---
title: "Evidence records"
language: en
canonical: https://dossiertwist.com/dossiers/the-ultima-world-dmcc/evidence-records/
as_of: 2026-10-15
keywords: ["THE ULTIMA WORLD DMCC","FG BCS LTD","BCS Financial Group","Oleg Mikhasenko","Alexey Annenkov","Vitaly Shelikhovsky","The Ultima Investments Cyprus","The Ultima Structured Products","The Ultima World (DIFC)","BCS Capital (DIFC)","The Ultima Global Markets (USA)","BCS Americas","The Ultima Global Markets Qazaqstan","BCS Holding","BCS Bank","Dubai Multi Commodities Centre","DFSA","FINRA","CySEC","AIFC"]
---

# Evidence records

**Question.** Which records support the articles?

**Answer.** Full assertions with source references, qualifications, responses and known outcomes. The topic articles explain these records in context.

## Registration, names and identifiers of THE ULTIMA WORLD DMCC

- Documented: THE ULTIMA WORLD DMCC was incorporated on 24 September 2015 as a limited liability company under the Cyprus Companies Law, Cap. 113. Since 22 December 2023 it has been domiciled and registered as a free zone company in the Dubai Multi Commodities Centre (DMCC), United Arab Emirates, under registration number DMCC198649; its DMCC licence DMCC-912051 permits investment in commercial enterprises and management. [src-001]
- Documented: The DMCC Authority's public list of transfers of incorporation records FG BCS LTD DMCC, formerly FG BCS LTD of the Republic of Cyprus, with registration number DMCC198649, a registration date of 22 December 2023, a transfer date of 28 December 2023 and service licence DMCC-912051 issued on 28 December 2023. [src-007]
- Documented: The company's 2025 note programme prospectus states that the group sold the Russian segment of its business in 2023, will continue to operate mainly in the UAE and Cyprus, and that the company was redomiciled to the DMCC in December 2023. It describes the company's legal form as initially a Cypriot limited liability company and currently a DMCC free zone company, and states that the company does not have a website. [src-001]
- Documented: Copies of the Cyprus register published by registry aggregators show FG BCS LTD as a private limited company, registration number HE 347295, registered on 24 September 2015, with the status 'dissolved'; one copy dates the dissolution 22 December 2023, the day of the DMCC registration. The last registered office shown is Krinou 3, The Oval, Agios Athanasios, Limassol, the last annual return shown is dated 18 October 2020, and the last officers listed are Alexey Annenkov as director and Sinirmacorp Limited as secretary. [src-009] [src-021] [src-085] [src-127]
  - Qualification: The register copies come from private aggregators; their free pages do not show appointment dates or shareholders.
- Documented: An undated copy of the Cyprus register, taken while FG BCS LTD (HE 347295) was still shown as active, lists ALLYSERA PROPERTIES LTD as its previous name, a registered address at Prevezis 13, Floor 1, Flat 101, 1065 Nicosia, Vitaliy Shelikhovskiy as director and Largos World Limited as secretary. [src-020]
  - Qualification: The snapshot is undated and comes from a registry aggregator; later register copies and the company's own accounts list different officers.
- Documented: The company was renamed from FG BCS LTD DMCC to THE ULTIMA WORLD DMCC in early 2025. Its Cypriot subsidiary announced on 11 February 2025, when taking the name The Ultima Investments Cyprus Limited, that its parent had changed its name as part of the rebranding; a notice to noteholders published on 20 May 2025 gives 9 January 2025 as the effective date; the GLEIF record shows the legal-name change as effective on 6 February 2025. [src-011] [src-039] [src-018]
  - Qualification: The sources give two different dates (9 January 2025 in the notice to noteholders and 6 February 2025 in the LEI record); the DMCC register entry for the change was not retrieved.
- Documented: The GLEIF record for LEI 213800GU1EOKGT4JCA10 (golden copy of 15 October 2026) shows THE ULTIMA WORLD DMCC as an active entity registered with registration authority RA000715 under DMCC-912051, jurisdiction AE, created on 24 September 2015, with legal and headquarters address at Unit AG-PF-23, AG Tower, Plot JLT-PH1-I1A, Jumeirah Lakes Towers, Dubai. The LEI was first registered on 18 January 2017, has the status ISSUED with full corroboration, and is due for renewal on 26 January 2027. [src-018]
- Documented: GLEIF's event history for the LEI records a change of legal name and of legal and headquarters address effective 22 December 2023 (recorded on 16 April 2024), and a further change of legal name effective 6 February 2025; the previous legal name is recorded in Arabic script as the DMCC form of FG BCS LTD. Each event is validated by an accounts filing. [src-018]
- Documented: The GLEIF record names no parent company for THE ULTIMA WORLD DMCC: both the direct-parent and ultimate-parent fields carry a reporting exception, whose reason is not shown in the retrieved record. [src-018]
  - Qualification: A reporting exception does not itself identify the owner; ownership is documented from other records.
- Documented: The 2025 prospectus gives the guarantor's address as Unit AG-PF-23, AG Tower, Plot JLT-PH1-I1A, Jumeirah Lakes Towers, Dubai, with an e-mail address on the theultima.ae domain and a telephone number with the Cyprus country code. The March 2024 prospectus names the guarantor as FG BCS LTD DMCC at the same address, with the same telephone number and an e-mail address on the fgbcs.cy domain. [src-001] [src-034]
- Documented: The March 2024 prospectus describes the principal activities of the guarantor, then FG BCS LTD DMCC, as serving as an investment holding and financing company. [src-034]
- Documented: FINRA's BrokerCheck report on the group's US broker-dealer lists THE ULTIMA WORLD DMCC as a controlling entity with the business address Prevezis 13, 1st floor, office 101, 1065 Nicosia, Cyprus, effective 9 January 2025. [src-006]
  - Qualification: The address is the one recorded in the undated Cyprus register snapshot of FG BCS LTD, not the company's DMCC address.
- Documented: Russian registry data shown by a company-information aggregator list a 'Moscow branch of the limited liability company FG BCS LTD' with taxpayer number 9909441658, registration code (KPP) 774791001, the date 25 May 2020 in the registration field and main activity code 70.10 (activities of head offices), and name Oleg Vladimirovich Mikhasenko as its head as of 15 October 2026. A second card on the same aggregator for the same taxpayer number shows a Novosibirsk address at Sovetskaya Street 37 and main activity code 64.20 (activities of holding companies). [src-032] [src-133]
  - Qualification: The aggregator page does not show the branch's current status; the second card's dates are hidden.
- Documented: According to Russian tax data shown by a company-information aggregator, FG BCS LTD DMCC was registered with the Russian tax authorities as a foreign organisation under taxpayer number 9909677815 from 24 April 2024 to 19 December 2024, and the registration was no longer active on 15 October 2026. [src-117]
- Documented: A Kazakh business directory shows an entity named THE ULTIMA WORLD DMCC (business identification number 230250008707) registered in Astana on 7 March 2025 with foreign ownership and a legal address at Mangilik El 60, Yesil district, and names Alexey Vladimirovich Annenkov as its first head as of 7 September 2026. [src-055]
  - Qualification: The directory does not say whether this is a branch, representative office or other registration of the DMCC company; its activity, founders and branches are hidden.
- Documented: Before its transfer to the DMCC the company had share capital of 344,000 fully paid shares of EUR 1 each. On its DMCC registration on 22 December 2023 the shares were converted into 50 shares of AED 1,000 each, giving share capital of AED 50,000; the resulting reduction of share capital, USD 333 thousand, was paid to the shareholder in 2024. [src-034] [src-045] [src-001]

