"Between 2011 and 2016, I transferred more than $700 million out of Kyrgyzstan."
At first glance, the confession seemed unbelievable. But Aierken Saimaiti, a 37-year-old Uyghur man who met with reporters in 2019, had the documents to prove it.
Those papers would provide the evidence for one of the most sensational corruption stories in the modern history of Central Asia: The canny operator had spent years in the employment of Khabibula Abdukadyr, whom he accused of running a smuggling empire that was raking in huge profits with the help of complicit Kyrgyz customs officials.
Saimaiti said he used a variety of fraudulent techniques to help launder the proceeds of that empire out of the region, where it could safely be stored in German bank accounts, British properties, and Dubai real estate developments that belonged to Abdukadyr and his family.
The laundering of so much dirty money out of Kyrgyzstan was a political bombshell, leading to fierce protests and eventually contributing to an uprising that overthrew the government.
But one question has remained unanswered: How could Saimaiti's hundreds of millions of dollars pass through both local and international banks for years without ever being noticed?
A new review of more than 2,000 Suspicious Activity Reports (SARs) -- filed to the U.S. Treasury by U.S. banks and later leaked to reporters -- offers a partial answer. (The reports were made available to OCCRP as part of the FinCEN Files, a collaborative investigation led by the International Consortium of Investigative Journalists and BuzzFeed News.)
Five of the reports in the leaked batch raised red flags about Saimaiti and the companies that received the money he sent. They were filed between February 2014 and January 2015 by officers from the U.S. branch of Deutsche Bank, which served as a correspondent bank for some of Saimaiti's U.S.-dollar transactions.
A correspondent bank is a third-party financial institution that acts as a go-between for banks in different countries that need to conduct cross-border payments with each other.
If you look at any basic research on what has happened in that country, the lack of integrity in government, you should not be relying on their banking institutions. You should be hiring independent experts if you have multiple millions of dollars flowing through your bank."-- Louise Shelley, Terrorism, Transnational Crime and Corruption Center
According to the reports, hundreds of Saimaiti's wire transfers to Abdukadyr companies and to Khabibula Abdukadyr himself were marked "suspicious." Compliance officers noted several classic signs of money laundering: He sent money in large round-dollar amounts, and the business purposes of the transactions were often unclear. In addition, the relationship between Saimaiti and the companies who received his money could not be independently established.
In at least some cases, Deutsche Bank employees tried to get to the bottom of what Saimaiti was doing. The SARs show that they repeatedly questioned his Kyrgyz banks about the purpose of his outgoing transactions. But their invariable answer was that Saimaiti was a legitimate entrepreneur and that everything was in order. At least three banks gave almost identical summaries, writing that they did not have "any reason to believe that the transactions are in any way of a suspicious nature."
Louise Shelley, a financial crime specialist who directs the Terrorism, Transnational Crime and Corruption Center at George Mason University, says that Deutsche Bank was working with insufficient information.
"If you look at any basic research on what has happened in that country, the lack of integrity in government, you should not be relying on their banking institutions," she said. "You should be hiring independent experts if you have multiple millions of dollars flowing through your bank."
In such cases, she said, banks can rely on a community of specialists.
"There are seminars for this," she said. "There used to be a company that would have seminars for bankers, [explaining] what you need to watch for in accepting money from the former Soviet Union."
But the problem goes beyond banks. The large volume of suspicious activity reports submitted to the U.S. Treasury Department every year means that any given case is unlikely to receive sufficient scrutiny, she said.
"Treasury doesn't have enough staff and it doesn't have enough [artificial intelligence]," Shelley said. "It doesn't use enough data analytics or have enough people trained in data analytics to pull all the pieces together."
In response to requests for comment, Deutsche Bank said it could not respond to questions about specific clients. "Banks file SARs on a regular basis, which is one of our legal obligations as part of the framework connecting financial institutions and law enforcement in the fight against financial crime," a spokesperson wrote. "That same framework legally restricts us from commenting further."
The Abdukadyr family acknowledged receiving questions from an email address known to be used by Khabibula Abdukadyr, but said they could provide information only at a later date.
'Help Us To Understand'
One exchange between Deutsche Bank and Investment Trade Bank, the Russian parent of one of Saimaiti's Kyrgyz banks, Rosinbank, highlights the dubious nature of the available information about him. (Rosinbank is now called Keremet Bank and is no longer owned by Investment Trade Bank.)
The case concerns one of the Abdukadyr family's main German companies, AKA Immobilien (now renamed AKA Group).
Over the course of 2014, Saimaiti sent at least $17.4 million to the company in 40 transactions, according to his records. He invented various justifications for these transfers, including "debt return" and the purchase of "textile materials" -- in the latter case, even citing what looked like a specific contract number.
But despite his efforts, Deutsche Bank grew suspicious. That spring, it sent an inquiry to the Investment Trade Bank asking for information about him, the recipients of his money, and the business purpose of his transactions.
The response was puzzling and likely did little to assuage the compliance officers' concerns. The reason for Saimaiti's transactions had been described incorrectly, the bank wrote, due to "technical mistakes…made by a client manager due to lack of attention."
In fact, the bank wrote, Saimaiti was sending $15 million to AKA Immobilien because he was purchasing property in a German municipality called Vaterstetten, just outside Munich, to establish a supermarket.
In response, Deutsche Bank asked a logical follow-up question: "From a previous response provided from your bank it was stated that your client is engaged in the wholesale trade of textile goods…clothes and carpets. Please can you help us to understand why your client is purchasing property for a supermarket?"
Investment Trade Bank answered: "Aerken [sic] Saimaiti (private entrepreneur) is in a process of expanding his business activity not only in the Kyrgyz Republic, but also in other countries," adding that "his transaction for purchase of supermarket is the investment for the future business activity in Germany."
This explanation turned out to be false. Saimaiti never acquired the Vaterstetten property. One local official who dealt closely with the development of the site said he had never heard of him.
Rather, the Vaterstetten property was acquired that same year by the Abdukadyr family's AKA Immobilien itself, possibly using the very same money Saimaiti was sending. The company's now-defunct website described its plans for the site: A 220-room hotel with an expected completion date of December 2017.
As with several other proposed Abdukadyr developments, those plans never came to fruition. In 2017, AKA Immobilien sold the property to a Bavarian company. When contacted by reporters, the Bavarian company's representative said the firm bought the plot through real estate agents and had no contact with the previous owners.
The documents in reporters' possession don't indicate whether Deutsche Bank was satisfied with the explanation it was given by Saimaiti's bank, or what other internal deliberations it made about Saimaiti's transfers. Equally unknown is whether the other banks that responded to Deutsche Bank about Saimaiti -- EcoIslamic Bank and Rosinbank (now Keremet Bank) -- had been misled by him, did not have full knowledge of what he was doing, or were intentionally providing false information.
Keremet bank did not respond to requests for comment. A representative of EcoIslamic Bank said he could not comment on Saimaiti’s transactions because the records from that period had been destroyed in line with regular practice.
The documents obtained by reporters shed no light on whether the main German branch of Deutsche Bank -- where AKA Immobilien held its account -- had any suspicions about Saimaiti's incoming money.
What's clear is that Saimaiti was able to continue sending money to Abdukadyr companies until at least 2017.
