural professional reaction of an official in the National Crime Agency or the Crown Prosecution Service or whoever they are? It just doesn't open cases which is why the UK is a hub for this type of fraudulent activity and has been infiltrated by Russian money so badly exactly exactly and I have direct experience working with many different countries this is the worst and I say no it's worse than like Lafia in Lafia, they can actually carry out criminal cases here, it's there, there's it's almost a pride not to do it um and the only way to solve it is to change the whole structure that is and I proposed this in the last bill of sanctions that was introduced, which is to remove any possibility of costs orders against the government and then the second thing to do is, um, if the government wins, if the National Crime Agency wins, they should keep the money and then use it to fund future processing, that's how I mean, this is easily fixed. a couple of lines but they slap it every time um SLA drops every time and this should be a totally multi-party issue there shouldn't be anyone against this um but what, but the people who are against this um are the legal community um, people are against this, they are people who simply make large amounts of money representing oligarchs, although aren't they?, but this is corrupting our country, it is not corrupting, it is corrupting our country and in the US.

The US can keep the profits. the Department of Justice keeps the profits when they issue these forfeiture orders. I think it is a devastating series of observations that we should take very seriously and I also think that your suggestions for changing them are simple, but it would be very, very effective if implemented, however, it would mean that the ecosystem that you were talking about of facilitators would be affected. their standards of living, that's not it and they would come to some committee like this and then I'll tell you how the world is going to completely change and it's impossible and if we do it everything will be bad and so on that's what will happen and and and somehow everything will come together. dilutes and This does not happen and I specifically worked on these specific amendments with your colleagues in Parliament in the last sanctions bill and everything was discarded, could you send them to us as well so we can have a look.

To them for our report, thank you, thank you, but I'm Steven, yes, but we're just following what Andel just said D and he just said the reality is, of course, we've already provided protection against uh, coming back against the FCA in certain areas, so it wouldn't be a surprise if we wanted to extend it to other agencies, the precedent already exists for us to use. Can I take you back to the beginning? Can we go over some of the differences in various regimes and the Institute of Chartered Accountants in England said that traditionally the UK financial sanctions regimes were aligned with the UK, sorry with the US and the US. , now they think that since the sanctions came to Russia, there has been some disparity in the sanctions system.

I guess this is followed by three questions: Do you agree with that point of view? Do you think the EU and the US aligned and, in fact, given what you said correctly in your open comments? These are these minor differences that don't really matter? the scale of sanctions that's in place is well, so it's a problem that we don't have harmonized sanctions and, um, and let me give you some examples, um, and like I said, the UK has actually done a better job in terms of sanctioning oligarchs than the US and the EU, so for example you have um uh vagit alak perov, he is the CEO of LC Oil.

LC Oil is one of Russia's largest oil companies and a big supporter of Putin, whom he has sanctioned here. in the UK, but he is not sanctioned in the EU or in us, you have Vladimir Pannan, he is sanctioned here Vladimir Panan is the CEO of Norel Nickel and he is also one of the people Putin has been assigning to buy interests in the foreign when a foreign corporation wants to withdraw from Russia and they have to sell for pennies on the dollar he has been one of the main recipients of uh uh of free money from people who withdraw he has been sanctioned here he has been sanctioned by the United States, but has not been sanctioned in the EU, so what do you do if you are panan?

You go to the EU. He can still travel to Coral and Calad Devol and Italy and all that kind of stuff. We can't control who they sanctioned, but there has to be a very big effort to do it and this is something that should really be pushed hard: harmonizing these sanctions so that you know that these people can't go anywhere because in the meantime they can find loopholes legal and, by the way, in the Magnitsky case itself, the EU does not have, uh, the EU only has human rights sanctions, they do not have corruption sanctions, we have human rights and corruption, we have human rights and corruption.

Etc., and all the people who were involved in the financial crime that Sergey Magnitsky was murdered for, they can't travel here, they can't travel to the US, they can't go to Canada, they can't go to Australia, but they can go anytime they want to the EU and until the EU plugs these loopholes it's a big problem because it doesn't achieve the goal, so at the beginning I think you said there were about 350 billion in sanctions. Have you made any estimates? How much money is evaded in sanctions due to discrepancies in various sanctions regimes? I don't have any estimates, but it's going to be a huge number because that's what these people do.