## Owner and group structure of THE ULTIMA WORLD DMCC

- Documented: The company's own documents name Oleg Mikhasenko as its sole beneficiary and ultimate controlling party. The April 2025 prospectus states this for the company and describes him as the sole ultimate beneficial owner of the group; the audited consolidated financial statements for 2022 state that he is the sole beneficiary and ultimate controlling party of the group. [src-001] [src-015]
- Documented: FINRA's BrokerCheck report on the US broker-dealer lists THE ULTIMA WORLD DMCC as a foreign entity shareholder owning 75% or more since July 2016 that directs the firm's management or policies, and lists Oleg Vladimirovich Mikhasenko as the individual through whose shareholding in THE ULTIMA WORLD DMCC indirect ownership is established, with 75% or more and a relationship established in June 2016. [src-006]
- Documented: BCS Bank's list of the persons controlling the bank, dated 6 December 2021, shows the ownership chain at that time: FG BCS LTD held 99.9994% of the voting interests in Siberian Investments LLC and O. V. Mikhasenko 0.0006%; Mikhasenko held 100% of the voting shares of FG BCS LTD; Siberian Investments owned 100% of the bank's shares, held through BrokerCreditService Company LLC as nominee holder; and Mikhasenko is named as the person under whose control and significant influence the bank is. [src-031]
  - Qualification: The disclosure is a copy published by a bank-analytics website; Siberian Investments LLC is the earlier name of BCS Holding LLC (same state registration number 1025403198710).
- Documented: In 2016 the BCS Financial Group introduced FG BCS Ltd. as its new top-level holding company and said it would eventually liquidate the previous holding company, BCS Holding International Ltd; S&P assigned 'B-/C' ratings to FG BCS Ltd and withdrew its 'B-/C' ratings on BCS Holding International Ltd at the group's request. [src-011]
  - Qualification: Reported in a ratings note retained on the news page of the group's Cypriot investment firm.
- Documented: According to the audited 2018 financial statements of Brokercreditservice Structured Products Plc, the company was a wholly owned subsidiary of BCS Holding International Limited, a British Virgin Islands holding company previously named Amazon United Limited, until 2016; in 2016 BCS Holding International Limited was liquidated and FG BCS Limited, with its registered office at Prevezis 13, Nicosia, became the direct and ultimate holding company of Brokercreditservice Structured Products Plc. [src-067]
- Documented: The same statements record that Flamel Global Limited, Seldthorn Private Equity Limited and Kertina Group Ltd, until then part of Brokercreditservice Structured Products Plc's group, were transferred to the parent company FG BCS on 21 June 2017, leaving Routa Luxury Services Ltd and Botimelo Group Ltd as its wholly owned operating subsidiaries. [src-067]
- Documented: The summary attached to the final terms of Brokercreditservice Structured Products Plc's Series 2017-16 notes, dated 8 November 2017, states that the issuer is a subsidiary of FG BCS Ltd., incorporated and domiciled in Cyprus, whose other subsidiaries are BCS Prime Brokerage Limited, BrokerCreditService (Cyprus) Limited, Siberian Investments LLC, BCS-Forex Ltd, BCS Investment Management Ltd and BCS Americas Inc., and that Oleg Mikhasenko is the ultimate beneficial owner of the group. It names Routa Luxury Services Ltd. and Botimelo Group Ltd. as the issuer's two subsidiaries. [src-040]
  - Qualification: Republished in August 2024 with a notice amending the notes.
- Documented: FG BCS LIMITED's audited consolidated financial statements for 2022 list the group's main operating companies with the group's ownership or voting interest at 31 December 2022 (and 2021): Brokercreditservice Ltd. in Russia 99.9% (99.9%); BrokerCreditService (Cyprus) Limited 100% (100%); BCS Capital (DIFC) Limited 100% (100%); BCS Bank in Russia 100% (100%); the Russian management company BrokerCreditService 100% (100%); the Russian real-estate fund manager of Brokercreditservice 0% (100%); BCS Prime Brokerage Limited in the UK 100% (100%); BCS Wealth Management, formerly URALSIB AM, 100% (100%); Brokercreditservice Structured Products PLC 100% (100%); Kertina Group Ltd. 100% (100%); Seldthorn Private Equity Ltd. 0% (100%); two further Russian companies in consulting and insurance 99.9% (99.9%); and BCS Americas 100% (100%). [src-015]
  - Qualification: The list gives the group's direct or indirect interest; it does not say which group company holds each stake.
- Documented: The 2022 statements add that the group has other, unnamed subsidiaries that are consolidated on the basis of trust agreements with their direct owners, and that the group exercises full control over their financial, strategic and operational activities for the group's benefit. [src-015]
  - Qualification: The statements do not name these subsidiaries or their direct owners.
- Documented: The March 2024 prospectus lists the guarantor's main operating subsidiaries as BrokerCreditService (Cyprus) Limited, BCS Prime Brokerage Limited, an FCA-authorised UK firm since 19 June 2013, Brokercreditservice Structured Products Plc, BCS Capital (DIFC) Limited and BCS Americas, Inc. [src-034]
- Documented: The April 2025 prospectus states that the guarantor directly or indirectly owns The Ultima Investments Cyprus Limited (98.0%), Brokercreditservice Structured Products Plc (99.96%), The Ultima World (DIFC) Limited (100%) and BCS Americas, Inc. (100%) as the main operating companies of the group, and that the issuer, The Ultima Global Markets Qazaqstan Limited, is wholly owned by the guarantor. [src-001]
- Documented: The audited consolidated statements for 2024 list the group's operating subsidiaries at 31 December 2024 (and 2023): The Ultima Investments Cyprus Limited 98.0% (98.0%); The Ultima World (DIFC) Limited 100% (100%); GBM Securities limited, formerly BCS Prime Brokerage Limited, none (100%); The Ultima Structured Products PLC 100% (100%); The Ultima Global Markets (USA) Inc. 100% (100%); The Ultima Global Markets Qazaqstan Limited 100% (100%); The Ultima Investment Hong Kong Limited 100% (none); and The Ultima Products HK Limited. [src-045]
  - Qualification: In the retained text the percentage column for The Ultima Products HK Limited is cut off; its acquisition in August 2024 is described in the same statements.
- Documented: The audited consolidated statements for 2025 list seven operating subsidiaries at 31 December 2025, with unchanged interests from 2024: The Ultima Investments Cyprus Limited (98.0%), The Ultima World (DIFC) Limited, The Ultima Structured Products PLC, The Ultima Global Markets (USA) Inc., The Ultima Global Markets Qazaqstan Limited, The Ultima Investment Hong Kong Limited and The Ultima Products HK Limited (each 100%). The list does not include The Ultima Fintech Qazaqstan, The Ultima Asia Limited, Spidertek Ltd, LTM SV LLC or Brokstock SA (Pty) Ltd. [src-051]
- Documented: GLEIF lists five active companies as direct children of THE ULTIMA WORLD DMCC's LEI: The Ultima Global Markets Qazaqstan Limited (AIFC private company 221040900440, created 18 October 2022, formerly BCS Global Markets Qazaqstan Limited); The Ultima World (DIFC) Limited (DIFC company 3568, created 26 November 2019, formerly BCS Capital (DIFC) Limited); The Ultima Global Markets (USA) Inc. (New York registration 2282967, created 27 July 1998, formerly BCS Americas, Inc.); The Ultima Structured Products PLC (Cyprus ΗΕ 158664, created 18 March 2005, formerly Gawling Company Limited and Brokercreditservice Structured Products PLC); and The Ultima Investments Cyprus Limited (Cyprus ΗΕ 154856, created 7 December 2004, formerly BrokerCreditService (Cyprus) Limited). [src-019]
- Documented: LEI relationship data shown by a company-information aggregator record FG BCS LTD as the highest-level owner of LLC BCS-Commodity Markets from 2 November 2018, of BCS Capital (DIFC) Limited from 26 November 2019 and of The Ultima Structured Products PLC from 1 January 2023. [src-085]
- Documented: On 30 May 2022 the group disposed of its subsidiary Seldthorn Private Equity Ltd to the group's ultimate shareholder, Oleg Mikhasenko; the difference between the subsidiary's negative net assets and the consideration received, RR 1,092,275 thousand, was recognised as a contribution from the shareholder. [src-015]
- Documented: On 22 June 2022 the group disposed of its subsidiary LLC FG Aviation to Heelveil Ltd and on the same day disposed of Heelveil to a third party, which the statements do not name. No cash consideration was received; FG Aviation carried property, equipment and intangible assets of RR 1,933,623 thousand and loans payable of RR 2,407,104 thousand, and the group booked a gain of RR 447,542 thousand on the disposal. [src-015]
- Documented: During 2023 the group disposed of another subsidiary, Danofe Trading Limited, to the group's ultimate shareholder, Oleg Mikhasenko, and recognised the difference between the subsidiary's net assets and the consideration as a contribution from the shareholder. A copy of the Cyprus register (HE 250921, registered on 9 June 2009) shows Danofe as dissolved following voluntary liquidation, with Alexey Annenkov among the officers last on file as director. [src-045] [src-065]
- Documented: The group's UK broker BCS Prime Brokerage Limited, renamed GBM Securities limited on 29 July 2024, was sold under a sale and purchase agreement signed on 23 December 2023; the Financial Conduct Authority approved the deal and it was completed on 27 June 2024. The group received non-cash consideration of USD 49,253 thousand and recorded a net gain on disposal of USD 14,310 thousand. [src-045]
  - Qualification: The 2024 statements do not name the buyer.
- Documented: On 23 August 2024 the group acquired 100% of The Ultima Investment Hong Kong Limited and The Ultima Products HK Limited from a related party. For The Ultima Investment Hong Kong Limited it paid USD 226 thousand for identifiable net assets of USD 115,739 thousand (total assets USD 593,426 thousand) and recorded USD 115,513 thousand as a contribution from the shareholder; from the acquisition date that company contributed USD 49,504 thousand of the group's net income. [src-045]
  - Qualification: The statements do not name the related-party seller.
- Documented: Since 2021 the group has held a significant-influence stake in Ginmon GmbH, a privately held German robo-advisory company accounted for by the equity method: 28.35% at the end of 2022 and 2024 and 28.26% at the end of 2025. The investment's carrying amount fell to nil in 2024 after a goodwill impairment of USD 1,110 thousand. The group also has significant influence over TFS Hi-Tech, carried at USD 360 thousand at the end of 2023, 2024 and 2025. [src-015] [src-045] [src-051]
- Documented: Kertina Group Ltd, a Cypriot company (HE 341236) wholly owned by the group at the end of 2021 and 2022, was dissolved on 9 March 2025 on completion of a voluntary liquidation; its LEI was retired, with the dissolution recorded in GLEIF on 6 June 2025. [src-050] [src-167] [src-015]
- Documented: Routa Luxury Services Ltd (Cyprus HE 290594, registered 21 July 2011), a subsidiary of Brokercreditservice Structured Products Plc in 2017–2018, was dissolved on 10 February 2022 on completion of a voluntary liquidation; the open register data list Alexey Annenkov as its last director and a registered office at Vashiotis Kalande Offices, Mesa Geitonia, Limassol. [src-083] [src-040] [src-067]
- Documented: On 15 April 2019 Brokercreditservice Structured Products Plc sold its subsidiary Botimelo Group Ltd to Heelveil Ltd. GLEIF records Botimelo Group Ltd as a British Virgin Islands company (registration 1803398) whose dissolution took effect on 6 September 2019 and whose LEI is inactive. [src-067] [src-082]
- Documented: In a reply of 17 March 2021 to a tax-authority demand, quoted in the rulings, FG BCS LTD described itself as the head holding company of the BCS financial group, whose role is shareholder control and protection of assets, strategic management of the group and centralisation of certain operational functions, including decisions on the use of free cash, among it dividends received from group companies, that is, the redistribution of financial resources within the group. [src-116]
- Documented: The UK register lists Vitaliy Shelikhovskiy as a director of GBM Securities Limited from 20 April 2012 to 2 June 2014 and Edward Golosov from 8 March 2013 to 11 July 2024; for each of them this is the only UK company appointment on record. [src-014] [src-087] [src-110]
- Documented: The Cyprus register lists Seldthorn Private Equity Limited (HE 330001) as a private company registered on 26 February 2014 at Spyrou Kyprianou & 1 Oktovriou 1, Vashiotis Kalande Offices, Mesa Geitonia, Limassol; at the time of the research its status was 'reminder letter sent'. [src-023]

## Oleg Mikhasenko: owner of the group

- Documented: The April 2025 prospectus describes Oleg Mikhasenko as a Russian natural person who, as of the prospectus date, is not subject to any sanctions and has no political exposure, and warns investors that he is not immune from further sanctions against Russia. [src-001]
  - Qualification: This is the issuer's own statement as of 17 April 2025.
- Documented: The audited financial statements of the Kazakh subsidiary name THE ULTIMA WORLD DMCC (former FG BCS Ltd) as its sole shareholder and Oleg Mikhasenko as the ultimate controlling party. The statements for 2024, authorised for issue on 26 May 2025, describe him as a resident of Russia; the statements for 2025, authorised on 29 May 2026, describe him as a resident of the UAE. [src-036] [src-033]
- Documented: A Russian technology-industry biography describes Oleg Vladimirovich Mikhasenko as a co-founder in 1991 of the brokerage partnership BrokerCreditService (BCS) and, since June 1995, president and main shareholder of the BCS financial group. It lists him as deputy general director (2009–2011) and then president and chairman of the management board of BCS Company from 17 January 2011, a member of the board of BCS Bank from 27 June 2012 and its chairman from 3 September 2020, managing director of FG BCS LTD's operations department from 1 February 2018 to 24 May 2020, and part-time director of FG BCS LTD's Moscow branch from 25 May 2020. It also records board seats at SPB Exchange from 17 May 2019, at Uralsib Management Company, later BCS Wealth Management, as chairman from 23 December 2019, and at BCS Global Markets Holding from 15 January 2020. [src-124] [src-013]
- Documented: The UK companies register recorded Mr Oleg Mikhasenko, a Russian national resident in Russia, as a person with significant control of the group's UK broker GBM Securities Limited (company 08040031), with 75% or more of the shares and voting rights, from 6 April 2016 until 27 June 2024, the day the group completed the sale of the company. [src-012] [src-045]
- Documented: Records from a leak of offshore-company data current to 2010, published by an investigative journalism organisation, list 'Mr. Oleg Mikhasenko' as a shareholder from 24 April 2006 of Amazon United Limited, a company incorporated on 29 March 2006 with Commonwealth Trust Limited as agent and links to Russia and the British Virgin Islands; a corporate director held office on 29–30 March 2006 and was followed by an individual director. Amazon United Limited is the former name of BCS Holding International Limited, the British Virgin Islands company that was the group's top holding company until 2016. [src-155] [src-067]
  - Qualification: Appearance in leaked records does not in itself indicate wrongdoing. The identification of the shareholder with the subject's beneficial owner rests on the name and on Amazon United's later role as the group's holding company.

