Sandalwood Continental Ltd.

🔴 High Risk

Jurisdiction of Registration

British Virgin Islands

Incorporation Date

Prior to 2006 (exact date unknown; active by March 2006 based on shareholder changes).

Registered Address

N/A

Directors / Shareholders

Shareholders included Oleg Gordin (from October 2007, law enforcement background), Vladislav Khotimsky (March 2006 to June 2007), and Alexander Plekhoz (June 2007). Mossack Fonseca provided nominee directors as proxies.

Beneficial Owner(s)

Suspected proxies for Sergei Roldugin (Putin confidant) and Bank Rossiya principals. No transparent UBO disclosure due to BVI’s weak enforcement.

Linked Individuals

Sergei Roldugin (cellist, Putin associate/PEP); Oleg Gordin (proxy with power of attorney); figures tied to Bank Rossiya (called Putin’s “cashier”); potential Mikhail Lesin links via successor entities.

Linked Entities

Ove Financial Corp. (BVI, successor post-2012); International Media Overseas (Panama, Roldugin-linked); Horwich Trading Ltd. (Cyprus); RCB Bank (Cyprus, VTB-backed); Sonnette Overseas (BVI, Roldugin-owned); entities in Troika Laundromat scheme.

Purpose

Shell vehicle for laundering Russian state-linked funds, concealing capital outflows via unsecured loans, interest assignments for $1, and fake share deals; asset concealment for Putin’s circle, evading sanctions/taxes through Cyprus-Russia-BVI loops.

Red Flags Identified

Unsecured $800M+ loans from RCB with no repayment capacity or collateral; $1 asset flips for $133M; luxury overvaluation in opaque deals (e.g., Rosneft shares); BVI’s zero transparency enabling proxy layers; Mossack Fonseca compliance alarms on $103M loan lacking economic sense. BVI’s lax AML rules politically abet such opacity, ignoring PEP risks.

Estimated Amount Laundered

Approximately $2 billion routed 2008-2013, including $800M RCB credit line, $600M loaned 2009, $350M in 2010; $57.6M from Troika Laundromat.

Involvement in Investigations or Leaks

Central to Panama Papers (ICIJ/OCCRP, 2016); implicated in Troika Laundromat (OCCRP, 2019) for fake deals benefiting Roldugin.

Regulatory Actions / Legal Proceedings

N/A

Sources

Sandalwood Continental Ltd.

Country of Incorporation:

United States

Year of Incorporation:

Registered Address:

N/A

Legal Structure / Entity Type:

Limited company (shell entity via Mossack Fonseca nominees)

Linked Real Estate Assets:

N/A

Linked Corporate Entities:

Ove Financial Corp. (BVI successor); International Media Overseas (Panama); Horwich Trading Ltd. (Cyprus); Sonnette Overseas (BVI); RCB Bank (Cyprus, VTB-backed); Troika Laundromat entities

Known Beneficial Owners:

N/A

PEPs Linked:

Sergei Roldugin (Putin confidant/PEP); Bank Rossiya figures (Putin’s “cashier”)

Involved in Laundering Schemes?:

Known Bank Accounts or IBANs:

N/A

Law Firm or Agent Used:

Mossack Fonseca (provided nominees and flagged suspicious activity internally)

Related Offshore Leak :

Panama Papers (ICIJ/OCCRP, 2016); Troika Laundromat (OCCRP, 2019)

Status of Entity:

Liquidated

Year of Dissolution (if any):

Jurisdiction:

British Virgin Islands

AML Network Risk Rating:

🔴 High Risk