I mean, you have the discrepancy in the regime and then maybe just as important. you have discrepancy in the implementation, just, um, I mean, so I could estimate here and now, which is that we have estimated that a trillion dollars were taken out of Russia during this 24e period and we are only talking about a few have been captured hundreds of billions of dollars, so there is probably a much larger amount than 700 billion dollars of money that is still floating somewhere that has not been touched because sanctions or facilitators are hiding the money just in terms of implementation like Against the difference in regimes that you pointed out and we recognize that we should pressure governments to come together more.

Where do you think the best implementation of sanctions regimes is taking place? You have already talked about the repo law in the US and as I understand it, in the US there is now a law against wealth managers acting for sanctioned or potentially sanctioned persons or potentially sanctioned persons from sanctioned countries. That's right and it's a world leading way of cutting down networks so the US is always um uh. More aggressive sanctions in all types of law enforcement work and are probably best practice in terms of emulating things, but having said that the UK, as I've already mentioned, has sanctioned more oligarchs than the UK.

The United States is a kind of slow-moving super-tanker. You never want to be on the wrong side of America when it comes to any of these types of things. Here, we, um, you know, we are a little less. "Um aggressive about the whole thing and, like I said, a lot of these people have money in trusts, so you know, I can remember one story that was about a large property located in I think it was owned by Alisher Usmanov, who was one of the sanctioned individuals and um uh and I think one day before he owns this huge property in Hampstead and um and he transferred it to his sister one day before the whole sanctions program came in and she became the beneficiary of the trust that owns the property and therefore we should look at each of these sanctions evasion mechanisms that they use and we should legislate against it in the future and it is about moving things, presumably if we had a regime like the personal regime politically exposed a sanctions regime for exposed persons I you may be politically exposed so your family members have to declare things if we had the same type of regime in place and it was implemented multilaterally that would start to fill the gap that you were Talking about: Yes and one last question, if I may, you know?

We have talked about the different regimes that exist, especially in implementation. How would you propose that the UK government should achieve a multilateral agreement? What are we doing? What should we do? of persuading others to fill the gaps in their regimes. I think the best way to get people to fill the gaps in their regimes is to point out that, you know, where they're not appropriate, you know, sometimes diplomacy is appropriate. sometimes polite diplomacy is appropriate and sometimes one should be a little less polite and we are, you know, we are in a war right now, whether we want to, you know, admit it or not, there is a war going on. and we are participants and we should not make any mistake about it and right now we can fight this war right now there is no bloodshed coming from there is not there is not a drop of blood from aBritish soldier um but we We are fighting a financial war and we should fight as hard as we can because that is the battlefield we are on now.

Thank you very much for his evidence, Mr Bradder, and for his entire campaign. Can you just take these final opportunities and anything else that you want to recommend to this committee, before we close this panel, well, the one thing that we haven't talked about and I think you're going to talk about that in your next session is the um. uh the oil and where it goes and I have the names of the refineries that refine the Russian oil and sell it to us and I just want to put it out there, get it on the record so you know that we should think about putting sanctions on these refineries or creating some kind of legislation on the one that we are not allowed to buy oil from these refineries or or and Get them and I'm just going to post them here for the record.

We in India have the Vinar refinery, which is 49% owned by the Russian state oil company Rosneft, and they receive Russian oil and sell Russian oil. refined product that reaches us, we have the Jam Nagar refinery in Cooch Golf, on the western coast of India, which is an important destination for the Russian crew that arrives in India, we have Barat oil, which is a company state, and then we have Hindustan. oil another state company in Turkey we have Star Refinery which concluded an agreement with the Russian oil company Luke Oil and in China we have the Copek group and cnoc.

I think those are all communications companies that buy Russian oil when we talk about India, China and Turkey, we are talking about specific companies, we don't have to sanction India, China and Turkey, we can just go after the companies that are buying the oil and just me saying that, probably, here in a public setting, on the record, where um uh it's. but if you start saying that, if you put this in your report, you know that's the kind of pressure that these companies don't need, I mean, they can get oil from anywhere they don't have to to take Russian oil and if the oil Russian doesn't find a home that easily, the price goes down, they will make less income and have less money to fight this war.