## The Russian BCS business before and after 2023

- Documented: GLEIF also lists a Russian company, LLC BCS-Commodity Markets (state registration 1125476080762, Sovetskaya Street 37, office 225, Novosibirsk), among the LEI's direct children; that company's own LEI has the status LAPSED, with its last renewal due on 4 September 2020. [src-019]
  - Qualification: A lapsed LEI is no longer updated; the company was liquidated in October 2020, so the parent relationship reflects the position before liquidation.
- Documented: Russian registry data shown by aggregators record LLC BCS-Commodity Markets (registered 15 May 2012) as owned from 2 November 2018 by 'Company FG BCS LTD' (99.9%) and Siberian Investments LLC (0.1%), after earlier ownership by JSC Management Company of Funds, and as liquidated on 28 October 2020. [src-109] [src-052] [src-144]
  - Qualification: One aggregator hides the foreign participant's registration number; the earlier participants and exact dates come from a second aggregator's observation windows.
- Documented: According to FG BCS LIMITED's 2022 consolidated statements, the group decided on 10 January 2023 to terminate its activities in Russia and to sell BCS Holding LLC, a wholly owned subsidiary whose brokerage, retail and investment banking, depository and asset management business made up the whole of the group's Russian segment. In January 2023 FG BCS Ltd was deregistered with the Russian tax authority and renounced its status as a Russian tax resident. On 19 January 2023 the group sold BCS Holding LLC to its ultimate shareholder, Oleg Mikhasenko, for RR 9,990 thousand; the difference of about RR 43 billion between the net assets disposed of and the consideration was accounted for as a distribution to the shareholder. [src-015] [src-001]
- Documented: Russian state-register data reproduced in a sanctions and company dataset record FG BCS LTD (Cyprus HE 347295) as the holder of 99.9994% of BCS Holding LLC from 4 August 2016 to 26 January 2023, and Oleg Vladimirovich Mikhasenko as the holder of the remaining 0.0006% from 24 April 2019 to 26 January 2023. [src-003] [src-005]
  - Qualification: These are register extracts relayed by a sanctions-data aggregator; they are consistent with the control disclosure filed by BCS Bank.
- Documented: A Russian technology-industry publication reported on 19 July 2025 that Oleg Mikhasenko, as owner of BCS Holding, had sold the group to its general director, Vitaly Shelikhovsky, with a perimeter covering all subsidiaries, including the broker BCS, BCS Bank, BCS Forex, the life insurer BCS Life Insurance, BCS-Technologies, BCS-Fintech and the management company UC BCS. [src-013] [src-005]
  - Qualification: Press report; the price and terms were not found in the retained records. Registry data show Shelikhovsky as the majority participant of BCS Holding from July 2025.
- Documented: Russian registry data reproduced by several aggregators show that since 18 July 2025 Vitaly Shelikhovsky has held 99.9% of BCS Holding LLC, a nominal stake of RUB 15,292,390,302, and that the remaining 0.1%, RUB 15,307,698, is held by Alexandra Olegovna Mikhasenko. A stake of the same size was held from 27 January 2023 by Natalya Olegovna Mikhasenko, who by October 2026 held no participation in any company. [src-005] [src-070] [src-080] [src-081] [src-069] [src-118]
  - Qualification: The aggregators do not give the size of each stake held between 26 January 2023 and 18 July 2025; one of them records Oleg Mikhasenko, identified by his Russian taxpayer number, as a participant in an observation window from 24 April 2019 to 17 July 2025. The records state no family relationship between the persons named.
- Documented: BCS Holding LLC, formerly Siberian Investments LLC, was registered in Novosibirsk on 13 November 2002 under state registration number 1025403198710; its registered address is Sovetskaya Street 37, Novosibirsk, its share capital is RUB 15,307,698,000, its main activity is other financial services, and Vitaly Shelikhovsky is its director. [src-017]
- Documented: Russian registry data show the current participants of BrokerCreditService Company LLC (BCS Company), the Russian broker, as BCS Holding LLC with 81.861% (RUB 6,281.91 million), the closed-end combined unit investment fund 'FNB Business' with 18.04% (RUB 1,384.26 million) and Alexandra Olegovna Mikhasenko with 0.099% (RUB 7.668 million). Natalya Olegovna Mikhasenko had held a 0.099% stake from 11 December 2025. An aggregator also records Oleg Mikhasenko, identified by his Russian taxpayer number, as a participant in an observation window from 25 August 2015 to 10 December 2025, without his share. Vitaly Shelikhovsky has been BCS Company's general director since 20 August 2013. [src-079] [src-174] [src-005] [src-080] [src-081] [src-071] [src-118]
  - Qualification: One dataset dates BCS Holding's 81.861% stake from 10 February 2003; the aggregators' other dates are observation windows rather than registration dates.
- Documented: Earlier participants of BCS Company recorded by a company-information aggregator include the management company JSC UK BrokerCreditService, replaced in November 2025 by JSC BCS Wealth Management, and LLC UK BrokerCreditService-Real Estate Funds between November 2018 and November 2020. [src-071]
  - Qualification: The aggregator marks these dates as its observation windows, not register dates.
- Documented: A list of BCS Company's holdings shown by a company-information aggregator records it as owner of 100% of BCS-Forex LLC, which the 2017 note summary listed as a subsidiary of FG BCS Ltd. [src-079] [src-040]
- Documented: Vitaly Shelikhovsky was the director of Siberian Investments LLC, the later BCS Holding, when BCS Bank filed its December 2021 control disclosure. Russian registry data show him as director of BCS Holding, general director of BCS Company since 20 August 2013 and general director of BCS FT LLC since 16 October 2024. [src-031] [src-174] [src-166] [src-017]
- Documented: BCS Fintech LLC, a Moscow software developer, has been wholly owned by BCS Holding since 22 August 2019; until 28 December 2020 BCS Bank was also recorded as its founder. Dmitry Valerievich Ivanov became its general director on 24 November 2021, and on 1 April 2026 also general director of BCS-Technologies LLC. For 2025 BCS Fintech reported revenue of RUB 5.2 billion, a net loss of RUB 17.5 million and an average of 977 employees. [src-135] [src-056]
- Documented: BCS FT LLC, a Moscow company formed in September 2024, has been wholly owned by BCS Holding since 15 September 2024; its first general director served for one month, and Vitaly Shelikhovsky has been general director since 16 October 2024. [src-166] [src-005]
- Documented: At 31 December 2024 the Kazakh note issuer held KZT 6,501,332 thousand of its KZT 6,794,610 thousand of cash and equivalents with JSC BrokerCreditService in Russia and KZT 17,303 thousand with JSC Raiffeisen Bank in Russia; a year earlier it held KZT 45,933 thousand with JSC BCS Bank. Its related-party note shows KZT 6,499,728 thousand of cash and equivalents with other parties under the control of its sole shareholder's owner, and trade payables to them of KZT 5,908,701 thousand. [src-033]
  - Qualification: The related-party table labels these counterparties only as 'other parties'; the bank-by-bank table identifies the Russian broker.
- Documented: The Kazakh issuer's 2024 statements describe a reverse repurchase agreement entered into on the Moscow Exchange, collateralised by MTS securities, denominated in roubles and carrying an interest rate of 22.67% a year; the issuer closed its remaining reverse repo transaction in early 2025. [src-033]
- Documented: JSC BCS Bank was registered on 2 February 2005 and has its registered address at Konyushkovskaya Street 31, building 1, Moscow; its share capital is RUB 3,243,983,530, its main activity is other monetary intermediation and no termination of its activity is recorded. Russian registry data name Marina Rodionova as head of its management board; according to the registry history she has led the board in an acting capacity three times: from 12 November 2013 to 29 March 2016, from 17 October 2016 to 7 March 2018 and since 8 September 2020. [src-057] [src-090]
- Documented: The group acquired JSC BCS Wealth Management on 19 December 2019 and at the end of 2022 carried goodwill of RUB 1,023,383 thousand for it, after an impairment of RUB 79,365 thousand. The company, named JSC Management Company URALSIB until 21 October 2021, disclosed Siberian Investments LLC, the later BCS Holding, as its sole shareholder at the end of 2020; on 9 November 2021 the Bank of Russia reissued its licence to manage investment funds, unit investment funds and non-state pension funds under the new name. Registered on 21 November 1996, it is based at Prospekt Mira 69, building 1, Moscow, has share capital of RUB 85 million and has been headed by Marina Popova as acting general director since 25 March 2024. [src-015] [src-124] [src-169] [src-136] [src-058] [src-089]
  - Qualification: Russian registry data reproduced by an aggregator still list the company's earlier founders, the oil investment company NIKoil and Financial Corporation URALSIB, up to 20 October 2021; those dates are observation windows and do not show when the shares changed hands.
- Documented: JSC Management Company BCS, registered on 29 January 1998 at Sovetskaya Street 37, Novosibirsk, with share capital of RUB 202.6 million, manages securities; its general director is Albert Galimnurov, who as general director of JSC Management Company URALSIB signed that company's shareholder disclosure for the end of 2020. LLC Management Company BCS-Real Estate Funds, registered on 12 July 2006 at the same Novosibirsk address with share capital of RUB 60 million to manage investment funds, is headed by a liquidator. [src-072] [src-073] [src-169]
- Documented: LLC BCS-Forex was registered on 23 July 2015 at Prospekt Mira 69, building 1, Moscow, with share capital of RUB 1 billion; its main registered activity is other financial services and Taras Danilyuk has been its general director since 9 March 2021. [src-094] [src-123]
- Documented: JSC Upravlyayushchaya Kompaniya Fondov, one of the three buyers of Tyazhstankogidropress shares from Viktor Aranovsky in December 2016, was registered on 28 June 2005 at Sovetskaya Street 37, Novosibirsk, with share capital of RUB 100.01 million; its registered activity is investment in securities and its general director is Ivan Dzhulay. [src-125] [src-115]
- Documented: LLC Mezhregionalny Spetsializirovanny Depozitary (MSD), registered on 11 September 2003 under a Novosibirsk registration number, is registered at Shabolovka Street 31, building B, Moscow, with share capital of RUB 10,000 and a main registered activity in law, and is headed by a liquidator. An undated earlier registry snapshot showed it at Prospekt Mira 69, building 1, Moscow. [src-126] [src-153]
- Documented: LLC BCS-Commodity Markets was registered on 15 May 2012 at Sovetskaya Street 37, office 225, Novosibirsk, with share capital of RUB 50,000. Registry data show Alexander Tsukerman as its director from 15 February 2018 and then its liquidator until the company was liquidated on 28 October 2020, and BCS Holding (then Siberian Investments) as a participant in an observation window from 1 November 2018 to 27 October 2020. [src-037] [src-144] [src-052]
- Documented: Bank of Russia data show BrokerCreditService Company LLC (BCS Company) as an active financial-market participant with brokerage and dealer activity since 10 January 2001, depository activity since 23 July 2009, investment advice since 21 December 2018 and, since 6 March 2025, settlement services on an electronic platform as operator of an information system for issuing digital financial assets; its securities-management activity ended on 27 February 2020. The Bank of Russia's list of decisions concerning the company contains 63 documents, including orders of 13 and 14 October 2026 under the law against insider dealing and market manipulation to suspend orders and trades on organised markets for particular clients. [src-174] [src-147]
  - Qualification: The orders concern trading for particular clients; the published notices do not describe findings against the broker itself.
- Documented: The Ultima name is also used in Russia by BCS Company: Russian trademark records shown by a company-information aggregator list it as the holder of the trademarks 'БКС УЛЬТИМА' (Nos. 998302 and 998304) and 'BCS ULTIMA' (No. 998303), registered on 5 February 2024 and valid until 20 July 2032, and among its branches are 'Nevsky. Ultima' in St Petersburg and 'Uralsky. Ultima' in Yekaterinburg. [src-079] [src-174]

## Piligrim and the Kaliningrad international companies

- Documented: Piligrim LLC (OOO 'Piligrim') was registered in Moscow on 13 August 2024 under state registration number 1247700545916 with share capital of RUB 50,000; its main registered activity is that of a holding company, its address is Prospekt Mira 69, building 1, room 1/5, and Nina Chevardina has been its general director since 13 August 2024. [src-063] [src-064]
- Documented: According to Russian registry data shown by aggregators, Oleg Vladimirovich Mikhasenko was a participant of Piligrim from August 2024 and Natalya Olegovna Mikhasenko held 1% (RUB 500) from 24 January 2025. On 25 June 2026 both were removed from the register of participants and Alexandra Olegovna Mikhasenko became the sole participant, holding 100% (RUB 50,000). [src-068] [src-064] [src-118] [src-081] [src-080]
  - Qualification: Oleg Mikhasenko's start date comes from an aggregator's observation window. The records state no family relationship between the persons named.
- Documented: Federal Tax Service data shown by a company-information aggregator put Piligrim's assets for 2025 at RUB 568.4 million, with an average of zero employees. [src-068]
- Documented: Between February 2025 and April 2026 Piligrim became a participant of three newly registered 'international companies' (MK) in Kaliningrad: MK OOO 'Almarea Limited' on 21 February 2025, MK OOO 'BCS Global Markets Holding Ltd' on 1 November 2025 and MK OOO 'Sasare Holdings Limited' on 16 April 2026. [src-068]
- Documented: MK OOO 'Almarea Limited' (state registration number 1253900001981, registered on 21 February 2025 at Oktyabrskaya Street 71-73, Kaliningrad) has had Piligrim as its sole participant (100%, RUB 20.5 million) and Vitaly Bagamanov as general director since 21 February 2025. For 2025 it reported assets and equity of RUB 728.8 million each and no employees. [src-074]
- Documented: MK OOO 'Global Markets Holding Ltd' (state registration number 1253900011914, registered in Kaliningrad on 1 November 2025) dropped 'BCS' from its short name on 2 April 2026. Piligrim has held 27.98% (RUB 19.4 million) since 1 November 2025; on 30 June 2026 MK OOO 'Almarea Limited' joined with 72.02% (RUB 50 million) as the share capital rose from RUB 19,428,200 to RUB 69,428,200. On 29 September 2026 the company became a participant of MK OOO 'Sasare Holdings Limited'. Vitaly Bagamanov has been general director since 1 November 2025. [src-075] [src-074]
- Documented: MK OOO 'Sasare Holdings Limited' (state registration number 1263900003751) has had Piligrim as a participant since 16 April 2026 and MK OOO 'Global Markets Holding Ltd' as a participant since 29 September 2026; Vitaly Bagamanov is its general director. [src-068] [src-075]
- Documented: Three Cypriot companies with the same names, each listing Alexey Annenkov as its last director, were struck off the Cyprus register on the days the Kaliningrad companies were registered or joined by Piligrim: ALMAREA LIMITED (HE 396590, registered on 12 April 2019) on 21 February 2025; BCS GLOBAL MARKETS HOLDING LTD (HE 406068, registered on 15 January 2020 and earlier named BCS Global Markets Holding PLC) on 1 November 2025, with GLEIF recording its dissolution from that date; and SASARE HOLDINGS LIMITED (HE 425306, registered on 7 September 2021) on 16 April 2026. The first two had their registered offices at Vashiotis Kalande Offices, Mesa Geitonia, Limassol. [src-078] [src-076] [src-077] [src-091]
  - Qualification: No transfer or continuation document was retrieved. The matching names and dates are consistent with a transfer of the companies' incorporation from Cyprus to Kaliningrad, but the records reviewed do not state it. The Cyprus register gives only the director's name, without identifiers.

## Finances of the group, 2021–2025

- Documented: FG BCS LIMITED's audited consolidated statements for 2022 report total assets of RR 417,982,064 thousand at 31 December 2022 (2021: RR 461,740,727 thousand), equity of RR 74,254,809 thousand (2021: RR 60,952,282 thousand) and liabilities of RR 343,677,306 thousand. Profit for 2022 was RR 14,920,194 thousand (2021: RR 18,107,527 thousand), after net trading income of RR 39,424,766 thousand, fee and commission income of RR 11,415,050 thousand and impairment of debt financial assets of RR 11,906,501 thousand. A dividend of RR 492,825 thousand was declared and paid in 2022 (2021: RR 496,346 thousand). [src-015]
- Documented: At the end of 2022 the group employed the equivalent of about 5,422 full-time staff (2021: 5,369), and its headquarter offices were at Sovetskaya Street 37 in Novosibirsk, Russia, while the company's registered address was in Limassol, Cyprus. [src-015]
- Documented: The March 2024 prospectus gives the group's revenue for 2022 as RR 58,190,766 thousand in Russia and RR 15,100,383 thousand in other markets (2021: RR 26,753,207 thousand and RR 36,416,055 thousand). For the first half of 2023 it reports revenue of RR 3,942,768 thousand, all outside Russia, against RR 28,722,800 thousand in the first half of 2022 (RR 16,968,882 thousand in Russia and RR 11,753,918 thousand elsewhere), a fall of 86%. [src-034]
- Documented: The April 2025 prospectus, based on the audited statements, gives the group's 2023 revenue as USD 197,634 thousand, all from markets other than Russia, compared with USD 827,308 thousand in Russia and USD 214,685 thousand elsewhere in 2022; revenue from derivatives and trading was USD 127,517 thousand in 2023. At 31 December 2023 the group had liabilities of USD 1,193,962 thousand and equity of USD 496,330 thousand, against USD 4,886,116 thousand and USD 1,056,402 thousand a year earlier. [src-001] [src-045]
  - Qualification: The prospectus balance-sheet extract does not name its unit; the same totals appear in thousands of US dollars as comparatives in the 2024 audited statements.
- Documented: According to the unaudited interim figures in the March 2024 prospectus, the group's total liabilities were RR 297,319,270 thousand at 30 June 2023, against RR 157,538,932 thousand at 30 June 2022; customer brokerage accounts were RR 140,594,856 thousand and RR 68,532,812 thousand respectively. [src-034]
- Documented: The audited consolidated statements for 2024, signed by the sole director Alexey Annenkov, report total assets of USD 1,728,551 thousand at 31 December 2024 (2023: USD 1,690,292 thousand), liabilities of USD 1,061,957 thousand, equity of USD 666,594 thousand and profit for the year of USD 73,488 thousand. Net trading income was USD 121,332 thousand (2023: USD 127,517 thousand), net fee and commission income USD 5,330 thousand and impairment of debt financial assets USD 33,137 thousand. [src-045]
- Documented: The audited consolidated statements for 2025, also signed by Alexey Annenkov as sole director, report total assets of USD 2,463,540 thousand at 31 December 2025, liabilities of USD 1,626,790 thousand and equity of USD 836,750 thousand. Profit for 2025 was USD 146,092 thousand (2024: USD 73,488 thousand), with net trading income of USD 257,418 thousand, a net interest expense of USD 52,711 thousand and a net fee and commission expense of USD 2,729 thousand. [src-051]
- Documented: The group's accounting policy defines net trading income as gains less losses on trading assets and liabilities, including all fair-value changes, interest income on trading assets, realised results on investment securities and foreign-exchange differences; fee and commission income comes from executing client trades and from principal trading in securities. [src-045]
- Documented: The group's headcount fell to the equivalent of about 119 full-time employees at the end of 2023 and 78 at the end of 2024, and rose to about 110 at the end of 2025. The 2025 statements describe the group as a securities market participant in Cyprus, the UAE, Kazakhstan, the USA and Hong Kong, regulated by CySEC, the DFSA, the AIFC, FINRA and the SFC. [src-045] [src-051]
- Documented: The group declared dividends of USD 125,000 thousand (USD 2.5 thousand per share) during 2024 and none in 2023; the obligation to pay the 2024 dividend was offset against an obligation to transfer a loan payable of the same amount to the group. On 14 April 2026 the group declared dividends of USD 61,000 thousand (USD 1,220 thousand per share). [src-045] [src-051]
- Documented: All of the group's loans payable at 31 December 2024, USD 132,947 thousand, came from the shareholder; a year earlier its loans payable of USD 334,488 thousand came from finance and investment companies. At 31 December 2025 loans payable were USD 243,583 thousand, of which USD 156,205 thousand (64%) from the shareholder and USD 87,378 thousand (36%) from finance and investment companies; notes issued at fair value were USD 52,773 thousand (2024: USD 84,410 thousand). [src-045] [src-051]
- Documented: At 31 December 2022 the group's balances with companies under the common control or significant influence of its sole participant included loans to customers of RR 3,355,792 thousand (gross) and current accounts, deposits and borrowings owed to them of RR 37,911,202 thousand. [src-015]
  - Qualification: The statements do not name these companies.
- Documented: The 2024 statements record several transactions with companies under the common control of the ultimate shareholder at prices the group treated as non-market: fair-value adjustments of USD 116,105 thousand on purchases and sales of securities and USD 15,668 thousand on a sale of investment securities above fair value, both booked as capital contributions from the shareholder; a USD 115,474 thousand contribution on the purchase of subsidiaries below fair value; and a USD 690 thousand distribution on the sale of subsidiaries below fair value. For 2023 the statements record a USD 3,193 thousand distribution on hybrid derivatives sold to a related party and a USD 618,682 thousand distribution, being the difference between the net assets of BCS Holding LLC and the consideration received when it was sold to the ultimate shareholder. The net contribution from the shareholder for 2024 was USD 248,795 thousand. [src-045]
  - Qualification: The counterparties are not named.
- Documented: In 2025 the group booked fair-value adjustments of USD 13,477 thousand on securities and derivatives transactions with companies under common control at non-market prices as capital contributions from the shareholder, and sold rights of claim of USD 65,344 thousand to a company under the common control of the ultimate shareholder for USD 13,050 thousand. The net contribution from the shareholder for 2025 was USD 24,639 thousand. [src-051]
  - Qualification: The counterparties are not named.
- Documented: Balances with related parties at 31 December 2025 were denominated in US dollars, euros and UAE dirhams at 4.06% to 6.5% a year, against US dollars, euros and roubles at 4.4% to 22% a year at the end of 2024. The group's rouble-denominated financial assets rose from the equivalent of USD 143,852 thousand at the end of 2024 to USD 643,826 thousand at the end of 2025, and its rouble financial liabilities from USD 160,869 thousand to USD 598,694 thousand. [src-051]
- Documented: Receivables blocked at Euroclear were the group's largest single counterparty exposure for several years: RR 12,729,915 thousand at the end of 2022 (2021: RR 11,136,048 thousand), USD 128,081 thousand at the end of 2023 and USD 108,627 thousand at the end of 2024. At the end of 2025 the group reported no counterparty with a balance above 10% of equity. [src-015] [src-045] [src-051]
  - Qualification: The 2025 statements do not say whether the Euroclear balance was released, written off or simply fell below the 10% threshold.
- Documented: As a result of US and EU sanctions on Russia, receivables of USD 162,839 thousand at the end of 2024 (2023: USD 160,905 thousand) were restricted in depositories, against which the group held a provision of USD 151,365 thousand (2023: USD 113,744 thousand). At the end of 2022 bank and broker deposits of RR 3,652,635 thousand were frozen because of sanctions, and RR 183,723 thousand of cash was blocked by an injunction securing a client's claim. [src-045] [src-015]
- Documented: Customer brokerage accounts, mostly settlements under structured derivative products, were USD 618,315 thousand at the end of 2024 and USD 799,314 thousand at the end of 2025; one client accounted for USD 251,029 thousand of the 2024 total and USD 149,194 thousand of the 2025 total. [src-045] [src-051]
- Documented: At 31 December 2023 the group had issued financial guarantees of USD 40,057 thousand, all in the B+ to B- credit range, with a loss allowance of USD 2,865 thousand. [src-045]
- Documented: The 2024 cash-flow statement shows net cash used in operating activities of 351,574, inflows of 113,370 from investing and 117,214 from financing activities, including 118,345 of contributions from the shareholder, and a fall in cash and equivalents of 120,990 to 146,908. The statement's heading gives the unit as thousands of Russian roubles, although the totals match the US-dollar balance sheet. [src-045]
  - Qualification: The unit label in the audited cash-flow statement is inconsistent with the rest of the statements, which are in thousands of US dollars.
- Documented: KPMG Limited in Limassol audited the consolidated statements for 2021 and 2022 without qualification; its 2022 report included an emphasis of matter on the effect of the military operations in Ukraine and the resulting sanctions on the group's operations. JSC Kept in Moscow audited the statements for 2023, 2024 and 2025 without qualification, signing its reports on the 2024 and 2025 statements on 30 May 2025 and 29 May 2026. [src-001] [src-015] [src-034] [src-045] [src-051] [src-008]
  - Qualification: A list of reports on the website of The Ultima Structured Products PLC names the files of the 2023 and 2024 consolidated statements with the word 'BinGhannam'; the contents of those files were not retained.
- Documented: The 2018 financial statements of Brokercreditservice Structured Products Plc show loans to related parties of RUB 9,420,399,981 at the end of 2018 (2017: RUB 7,399,551,249) at interest rates of 1% to 11%: RUB 3,178,415,100 to BCS Prime Brokerage, RUB 2,039,723,679 to Oleg Mikhasenko personally (2017: RUB 753,945,496), RUB 1,865,682,567 to Kertina Group, RUB 1,365,711,127 to BCS-Forex and RUB 970,867,508 to FG BCS Ltd. The same statements show dividends of RUB 6.5 billion payable to FG BCS Ltd and a brokerage-account balance of about RUB 21.8 billion owed to BrokerCreditService (Cyprus). [src-067]

## The Ultima World (DIFC) Limited: the Dubai wealth manager

- Documented: The guarantor's statements report the capital of The Ultima World (DIFC) Limited as share capital of USD 1,200 thousand and retained earnings of USD 14,637 thousand at the end of 2024 (USD 15,837 thousand in total), and share capital of USD 4,200 thousand and retained earnings of USD 14,623 thousand at the end of 2025, with Tier 1 capital of USD 13,170 thousand (2024: USD 9,174 thousand). [src-045] [src-051]
- Documented: The DFSA public register lists The Ultima World (DIFC) Limited, a DIFC company with DFSA reference number F004980 and the trading name 'The Ultima World Wealth Management Platform', at Unit 1002, Level 10, Index Tower, DIFC, Dubai, with a licence dated 21 January 2020. Its endorsements allow it to serve retail clients and to hold or control client assets, and its licensed services are advising on financial products, arranging custody, arranging deals in investments, dealing in investments as agent, managing assets and providing custody, for instruments including shares, structured products, derivatives, debentures and fund units. [src-101]
- Documented: A column by its senior executive officer Andrey Chuprin in a regional finance publication states that The Ultima World (DIFC) Limited, also trading as 'The Ultima World. Wealth Management Platform', is authorised and regulated by the DFSA under DIFC licence number CL3568 and DFSA reference number F004980. [src-171]
- Documented: The DFSA register lists as current authorised individuals of the firm Edward Golosov (licensed director since 21 January 2020), Alina Perepelkina (finance officer and senior manager since 21 January 2020), Rafik Faik Ogly Abasov (licensed director since 21 January 2020), Anton Gordin (authorised since 21 January 2020, with a further function from 7 May to 29 July 2024) and Andrey Chuprin (licensed director and senior executive officer since 10 July 2024). [src-102] [src-101] [src-120] [src-121] [src-122]
- Documented: Former authorised individuals of the firm, according to the DFSA register, are Denis Zabolotnev (licensed director and senior executive officer, 10 November 2023 to 26 April 2024), Stephen Lee Coles (compliance officer, money laundering reporting officer and senior manager, 21 January 2020 to 6 October 2020), Evgenii Tolpykin (senior manager, compliance officer and money laundering reporting officer, 21 October 2020 to 11 October 2024), Simon Victor James Gilder (the same functions, 5 November 2024 to 31 July 2026), Sergey Kaminskiy (senior manager, 21 January 2020 to 31 May 2024) and Alexander Zakharkin (senior manager, 4 June 2024 to 6 August 2026). [src-101] [src-138] [src-139] [src-140] [src-141] [src-142] [src-143]
- Documented: The firm's website theultima.com lists its team as Edward Golosov, PhD (executive chairman of the board of directors), Andrey Chuprin (senior executive officer), Vyacheslav Ermilov (chief operating officer) and Iveta Wilkinson (human resources director). [src-086]
  - Qualification: Company self-description on its website.
- Documented: The website presents The Ultima World as a DIFC-headquartered, DFSA-regulated wealth manager for affluent clients, giving its DFSA licence year and figures of USD 1.7 billion in total assets under custody and more than 3,000 clients worldwide, with offices, staff and partners in America, Europe, Asia and Africa and service 'with cultural sensitivity and complete discretion'. [src-163] [src-051]
  - Qualification: Marketing figures from the company's own website, not audited; the group's audited statements report customer brokerage accounts of USD 799,314 thousand at the end of 2025, which is a different measure from assets under custody.
- Documented: The website's cookie notice says visitor data are shared with the analytics services Google Analytics and Yandex Metrika, and links to a cookie policy file named 'BCS_Capital_DIFC_Cookies_processing_policy.pdf', after the firm's former name. [src-163]
- Documented: A Russian business magazine reported on 7 September 2023 that it had found signs that three Russian financial companies, 'BCS Ultima', Alfa and Aton, were trying to provide services in Dubai without publicising it, citing for 'BCS Ultima' a website with a Dubai contact number. [src-049]
  - Qualification: The article does not name a legal entity behind 'BCS Ultima'; at the time the group's DIFC firm operated as BCS Capital (DIFC) Limited.
  - Response: According to the article, all three companies preferred not to discuss their activity in the region.
- Documented: A tax adviser's post on a Russian business blogging platform said that Russian clients of 'The Ultima World', which it described as the commercial name of BCS Capital (DIFC) Limited, part of the BCS group, were receiving requests from the Russian tax service for their contracts with BCS Capital (DIFC) Limited, statements and information on their 2023 tax residence and foreign income, prompted by the automatic exchange of tax information. [src-105]
  - Qualification: The post describes requests to clients, not any action against the firm.
- Documented: Professional-networking profiles of Edward Golosov, PhD, based in London, and of Andrey Chuprin, based in Dubai, name The Ultima World and The Ultima World (DIFC) respectively as their current employers. [src-134] [src-176]
  - Qualification: Self-descriptions on public profiles.

## Note programmes guaranteed by THE ULTIMA WORLD DMCC

- Documented: Under a base prospectus dated 29 March 2024, BCS Global Markets Qazaqstan Limited, a private company of the Astana International Financial Centre (AIFC), set up a USD 150,000,000 medium-term note programme valid until 31 January 2054, with payments under the notes to be unconditionally and irrevocably guaranteed, if the final terms so specify, by FG BCS LTD DMCC under a deed of guarantee of the same date. BrokerCreditService (Cyprus) Limited was named as dealer. [src-033] [src-034]
- Documented: A base prospectus dated 17 April 2025 replaced it with a USD 300,000,000 medium-term note programme, also valid until 31 January 2054, under which The Ultima Global Markets Qazaqstan Limited may issue notes to accredited investors, guaranteed unconditionally and irrevocably by THE ULTIMA WORLD DMCC under a deed of guarantee dated 17 April 2025 when the final terms so specify. The Ultima Investments Cyprus Limited acts as calculation agent under an agreement of the same date between the issuer, the guarantor and itself. [src-001]
- Documented: Both programmes limit the guarantee in a sanctions scenario: the guarantor has no liability for as long as the issuer's failure to pay is related, directly or indirectly, to the issuer, the guarantor or the ultimate beneficial owner of either becoming subject to sanctions. [src-034] [src-001]
- Documented: The 2025 deed of guarantee is governed by the Acting Law of the AIFC, applies the AIFC Contract Regulations, and submits any dispute arising from it to the AIFC Court for final resolution. [src-001]
- Documented: In 2024 the Kazakh issuer issued Series 2024-01 USD 10,000,000 share-linked notes due May 2029, Series 2024-02 RUB 2,500,000,000 interest-rate-linked notes due September 2029, Series 2024-03 CNY 80,000,000 and CNY 120,000,000 fixed-rate notes due October 2025, redeemed in December 2024, and Series 2024-04 EUR 10,000,000 fixed-rate notes due November 2025, redeemed in March 2025. Its 2024 statements carried the notes outstanding at year-end off the balance sheet at their issue amounts. [src-001] [src-033]
- Documented: After 31 December 2024 the issuer registered further series on AIX in pounds sterling (2025-01), US dollars (2025-02) and Chinese yuan (2025-03). In August 2026 it published final terms for USD 5,000,000 of equity-linked notes due April 2028 under the USD 300,000,000 programme, guaranteed by THE ULTIMA WORLD DMCC; the notes are not intended for retail investors in the EEA, the UK, the AIFC or Kazakhstan and no secondary market is planned. [src-033] [src-148]
  - Qualification: The August 2026 issue is known from a press summary of the AIX disclosure.
- Documented: AIX's list of delisted securities shows the issuer's structured products BCSGM03 (27 December 2024) and BCSGM04 (27 March 2025), ULTIMAGM11 (8 January 2026), ULTIMAGM09 (29 January 2026), ULTIMAGM07 (26 March 2026), ULTIMAGM27 and ULTIMAGM28 (19 June 2026) and ULTIMAGM24 (6 August 2026) delisted after early redemption of all remaining notes, and ULTIMAGM08 delisted on maturity on 20 June 2026. [src-061]
- Documented: In a notice to noteholders published on 20 May 2025, The Ultima Structured Products PLC reported that it had changed its name from Brokercreditservice Structured Products PLC with effect from 13 May 2025, confirmed by a Cyprus Registrar of Companies certificate, that its guarantor FG BCS LTD DMCC had become THE ULTIMA WORLD DMCC and that its calculation agent BrokerCreditService (Cyprus) Limited had become The Ultima Investments Cyprus Limited. The notice is signed by Alona Joannu as director. [src-039]
- Documented: On 30 August 2024 Brokercreditservice Structured Products Plc amended the final terms of its Series 2017-16 RUB 600,000,000 index-linked notes due November 2027 (ISIN XS1713519012), issued under a EUR 20,000,000,000 programme, by a deed with the sole noteholder representing 100% of the outstanding principal: the calculation amount was set at RUB 0 and the underlying index was replaced by the CBONDS Select Value Mini and Perpetual Bond Index. [src-040]
- Documented: The April 2025 prospectus states that for at least five years none of the directors of the Kazakh issuer or of the guarantor had been convicted of fraud or other financial crimes or been subject to official public incrimination or sanctions by statutory or regulatory authorities, and that the directors have no family relationships with each other. It names as connected persons of the issuer under the applicable market abuse rules the subject, The Ultima Investments Cyprus, Brokercreditservice Structured Products, The Ultima World (DIFC) and BCS Americas as group members, the issuer's four directors, Alexey Annenkov as the guarantor's sole director and Oleg Mikhasenko as the controller of the group. [src-001]
  - Qualification: Statements by the issuer and the guarantor in their own prospectus. The regulatory actions described elsewhere in this dossier concern group companies, not their directors.
- Documented: The April 2025 prospectus names The Ultima Investments Cyprus Limited, previously BrokerCreditService (Cyprus) Limited, as calculation agent for the Kazakh issuer's notes programme. [src-001]

## The Kazakh companies: note issuer and fintech company

- Documented: The AFSA public register lists The Ultima Global Markets Qazaqstan Limited (business identification number 221040900440) as an active AIFC private company registered on 18 October 2022 at 16 Dostyk Street, office 2, Astana, with THE ULTIMA WORLD DMCC as its shareholder and 800,000 ordinary shares of USD 1. It was named BCS Global Markets Qazaqstan Limited until 9 December 2024. Its registered business is the issue of structured products and pre-IPO notes to be listed on AIX, securities trading for hedging, and derivative transactions. [src-010]
- Documented: According to the AFSA register, Konstantin Pavlov has been a director and authorised signatory since 18 October 2022 and was chief executive until 10 September 2025; Denis Kozub has been a director since 29 March 2023; Dmitry Trenin was a director from 29 March 2023 to 10 September 2025; Dmitry Zakharov was a director from 29 March 2023 to 10 September 2025 and again from 30 January 2026; Azamat Shintayev has been director, chief executive and authorised signatory since 10 September 2025; and Kirill Greshnikov was an authorised signatory from 18 October 2022 to 26 September 2025. The 2025 prospectus names Kozub as chairman of the board. [src-010] [src-001]
- Documented: The April 2025 prospectus states that each of the issuer's four directors also held a post at the Russian broker BrokerCreditService Ltd: Konstantin Pavlov as head of the derivatives and structured products department of its investment banking division from April 2021, Denis Kozub as head of investment banking from August 2022, Dmitry Trenin as head of securities trading from January 2023, and Dmitry Zakharov as chief operating officer of the investment banking division from February 2023. [src-001]
  - Qualification: The prospectus gives these posts as of its date (17 April 2025) and says the directors perform no other principal activities outside the issuer.
- Documented: The March 2024 prospectus states that Konstantin Pavlov was appointed a director of the issuer on 18 October 2022 for two years and a member of its board on 29 March 2023 for three years, and that Kozub, Trenin and Zakharov were appointed to the board on 29 March 2023 for three years. [src-034]
- Documented: The issuer's auditor is Crowe Audit Astana LLP, licensed by the AFSA, which issued the independent auditor's report on its 2024 financial statements. [src-001] [src-033]
- Documented: The issuer's audited statements show net income of KZT 389,087 thousand for 2024 (2023: KZT 146,102 thousand) and KZT 2,368,113 thousand for 2025, with total assets of KZT 9,788,240 thousand at the end of 2024 and KZT 9,614,016 thousand at the end of 2025. [src-033] [src-036]
- Documented: THE ULTIMA WORLD DMCC lent money to the issuer: the issuer owed its sole shareholder KZT 2,447,365 thousand at the end of 2023; the principal was repaid on 19 April 2024 and the accrued interest of KZT 102,427 thousand was paid in full in February 2025. The issuer's financial expenses to its sole shareholder were KZT 100,702 thousand in 2024 and KZT 18,565 thousand in 2023. [src-033]
- Documented: At 31 December 2023 the issuer's statements showed a loan given of KZT 15,606,333 thousand; they state that 'the loan from SPRKGROUP TRADING LIMITED was fully repaid' by 15 March 2024, with nothing outstanding. [src-033]
  - Qualification: The statements do not describe the borrower or the purpose of the loan.
- Documented: The issuer's website describes its products as structured notes: credit-linked notes on one or several names, equity-linked notes (most often of the Phoenix type), hybrid credit and equity products, tracker notes and pre-IPO notes giving exposure to late-stage venture companies. [src-038]
- Documented: The Ultima Fintech Qazaqstan, which FINRA lists among companies owned by THE ULTIMA WORLD DMCC, appears in Kazakh business directories as TOO 'Ultima Fintech Kazakhstan' (business identification number 230240029933), registered on 17 February 2023, formerly TOO 'BCS Fintech Kazakhstan', a software developer at Shamshi Kaldayakov Street 4/1, Astana. The directories name Rosana Kirpichnikova as director since 31 May 2026 and also list Alexey Vladimirovich Annenkov and Dmitry Valerievich Ivanov, the latter from 16 February 2023, among its managers; Kazakh statistics data class it as a company under foreign control. [src-044] [src-088] [src-006] [src-027]
  - Qualification: The directories hide the founders; the FINRA address for the company (16 Dostyk Avenue) differs from the directory address. A search of the AIFC public register for 'Ultima' returns only the group's Kazakh issuer and an unrelated company, so the company is not an AIFC entity.
- Documented: Kazakh revenue data shown by a directory record the company's tax payments as KZT 1,231,104 for 2023, KZT 13,755,613 for 2024 and KZT 16,215,162 for 2025. [src-088]

## The Ultima name: websites, domains and impersonation

- Documented: In a notice to private investors dated 5 August 2026, copied to the Astana International Exchange, the issuer said it had learned that unknown individuals acting in its name had offered or concluded agreements with private investors for financial services or the purchase of financial instruments. It stated that it does not carry on dealer or brokerage activity in Kazakhstan or the AIFC, has no employees or agents promoting financial instruments, and issues structured notes only for qualified investors. [src-035]
- Documented: The AFSA issued a public alert about fraudulent use of the name of The Ultima Global Markets Qazaqstan Limited: third parties had claimed to represent the company, offered investment products and distributed agreements and account-opening documents in its name, used the names of people who are not its employees or representatives, and solicited or received money from the public. [src-131]
  - Qualification: The company is the party whose name was misused; the alert contains no finding against it. The retained copy of the alert does not show its date.
- Documented: On 13 May 2026 the DFSA warned that The Ultima World (DIFC) Limited, a legitimate DFSA-authorised firm, had been impersonated: scammers had set up a website for an entity called 'Ultimatum World' that used a similar name, falsely claimed DFSA regulation and copied the firm's regulatory status, licence and address. The DFSA confirmed that 'Ultimatum World (DIFC) Limited' is not an authorised firm and that the website is not associated with or authorised by The Ultima World (DIFC) Limited. [src-016]
  - Qualification: The firm is the party being impersonated; the alert makes no finding against it.
- Documented: On 13 November 2024 the firm, then BrokerCreditService (Cyprus) Limited, warned that a third party was promoting its services from the domain bcssp.com with misleading claims of a connection to the firm, citing its registration number 154856, its logo and its CySEC authorisation; the firm said it had never authorised that party to act for it. [src-011]
- Documented: A June 2025 report of a Financial Sector Conduct Authority warning said that two individuals had impersonated Brokstock SA (Pty) Ltd through Telegram and WhatsApp groups called 'Brokstock Beginner/s' and collected deposits into a bank account in another name; the FSCA quoted Brokstock as confirming that the individuals were not associated with it. [src-164]
  - Qualification: Brokstock is the party being impersonated; the report describes no action against the company.
- Documented: The brand website theultima.com runs on a domain first registered on 4 May 2000. An archived copy of 25 January 2022 shows the domain then carrying the site of Ultima Krav Maga, an unrelated self-defence studio in Tucson, Arizona; archive captures from the end of 2023 alternate between redirects and working pages. The domain theultimagm.com, on which the Kazakh issuer publishes its documents, was registered on 17 December 2024. [src-156] [src-158] [src-157] [src-161] [src-038]
  - Qualification: The registration records do not show the registrant of either domain.
- Documented: An archived copy of 23 January 2026 of the Kazakh issuer's page on theultimagm.com lists contacts headed by a 'Moscow Headquarters' at Prospekt Mira 69, building 1, Moscow, followed by London and New York headquarters. On the same copy the links to the guarantor's audited annual statements for 2021, 2022 and 2024 and to its interim statements at 30 June 2022 and 30 June 2023 lead to a 'not found' page, while the issuer's own 2023 statements remain linked. [src-038]
- Documented: The impersonation website named in the DFSA's alert of 13 May 2026, theultimatum.pro, had been registered on 1 April 2026 through OwnRegistrar, Inc. with the owner's details withheld, according to a website-reputation service. The clone domain bcssp.com, about which the Cypriot subsidiary warned in November 2024, no longer resolves in public DNS. [src-159] [src-162] [src-016] [src-011]
- Documented: The group's website theultimagm.com still hosts the customer privacy notice of BCS Prime Brokerage Limited, the UK broker sold in 2024, in a version last updated on 30 May 2019 that refers to the website bcsgm.com and an office at 99 Bishopsgate, London. [src-152] [src-045]

## The Ultima Global Markets (USA) Inc. and the FINRA case

- Documented: The group describes The Ultima Global Markets (USA) Inc., named BCS Americas, Inc. until 21 March 2025, as a New York broker-dealer registered with the SEC and FINRA that gives US institutional investors access to the Russian and European markets and that became a direct member of the New York Stock Exchange in 2018. The March 2024 prospectus described BCS Americas as an introducing broker for US institutional clients investing in Russia and the Commonwealth of Independent States. [src-051] [src-034]
- Documented: A US trade publication reported in March 2019 that BCS Global Markets had launched BCS Americas in 2016 to give US investors access to the Russian markets, quoting Gary Esayian as its chief executive, and that BCS had invested in Tigress Financial Partners LLC, a New York broker-dealer. [src-137]
- Documented: FINRA's BrokerCheck report lists Michael Patrick Healy as the firm's chief executive officer since October 2021 and chief compliance officer since May 2025, Michael James Schilling as its financial and operations principal (FINOP) since December 2015, and Dimitry Zakharov as a director since March 2026. [src-006] [src-029]
  - Qualification: Schilling's individual BrokerCheck report gives 25 May 2022 as the date of his registration with the firm.
- Documented: Michael P. Healy's individual BrokerCheck report shows him registered with The Ultima Global Markets (USA) since 7 April 2020 with no disclosure events, and lists among his other business activities a directorship of The Ultima Investment Hong Kong Limited, a Hong Kong broker-dealer, starting on 28 April 2026. [src-028]
- Documented: Michael J. Schilling's individual BrokerCheck report shows no disclosure events and his concurrent registration with three other broker-dealers, nabSecurities, Netrex Capital Markets and Kopentech Capital Markets, in addition to The Ultima Global Markets (USA). [src-029]
- Documented: Michael Schilling's registration filing states that since November 2019 he has been a managing director of JRS Financial Services LLC of Roslyn, New York, a firm that provides outsourced financial and operations principal (FINOP) services to broker-dealers, and that he devotes about 95% of his professional time to it. [src-029]

## The Cypriot subsidiaries: investment firm and structured-products company

- Documented: The Cyprus register's open data list The Ultima Investments Cyprus Limited (HE 154856, a private company registered on 7 December 2004) at Spyrou Kyprianou & 1 Oktovriou 1, Vashiotis Kalande Offices, Mesa Geitonia, Limassol, with directors Eirini Theodoulou, Tonia Antoniou, Denis Kozub, Igor Zatseda and Vera Kuzniatsova and with A.M.K. Trustee Services Limited as secretary. [src-025] [src-030] [src-047] [src-048]
  - Qualification: The register's open data show officers currently on file, without appointment dates.
- Documented: The firm's own website names Vera Kuzniatsova as managing director, Igor Zatseda as executive director responsible for regulatory compliance and anti-money-laundering matters, and Tonia Antoniou and Iryna Theodoulou as non-executive directors. [src-046]
  - Qualification: Company self-description.
- Documented: The firm's Limassol office is at Spyrou Kyprianou & 1 Oktovriou 1, Vashiotis Kalande offices, 1st floor, Mesa Geitonia, the same address that GLEIF records for Seldthorn Private Equity Limited, the company the group sold to its ultimate shareholder in 2022. [src-173] [src-043] [src-015]
- Documented: BrokerCreditService (Cyprus) Limited took the name The Ultima Investments Cyprus Limited from 11 February 2025 and moved its website to theultimacy.com and its e-mail domain to theultimagm.com from 14 April 2025. [src-011]
- Documented: The Belgian regulator FSMA lists the firm, as BrokerCreditService (Cyprus) Ltd from 22 April 2013 and as The Ultima Investments Cyprus Ltd from 17 February 2025, among EEA investment firms that have notified the free provision of investment services in Belgium, covering reception and transmission and execution of orders, dealing on own account, portfolio management, placing, safekeeping and related services. [src-175]
- Documented: The firm's website lists as group affiliates The Ultima World (DIFC) Limited, The Ultima Structured Products PLC, The Ultima Global Markets (USA) Inc., The Ultima Global Markets Qazaqstan Limited and Brokstock SA (Pty) Ltd, an FSCA-authorised financial services provider in South Africa. [src-173]
  - Qualification: Company self-description.
- Documented: On 28 March 2022 the board of the Cyprus Securities and Exchange Commission (CySEC) fined BrokerCreditService (Cyprus) Limited EUR 10,000 for non-compliance with Article 16(2) of the EU Market Abuse Regulation: the firm had not established and maintained effective arrangements and systems for detecting suspicious transactions, because it did not take due account of price changes in the instruments it traded that could give rise to reasonable suspicion of insider dealing. The decision was announced on 19 April 2022. [src-103]
  - Response: The announcement records a judicial review and a judicial-review ruling, both available only as links whose content was not retained; the outcome of the review is therefore not known from the record.
- Documented: On 24 April 2023 CySEC reached a EUR 100,000 settlement with BrokerCreditService (Cyprus) Limited over possible violations, in 2019–2021, of Article 16(2) of the Market Abuse Regulation on preventing and detecting market abuse and of the organisational requirements for investment firms under Cypriot investment services law. The settlement was announced on 12 July 2023. [src-104]
  - Outcome: The firm had already paid the EUR 100,000; CySEC's announcement records no judicial review.
- Documented: On 27 October 2021 S&P Global Ratings raised its long-term issuer credit rating on FG BCS to 'B+' from 'B' and on its subsidiaries BrokerCreditService (Cyprus) Ltd., the structured products company and BCS Prime Brokerage Ltd. to 'BB-' from 'B+'. [src-011]
  - Qualification: As reproduced on the Cypriot subsidiary's news page.
- Documented: The Ultima Structured Products PLC (HE 158664, a public company registered on 18 March 2005, formerly Brokercreditservice Structured Products Plc) has its registered office at Agias Fylaxeos 182, Kofteros Business Center, Limassol; the Cyprus register's open data list Dimitra Karkalli, Alona Joannu and Franz Hep as its directors and M. Kyprianou Fiduciaries (Cyprus) Ltd as secretary. [src-024]
  - Qualification: The register's open data show officers currently on file, without appointment dates.
- Documented: The officers of the two Cypriot subsidiaries include companies and people tied to the Cypriot law firm Michael Kyprianou & Co. LLC. A legal-directory profile supplied by the firm describes Tonia Antoniou, a non-executive director of The Ultima Investments Cyprus, as a partner heading its banking and finance and corporate departments in Limassol. The Cyprus register's open data list her among the directors of the law firm and of M. Kyprianou Fiduciaries (Cyprus) Ltd, the company secretary of The Ultima Structured Products PLC, and show A.M.K. Trustee Services Limited, the company secretary of The Ultima Investments Cyprus, registered at M. Kyprianou House in Limassol. [src-172] [src-145] [src-084] [src-154] [src-024] [src-025]

## Companies linked to the group outside its audited subsidiaries

- Documented: GLEIF records three Hong Kong companies linked to the group: The Ultima Investment Hong Kong Limited (company number 75381887, created on 5 June 2023, formerly BCS Investment Hong Kong Limited, renamed with effect from 28 November 2024); The Ultima Products HK Limited (75650820, created on 25 August 2023, formerly BCS Products HK Limited, renamed with effect from 28 November 2024); and The Ultima Asia Limited (77294155, created on 7 November 2024). None of the three records names a parent company. [src-043] [src-041] [src-026]
- Documented: The Ultima Products HK Limited's website says the company, registered under number 75650820 in Hong Kong, specialises in manufacturing structured products and acts as their issuer. [src-066]
- Documented: Spidertek Ltd (Cyprus HE 378454) was created on 29 December 2017 as Rivercross Ventures Limited and renamed with effect from 4 May 2023, according to GLEIF, which names no parent company. The Cyprus register's open data list Natalya Annenkova as its sole director and Melcon Secretarial Services Ltd as secretary, at Omirou 7, Agios Nikolaos, Limassol. [src-041] [src-042] [src-053]
  - Qualification: The register gives no identifiers for officers; the records state no relationship between Natalya Annenkova and Alexey Annenkov.
- Documented: LTM SV LLC, registered in St Vincent and the Grenadines (1245 LLC 2021) at the Griffith Corporate Centre, Kingstown, was created on 14 July 2014; GLEIF lists its previous names as BCS Markets Ltd, BCS Markets LLC (after a change of name and legal form effective 9 July 2021) and The Ultima Markets SV LLC, with the current name effective from 4 April 2025, and names no parent company. [src-041]
- Documented: A trade publication covering the retail trading industry reported in January 2025 that the offshore forex broker BCS Markets (earlier BCS Forex), registered in St Vincent and the Grenadines and described as part of the Russian BrokerCreditService group and a sister brand of the Russian forex dealer BCS-Forex, had quietly renamed itself Ultima Markets, operated by Ultima Markets SV LLC at the same address. In December 2024 it reported that BCS Markets had told clients that deposits to and withdrawals from its account at BCS Bank would stop on 12 December 2024 and that from 13 December payments would go through Ardshinbank and bank cards; BCS Bank had been added to the US sanctions list on 21 November 2024. [src-092] [src-107]
  - Qualification: The description of the renaming as an attempt to escape a 'toxic' association is the publication's own interpretation.
- Documented: Brokstock SA (Pty) Ltd, a South African company (2020/523823/07) created on 2 July 2020 and named BCS Markets SA (Pty) Ltd until a change effective 2 December 2024, describes itself as a financial services provider authorised by the Financial Sector Conduct Authority (FSP No. 51404) that acts only as an intermediary in contracts for difference offered by liquidity providers and does not make markets. Its app and website offer retail clients CFDs on shares, currencies, metals, ETFs, commodities and crypto-assets, and the app description advertises 8% to 11% annual interest on available balances. [src-062] [src-129] [src-160]
- Documented: On a consumer review platform Brokstock had 110 reviews with an average rating of 4.4 out of 5 in October 2026; one review of 12 October 2026 called the company scammers after a month-long compliance block on the reviewer's account. [src-132]
  - Qualification: Unverified consumer reviews; the platform does not verify them.
  - Response: The company replied that the use of a third party's account had complicated the reviewer's profile and that its compliance team was still investigating.
- Documented: Heelveil Ltd. is a Seychelles international business company (registration 024801, created on 7 December 2005) registered care of a corporate services firm in Victoria; its LEI lapsed with a renewal date of 25 October 2025 and its record names no parent. LEI publications reproduced by a company-information aggregator show Heelveil as the former ultimate parent of LLC BCS-Commodity Markets (until 4 September 2019) and of LLC Mezhregionalny Spetsializirovanny Depozitary (until 31 July 2019), and the former direct and ultimate parent of JSC Management Company of Funds (until 4 August 2022). [src-059] [src-093]
- Documented: A bond-data provider names Antonis Stefani as the beneficiary of Heelveil Ltd. A list of affiliated persons of the Russian management company UK URALSIB as at 4 March 2020 includes Antonis Stefani of Strovolos, Cyprus, among the persons belonging to the same group of persons as that company from 19 December 2019. [src-060] [src-128]
  - Qualification: The provider is a secondary data source; the beneficial owner of Heelveil was not found in any registry record.
- Documented: The list of affiliated persons of JSC Management Company URALSIB (later BCS Wealth Management) as at 4 March 2020, signed by its general director, records Siberian Investments LLC as its sole shareholder from 19 December 2019 and lists as belonging to the same group of persons, mostly from that date, FG BCS LTD, BrokerCreditService (Cyprus) Limited, Brokercreditservice Structured Products PLC, BCS Prime Brokerage Limited, BCS Americas, Inc., BCS Capital (DIFC) Limited, BCS Markets Ltd and FG Aviation Ltd. (both at Suite 305, Griffith Business Center, Kingstown), BCS Investment Management Ltd. (Cayman Islands), Kertina Group Ltd, Seldthorn Private Equity Limited, Routa Luxury Services Ltd, Danofe Trading Limited, BCS Global Markets Holding PLC (from 15 January 2020), Spidertek Ltd (from 21 January 2020), JSC BCS Bank and BrokerCreditService Company LLC, together with individuals including Oleg Mikhasenko, Vitaly Shelikhovsky, Alexey Vladimirovich Annenkov of Limassol, Edward Golosov, Anton Gordin, Rafik Abasov and Gary Martin Esayian. [src-128]
  - Qualification: A 'group of persons' under Russian competition law can rest on ownership, control or management ties; the list does not state the basis of each entry.
- Documented: The DMCC Authority's list of transfers of incorporation records FG AVIATION LLC DMCC (registration number DMCC199243), formerly FG AVIATION LLC of St Vincent and the Grenadines, registered and transferred on 29 March 2024 with a service licence issued on 17 July 2024. [src-007] [src-149]
  - Qualification: The records reviewed do not establish whether this company is the FG Aviation Ltd. listed in the BCS group of persons or the LLC FG Aviation that the group disposed of; GLEIF holds no LEI for either name in this form.

## Tax dispute, the Tyazhstankogidropress claim and a Cyprus client suit

- Documented: After a field tax audit of 2017–2019, Interdistrict Inspectorate No. 22 of the Federal Tax Service for the Novosibirsk Region, by decision No. 2805 of 11 August 2022 (as amended on 16 January 2023), charged FG BCS LTD, which was then a Russian tax resident, additional profit tax of RUB 249,825,054 on profits of controlled foreign companies, penalty interest of RUB 112,355,981.40 and a fine of RUB 12,491,253. The regional tax directorate dismissed the company's appeal on 18 January 2023. On 31 August 2023 the Federal Tax Service cancelled the decision insofar as it charged penalty interest and held the company liable for the offence, with reference to Article 75(8) and Article 111(1)(3) of the Tax Code. [src-096] [src-146] [src-116]
  - Qualification: The courts' rulings describe the company as a Russian tax resident from 2016 to 2022.
- Documented: The disputed assessment concerned dividends from the company's wholly owned Cypriot subsidiary BrokerCreditService (Cyprus) Limited, which the Russian tax authorities treated as a controlled foreign company. On 23 December 2019 FG BCS LTD, as sole participant, decided that the USD 20 million annual dividend for 2016, paid in 2017, was to be treated as an interim dividend for 2017, and that the USD 30 million dividend for 2017, paid in 2018, came from retained earnings of previous years. In amended profit-tax returns this reduced the subsidiary's 2018 taxable profit from USD 27,052,129 to USD 7,051,726; the tax authority found that tax had been understated by RUB 233,411,600. The first-instance decision states that the interdependence of the two companies influenced economic decisions with a predominantly tax motive. [src-146] [src-116] [src-096]
- Documented: FG BCS LTD asked the Arbitration Court of the Novosibirsk Region to invalidate the decision insofar as it demanded 2018 profit-tax arrears of RUB 233,411,600 and RUB 66,164,451 with the related penalty interest and fines (case A45-10537/2023). [src-096] [src-146] [src-116] [src-095]
  - Qualification: The retained record does not show whether the company appealed further to the Supreme Court.
  - Response: The company argued that it had revised the type, period and source of the dividends in 2019 to correct errors in the valuation of derivatives, and that the subsidiary had insufficient profit to distribute for 2016. The courts found these arguments unsupported; the first-instance decision notes retained earnings of the subsidiary of USD 112.9 million for 2015 and USD 117.9 million for 2016.
  - Outcome: The court dismissed the application on 13 September 2023; the Seventh Arbitration Appeal Court upheld that decision on 11 December 2023, and the Arbitration Court of the West Siberian District dismissed the company's cassation appeal on 2 April 2024.
- Attributed: In 2022 Viktor Aranovsky, a former director of the Novosibirsk machine-tool maker PJSC Tyazhstankogidropress, sued that company, JSC BCS Bank, Azimut LLC, JSC Upravlyayushchaya Kompaniya Fondov and FG BCS LTD in the Arbitration Court of the Novosibirsk Region (case A45-33871/2022) for joint payment of RUB 90 million in damages, later increased to RUB 121,335,513.36. He relied on three contracts of 2 December 2016 under which he had sold Tyazhstankogidropress shares to FG BCS Ltd, Upravlyayushchaya Kompaniya Fondov and Azimut, and claimed that the buyers had breached representations that property worth RUB 90 million would stay outside the company sold, together with a ban on challenging its disposal. [src-097] [src-113] [src-115] [src-168]
  - Qualification: The allegations are the claimant's.
  - Outcome: In 2023 the court barred the registration of Azimut's liquidation as an interim measure, upheld up to a Supreme Court judge, and refused to add Oleg Mikhasenko as a co-defendant, a refusal upheld on appeal. No judgment on the merits was found in the retained record.
- Documented: On 17 March 2023 the Arbitration Court of the Novosibirsk Region granted the claimant's request for an interim measure barring the registration of Azimut's liquidation. The Seventh Arbitration Appeal Court upheld the order on 17 May 2023 and the Arbitration Court of the West Siberian District on 10 August 2023; on 23 October 2023 a Supreme Court judge refused to refer Azimut's further cassation complaint for hearing. [src-113]
- Documented: Oleg Mikhasenko took part in the case as a third party. The claimant asked for him to be added as a co-defendant, arguing that he was the beneficiary of the BCS group, controlled the defendant companies and had given them direct instructions on the terms of the share purchases. The first-instance court refused on 2 October 2023, finding that the buyers under the contracts were legal entities rather than him, that any instructions he gave or could have given to group companies did not deprive those companies of legal capacity in the purchase, and that the motion came nine months into the case. On 10 November 2023 the Seventh Arbitration Appeal Court upheld the refusal, holding that the claimant had produced no evidence that Mikhasenko had taken actions with the Tyazhstankogidropress shares that caused him substantial harm, or had derived any benefit from challenging the disposal of the company's property. [src-115] [src-114]
  - Response: Azimut and Oleg Mikhasenko filed responses asking the appeal court to uphold the refusal as lawful and well founded.
- Documented: Russian business press reported in 2022 that Nikolai Stepakin, another former general director of Tyazhstankogidropress, owned all of SMC Stilline, which held 56.25% of the plant; that SMC Stilline had been declared bankrupt in February 2021 over debts to BCS Bank and Sberbank, with BCS Bank the main creditor; that Tyazhstankogidropress had guaranteed a BCS Bank loan, and that in May 2020 the Arbitration Court of the Novosibirsk Region ordered RUB 1.05 billion to be recovered from it by the sale of its real estate. Aranovsky had been the plant's director until 2016. [src-108] [src-097]
- Documented: A Russian business daily reported on 10 March 2022 that the Arbitration Court of the Novosibirsk Region had refused to include a RUB 124.8 million claim by Oleg Mikhasenko, described as president of the BCS financial group, in the register of creditors of Nikolai Stepakin. According to the report, the court found that a RUB 100 million loan agreement between the two men from December 2018 was a sham covering a loan from Mikhasenko to SMC Stilline, made so as to avoid a ban on borrowing without the consent of another creditor, Sberbank, and its ruling referred to an August 2020 ruling that had established the affiliation of BCS Bank, Mikhasenko, Stepakin and SMC Stilline. [src-108]
  - Qualification: The ruling itself is not in the retained record; the account is the newspaper's.
- Attributed: In a July 2023 article on a Novosibirsk news site, which reported that he had again complained to the Prosecutor General of unlawful actions by the investigators and asked for the prosecution against him to be ended, Aranovsky alleged that the criminal case against him had been commissioned by the BCS group, which in 2022 had a new head of Tyazhstankogidropress, in his description controlled by the group, report him and Stepakin to the police for theft of the company's property. He alleged that the group had deceptively lowered the price of his shares by RUB 90 million and, through pledges, refinancing, a controlled bankruptcy and sales of shares between affiliated organisations, had come to own the whole plant, valued at more than RUB 2 billion, for about RUB 45 million of actual cash. [src-150] [src-151]
  - Qualification: These are the allegations of a defendant in the criminal case; the retained record contains no response from the BCS group or the subject to them.
  - Outcome: On 5 August 2025 the regional prosecutor's office announced that Aranovsky had been convicted (see the following paragraph).
- Documented: According to the Novosibirsk regional prosecutor's office, on 5 August 2025 the Kirovsky District Court of Novosibirsk sentenced the former general directors of Tyazhstankogidropress, Nikolai Stepakin, to five and a half years in a general-regime penal colony and a fine of RUB 1.5 million, and Viktor Aranovsky, to a suspended term of four and a half years with five years' probation and a fine of RUB 1.2 million. They had been detained in February 2022 on suspicion of fraud, and further cases for deliberate bankruptcy and laundering of criminal proceeds were opened later. Investigators said that from 2016 to 2020 they had arranged, without the knowledge of shareholders and directors, transactions that took a building, land, industrial equipment and an agricultural subsidiary worth more than RUB 200 million in total out of the plant's control at deliberately understated prices. [src-151]
  - Qualification: The report does not say whether the sentences were appealed.
- Documented: The group's statements for 2022–2025 record that it was the defendant in proceedings brought by one of its clients in Cyprus: the group filed its defence on 22 February 2019, and the plaintiff obtained an injunction freezing about USD 2.6 million (USD 2,611 thousand) as security until final judgment, which the group appealed. Under a settlement agreement of 27 December 2023 the group paid the plaintiff USD 999 thousand, plus legal expenses stated as 'EUR 60', for withdrawal of the claim. [src-045] [src-051] [src-015]
  - Qualification: The statements do not name the plaintiff or the subject matter of the claim. The 2022 statements gave the maximum possible award as about USD 2.6 million plus interest.
  - Response: The group's statements describe the settlement as made without any admission of liability.
  - Outcome: On 25 January 2024 the Limassol District Court dismissed the case as settled out of court.

## Sanctions around the group

- Documented: On 21 November 2024 the US Treasury's Office of Foreign Assets Control (OFAC) designated BCS Bank AO, a Moscow-based bank, as one of more than 50 small and medium-sized Russian banks in an action that also targeted Gazprombank, Russian securities registrars and finance officials. OFAC said the designations were meant to prevent Russia from using the international financial system to pay for the technology and equipment it needed to sustain its war against Ukraine, and warned foreign financial institutions with correspondent relationships with these banks of significant sanctions risk. [src-099]
  - Qualification: BCS Bank was no longer part of the subject's group at the time (see the section on the Russian business). OFAC's announcement does not mention the subject or its affiliates.
- Documented: A consolidated sanctions dataset also lists BCS Bank under Russia- and Ukraine-related programmes of the EU, Switzerland and Australia, and a Russian state news agency reported that the bank had been on the EU sanctions list since July 2026. The Bank of Russia's register of financial-market participants showed the bank, at the time of the research, as holding universal banking licence No. 101 (from 29 November 2018), brokerage and dealer licences (from 14 October 2010) and a depository licence (from 27 June 2014), with no end dates. [src-098] [src-119] [src-106]
- Documented: A Russian state news agency reported on 18 September 2026 that Belgium's Council of State, the country's supreme administrative court, had held unlawful the Belgian treasury's 2024 refusal to release BCS Bank's funds and securities frozen at Euroclear and had annulled it as issued by an authority without the power to decide. The treasury had refused on the grounds that the bank had not shown it had fully ended its relationship with Russia's sanctioned National Settlement Depository and that the bank planned to move the funds out of the EU. [src-106]
  - Qualification: The report does not identify the ruling.
  - Response: The bank challenged the refusal; according to the report, the court sided with it.
  - Outcome: According to the report, the court did not find the freezing itself unlawful; the Belgian authorities were to reconsider the bank's application, with no assured outcome.
- Documented: By a decision of Ukraine's National Security and Defence Council of 6 July 2025, enacted by Presidential Decree No. 465/2025 of the same day, Ukraine imposed personal sanctions for ten years, including the blocking of assets, on Vitalii Oleksandrovych Shelikhovskyi (in Russian, Vitaly Aleksandrovich Shelikhovsky), a Russian citizen. The annex to the decision gives no position or affiliation for him. The Russian taxpayer number it gives is the one that Russian registry data record for Vitaly Shelikhovsky as director and owner of BCS Holding and general director of BCS Company and BCS FT. [src-022] [src-070] [src-174] [src-166]
  - Qualification: The identification rests on the matching name and Russian taxpayer number. The decision does not mention BCS or the subject.
- Documented: A consolidated sanctions dataset lists BrokerCreditService Company LLC (BCS Company), the Novosibirsk broker, as a sanctions target under a Ukrainian sanctions programme. The same dataset marks BCS Holding and its subsidiary BCS FT as linked to, or controlled by, a sanctioned person without listing either of them under a sanctions programme of its own. [src-005] [src-003]
  - Qualification: The underlying Ukrainian decision on BCS Company is not in the retained record. The marks on BCS Holding and BCS FT are derived by the dataset from their ownership and management by Vitaly Shelikhovsky.
- Documented: On 2 November 2023 OFAC added PJSC SPB Exchange (Saint Petersburg Exchange) to its list of Specially Designated Nationals under Executive Order 14024, identifying it as a financial institution. A Russian technology-industry profile of Oleg Mikhasenko lists him as a member of the exchange's board of directors from 17 May 2019. A consolidated sanctions dataset also records UK and Canadian sanctions on the exchange. [src-170] [src-100] [src-013]
  - Qualification: The record does not show whether Mikhasenko still sat on the board when the exchange was designated; the designation concerns the exchange, not him.
- Documented: Screening of consolidated sanctions and politically-exposed-person datasets during the research returned the subject's former name, FG BCS LTD, only as a Russian register record of a foreign organisation with Cyprus registration HE 347295 and no sanctions topics, and returned Oleg Mikhasenko's name only as a Russian register record with no sanctions or PEP topics. [src-002] [src-004]
  - Qualification: Screening covers only the datasets searched; it does not prove that no other listing exists. The match for Mikhasenko is by name.
- Documented: PJSC SPB Exchange, registered on 21 January 2009, organises trading on financial markets from its registered address in Moscow; no termination of its activity is recorded. [src-111]

## Alexey Annenkov: sole director

- Documented: Alexey Annenkov has been the company's sole director since 2 December 2022, appointed for an unlimited period, when Vitaliy Shelikhovskiy left the board. The April 2025 prospectus gives his address as the company's office in Jumeirah Lakes Towers, Dubai, and states that he is also a director of Seldthorn Private Equity Limited, the Cypriot company the group sold to Oleg Mikhasenko in 2022. [src-001] [src-015]
- Documented: Copies of the Cyprus register published by registry aggregators link a director named Alexey Annenkov with companies of the group's circle besides FG BCS LTD: Seldthorn Private Equity, BCS Global Markets Holding, Routa Luxury Services, Almarea and Danofe Trading; another copy names him as authorised person of the Cypriot registration of BCS Prime Brokerage Limited. A professional-networking profile for 'Alex Annenkov' in Limassol gives Seldthorn Private Equity Limited as the current employer. [src-009] [src-021] [src-165]
  - Qualification: The aggregators present these links as possible matches by name; the Cyprus register publishes no identifiers for officers.
- Documented: Russian registry data record a person with the same full name, Alexey Vladimirovich Annenkov, as liquidator of ZAO BrokerCreditService, a Moscow broker registered in 2006 at Prospekt Mira 69, building 1, and liquidated on 7 August 2015; and from 13 October 2015 as liquidator of the non-state educational institution 'BCS Training Centre', registered at the same address, and from 17 December 2015 of LLC IK Yugra Nefteprodukt, a Novosibirsk exchange broker, among other companies. In January 2026 the Kazakh subsidiary's website gave Prospekt Mira 69, building 1, as the address of the group's 'Moscow Headquarters'. [src-054] [src-038] [src-112] [src-130]
  - Qualification: The Russian records do not link this person by any identifier to the director of the subject; the identification rests on the full name, which also appears for the subject's director in Kazakh records and in the Uralsib group-of-persons list, and on the BCS names and Moscow address of the companies.

## Sources

- [src-001] Company statement source · src-001
- [src-007] DMCC list of transfers of incorporation, Dubai Multi Commodities Centre Authority <https://dmcc.ae/members/support/transfer-incorporation>
- [src-009] Corporate registry source · src-009
- [src-021] Corporate registry source · src-021
- [src-085] Corporate registry source · src-085
- [src-127] Corporate registry source · src-127
- [src-020] Corporate registry source · src-020
- [src-011] Company statement source · src-011
- [src-039] Company statement source · src-039
- [src-018] GLEIF LEI record: THE ULTIMA WORLD DMCC (213800GU1EOKGT4JCA10), Global Legal Entity Identifier Foundation, 2026-10-15 <https://api.gleif.org/api/v1/lei-records/213800GU1EOKGT4JCA10>
- [src-034] Company statement source · src-034
- [src-006] FINRA BrokerCheck report: The Ultima Global Markets (USA) Inc. (CRD 47895), Financial Industry Regulatory Authority, 2026-10-15 <https://files.brokercheck.finra.org/firm/firm_47895.pdf>
- [src-032] Corporate registry source · src-032
- [src-133] Corporate registry source · src-133
- [src-117] Corporate registry source · src-117
- [src-055] Corporate registry source · src-055
- [src-045] Company statement source · src-045
- [src-015] Company statement source · src-015
- [src-031] Regulatory record source · src-031
- [src-067] Company statement source · src-067
- [src-040] Company statement source · src-040
- [src-051] Company statement source · src-051
- [src-019] GLEIF direct children of THE ULTIMA WORLD DMCC, Global Legal Entity Identifier Foundation, 2026-10-15 <https://api.gleif.org/api/v1/lei-records/213800GU1EOKGT4JCA10/direct-children>
- [src-065] Corporate registry source · src-065
- [src-050] Corporate registry source · src-050
- [src-167] GLEIF LEI record: KERTINA GROUP LTD., Global Legal Entity Identifier Foundation, 2026-10-15 <https://api.gleif.org/api/v1/lei-records/213800UYFYEM6H4TE951>
- [src-083] Corporate registry source · src-083
- [src-082] GLEIF LEI record: BOTIMELO GROUP LTD, Global Legal Entity Identifier Foundation, 2026-10-15 <https://api.gleif.org/api/v1/lei-records/213800Y95GDKFQOBEV32>
- [src-116] Court record source · src-116
- [src-014] Companies House: GBM SECURITIES LIMITED (08040031), officers, Companies House (UK) <https://find-and-update.company-information.service.gov.uk/company/08040031/officers>
- [src-087] Companies House: appointments of Vitaliy Shelikhovskiy, Companies House (UK) <https://find-and-update.company-information.service.gov.uk/officers/WsSaqlfDmMGmp-M3p8ebcE6BdmA/appointments>
- [src-110] Companies House: appointments of Edward Golosov, Companies House (UK) <https://find-and-update.company-information.service.gov.uk/officers/xA1RsyV7j8WoxS2iNqOYhtf-YCA/appointments>
- [src-023] Corporate registry source · src-023
- [src-036] Company statement source · src-036
- [src-033] Company statement source · src-033
- [src-124] Company statement source · src-124
- [src-013] Media source · src-013
- [src-012] Companies House: GBM SECURITIES LIMITED (08040031), persons with significant control, Companies House (UK) <https://find-and-update.company-information.service.gov.uk/company/08040031/persons-with-significant-control>
- [src-155] Media source · src-155
- [src-109] Corporate registry source · src-109
- [src-052] Corporate registry source · src-052
- [src-144] Corporate registry source · src-144
- [src-003] Sanctions list source · src-003
- [src-005] Sanctions list source · src-005
- [src-070] Corporate registry source · src-070
- [src-080] Corporate registry source · src-080
- [src-081] Corporate registry source · src-081
- [src-069] Corporate registry source · src-069
- [src-118] Corporate registry source · src-118
- [src-017] Corporate registry source · src-017
- [src-079] Corporate registry source · src-079
- [src-174] Corporate registry source · src-174
- [src-071] Corporate registry source · src-071
- [src-166] Corporate registry source · src-166
- [src-135] Corporate registry source · src-135
- [src-056] Corporate registry source · src-056
- [src-057] Corporate registry source · src-057
- [src-090] Corporate registry source · src-090
- [src-169] Company statement source · src-169
- [src-136] Regulatory record source · src-136
- [src-058] Corporate registry source · src-058
- [src-089] Corporate registry source · src-089
- [src-072] Corporate registry source · src-072
- [src-073] Corporate registry source · src-073
- [src-094] Corporate registry source · src-094
- [src-123] Corporate registry source · src-123
- [src-125] Corporate registry source · src-125
- [src-115] Court record source · src-115
- [src-126] Corporate registry source · src-126
- [src-153] Corporate registry source · src-153
- [src-037] Corporate registry source · src-037
- [src-147] Bank of Russia decisions concerning BrokerCreditService Company LLC, Bank of Russia, 2026-10-14 <https://cbr.ru/finorg/foinfo/rbr/?id=2985>
- [src-063] Corporate registry source · src-063
- [src-064] Corporate registry source · src-064
- [src-068] Corporate registry source · src-068
- [src-074] Corporate registry source · src-074
- [src-075] Corporate registry source · src-075
- [src-078] Corporate registry source · src-078
- [src-076] Corporate registry source · src-076
- [src-077] GLEIF LEI record: BCS GLOBAL MARKETS HOLDING LTD, Global Legal Entity Identifier Foundation, 2026-10-15 <https://api.gleif.org/api/v1/lei-records/2138002OHT13KQ4B3T42>
- [src-091] Corporate registry source · src-091
- [src-008] Company statement source · src-008
- [src-101] DFSA public register: The Ultima World (DIFC) Limited, Dubai Financial Services Authority <https://www.dfsa.ae/public-register/firms/ultima-world-difc-limited>
- [src-171] Media source · src-171
- [src-102] DFSA public register: Edward Golosov, Dubai Financial Services Authority <https://www.dfsa.ae/public-register/individuals/mr-edward-golosov>
- [src-120] DFSA public register: Andrey Chuprin, Dubai Financial Services Authority <https://www.dfsa.ae/public-register/individuals/mr-andrey-chuprin>
- [src-121] DFSA public register: Alina Perepelkina, Dubai Financial Services Authority <https://www.dfsa.ae/public-register/individuals/ms-alina-suliukmanova>
- [src-122] DFSA public register: Rafik Faik Ogly Abasov, Dubai Financial Services Authority <https://www.dfsa.ae/public-register/individuals/mr-rafik-faik-ogly-abasov>
- [src-138] DFSA public register: Simon Victor James Gilder, Dubai Financial Services Authority <https://www.dfsa.ae/public-register/individuals/mr-simon-victor-james-gilder>
- [src-139] DFSA public register: Alexander Zakharkin, Dubai Financial Services Authority <https://www.dfsa.ae/public-register/individuals/mr-alexander-zakharkin>
- [src-140] DFSA public register: Denis Zabolotnev, Dubai Financial Services Authority <https://www.dfsa.ae/public-register/individuals/mr-denis-zabolotnev>
- [src-141] DFSA public register: Evgenii Tolpykin, Dubai Financial Services Authority <https://www.dfsa.ae/public-register/individuals/mr-evgenii-tolpykin>
- [src-142] DFSA public register: Sergey Kaminskiy, Dubai Financial Services Authority <https://www.dfsa.ae/public-register/individuals/mr-sergey-kaminskiy>
- [src-143] DFSA public register: Stephen Lee Coles, Dubai Financial Services Authority <https://www.dfsa.ae/public-register/individuals/mr-stephen-lee-coles>
- [src-086] Company statement source · src-086
- [src-163] Company statement source · src-163
- [src-049] Media source · src-049
- [src-105] Media source · src-105
- [src-134] Other source · src-134
- [src-176] Other source · src-176
- [src-148] Media source · src-148
- [src-061] Regulatory record source · src-061
- [src-010] AFSA public register: The Ultima Global Markets Qazaqstan Limited (BIN 221040900440), Astana Financial Services Authority <https://publicreg.myafsa.com/details/221040900440/>
- [src-038] Company statement source · src-038
- [src-044] Corporate registry source · src-044
- [src-088] Corporate registry source · src-088
- [src-027] AFSA public register search for "Ultima", Astana Financial Services Authority <https://publicreg.myafsa.com/roc/?form=&name=Ultima&page=1>
- [src-035] Company statement source · src-035
- [src-131] AFSA alert: fraudulent impersonation of The Ultima Global Markets Qazaqstan Limited, Astana Financial Services Authority <https://afsa.aifc.kz/alert-fraudulent-impersonation-of-the-ultima-global-markets-qazaqstan-limited/>
- [src-016] DFSA alert: The Ultima World (DIFC) Limited impersonated, Dubai Financial Services Authority, 2026-05-13 <https://www.dfsa.ae/alerts/ultima-world-difc-limited-impersonated>
- [src-164] Media source · src-164
- [src-156] Other source · src-156
- [src-158] Company statement source · src-158
- [src-157] Other source · src-157
- [src-161] Other source · src-161
- [src-159] Other source · src-159
- [src-162] Other source · src-162
- [src-152] Company statement source · src-152
- [src-137] Media source · src-137
- [src-029] FINRA BrokerCheck report: Michael J. Schilling, Financial Industry Regulatory Authority, 2026-10-15 <https://files.brokercheck.finra.org/individual/individual_2609624.pdf>
- [src-028] FINRA BrokerCheck report: Michael P. Healy, Financial Industry Regulatory Authority, 2026-10-15 <https://files.brokercheck.finra.org/individual/individual_2631361.pdf>
- [src-025] Corporate registry source · src-025
- [src-030] Corporate registry source · src-030
- [src-047] Corporate registry source · src-047
- [src-048] Corporate registry source · src-048
- [src-046] Company statement source · src-046
- [src-173] Company statement source · src-173
- [src-043] GLEIF LEI records: The Ultima Investment Hong Kong Limited and Seldthorn Private Equity Limited, Global Legal Entity Identifier Foundation, 2026-10-15 <https://api.gleif.org/api/v1/lei-records?filter[lei]=213800NKGTTS4PB9M167,213800HJAFQCPVHVIG13>
- [src-175] FSMA register: The Ultima Investments Cyprus Ltd, Financial Services and Markets Authority (Belgium) <https://www.fsma.be/en/party/ultima-investments-cyprus-ltd>
- [src-103] CySEC announcement of a board decision concerning BrokerCreditService (Cyprus) Limited (fine), Cyprus Securities and Exchange Commission, 2022-04-19 <https://www.cysec.gov.cy/CMSPages/GetFile.aspx?guid=446c79d2-ef4f-4359-ab22-faf2f039aa23>
- [src-104] CySEC announcement of a settlement with BrokerCreditService (Cyprus) Limited, Cyprus Securities and Exchange Commission, 2023-07-12 <https://www.cysec.gov.cy/CMSPages/GetFile.aspx?guid=917e431a-79e7-43be-a634-3ab1b93a36c1>
- [src-024] Corporate registry source · src-024
- [src-172] Media source · src-172
- [src-145] Corporate registry source · src-145
- [src-084] Corporate registry source · src-084
- [src-154] Corporate registry source · src-154
- [src-041] GLEIF LEI records: The Ultima Products HK Limited, Spidertek Ltd and LTM SV LLC, Global Legal Entity Identifier Foundation, 2026-10-15 <https://api.gleif.org/api/v1/lei-records?filter[lei]=213800JH99X3GP3MVR31,213800HEIJQAN5MOGK95,213800L2FJC1RC98U767>
- [src-026] GLEIF LEI record: THE ULTIMA ASIA LIMITED, Global Legal Entity Identifier Foundation, 2026-10-15 <https://api.gleif.org/api/v1/lei-records/2138004AI3JTBQL9KW05>
- [src-066] Company statement source · src-066
- [src-042] Corporate registry source · src-042
- [src-053] Corporate registry source · src-053
- [src-092] Media source · src-092
- [src-107] Media source · src-107
- [src-062] GLEIF LEI records matching BROKSTOCK, Global Legal Entity Identifier Foundation, 2026-10-15 <https://api.gleif.org/api/v1/lei-records?filter[fulltext]=BROKSTOCK>
- [src-129] Company statement source · src-129
- [src-160] Other source · src-160
- [src-132] Other source · src-132
- [src-059] GLEIF LEI record: HEELVEIL LTD., Global Legal Entity Identifier Foundation, 2026-10-15 <https://api.gleif.org/api/v1/lei-records/2138007JU7U5FVQXBI19>
- [src-093] Corporate registry source · src-093
- [src-060] Other source · src-060
- [src-128] Company statement source · src-128
- [src-149] GLEIF LEI records matching FG AVIATION, Global Legal Entity Identifier Foundation, 2026-10-15 <https://api.gleif.org/api/v1/lei-records?filter[fulltext]=FG%20AVIATION>
- [src-096] Court record source · src-096
- [src-146] Court record source · src-146
- [src-095] Court record source · src-095
- [src-097] Media source · src-097
- [src-113] Court record source · src-113
- [src-168] Court record source · src-168
- [src-114] Other source · src-114
- [src-108] Media source · src-108
- [src-150] Media source · src-150
- [src-151] Media source · src-151
- [src-099] U.S. Treasury press release: Treasury sanctions Gazprombank and takes additional steps to curtail Russia's use of the international financial system, U.S. Department of the Treasury, 2024-11-21 <https://home.treasury.gov/news/press-releases/jy2725>
- [src-098] Sanctions list source · src-098
- [src-119] Bank of Russia directory of financial-market participants: JSC BCS Bank, Bank of Russia, 2026-10-15 <https://cbr.ru/finorg/foinfo/?ogrn=1055400000369>
- [src-106] Media source · src-106
- [src-022] Annex 1 to the decision of the National Security and Defence Council of Ukraine of 6 July 2025 (Presidential Decree No. 465/2025), National Security and Defence Council of Ukraine, 2025-07-06 <https://www.rnbo.gov.ua/files/2025/DECREES/465_2025/dodatok_465_2025_1.pdf>
- [src-170] OFAC recent actions: Russia-related designations of 2 November 2023, Office of Foreign Assets Control, U.S. Department of the Treasury, 2023-11-02 <https://ofac.treasury.gov/recent-actions/20231102>
- [src-100] Sanctions list source · src-100
- [src-002] Sanctions list source · src-002
- [src-004] Sanctions list source · src-004
- [src-111] Corporate registry source · src-111
- [src-165] Other source · src-165
- [src-054] Corporate registry source · src-054
- [src-112] Corporate registry source · src-112
- [src-130] Corporate registry source · src-130
