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 to Highland Ventures. According to one wire transfer, on January 30, 2013, Milasi Engineering transferred $69,600,000 from its account at SMP Bank in Moscow to Highland Ventures' account at The Pictet Group, a private bank with offices in Geneva, Switzerland. Payment details for the wire transfer described the funds as "dividends for 2011 year," suggesting Highland Ventures—or its beneficial owner—was one of Milasi Engineering's shareholders. A second wire transfer on December 18, 2013, shows Milasi Engineering transferred $54,451,493.49 from its account at Gazprombank in Moscow to the same Highland Ventures account at The Pictet Group. That wire transfer described the funds as "dividends for 2012 year." Together, the two transfers to Highland Ventures from Milasi Engineering exceeded $124 million.

Three months later, on March 18, 2014, two days after President Obama signed EO 13661, which authorized sanctions on individuals providing material support to the Russian government, Highland Ventures moved $39,588,000 from its account with The Pictet Group in Geneva, Switzerland to its account at Gazprombank in Moscow, Russia. Two days after that, on March 20, 2014, the U.S. Treasury Department designated Arkady and Boris Rotenberg as sanctioned

determined that Culloden "has always been owned by Boris Rotenberg since it was incorporated" and following sanctions on Boris Rotenberg "Markom continued with the transfer of the company to Cyprus." See BARC_006068-69. After the transfer of Arkady Rotenberg's interests, Milasi Engineering was majority owned by Igor Rotenberg who, at the time, was not yet sanctioned by the United States. This was presumably purposeful to comply with the Treasury Department rule that a company is only considered blocked if it is majority owned by a sanctioned individual. See (2014), https://www.treasury.gov/resource-center/sanctions/Documents/licensing_guidance.pdf. Therefore, the fact that sanctioned Boris Rotenberg owned a minority share did not affect Milasi Engineering's status as a sanctioned entity. As with Highland Ventures, Milasi Engineering made U.S. dollar transfers labeled as dividends to Culloden. On January 30, 2013 Milasi Engineering transferred $63,880,000 from its SMP Bank account in Moscow to Culloden's account at The Pictet Group with the wire instructions "Dividends for 2011 Year." See JPMorgan Chase (Nov. 7, 2018), SB981623-FI US Wire Search, Milasi Engineering, line 5. On October 8, 2013, Milasi Engineering sent $15,000,000 from its SMP Bank account to Culloden's Societe Generale account in New York with the same wire instructions. See JPMorgan Chase (Nov. 7, 2018), SB981623-FI US Wire Search, Milasi Engineering, line 9. Milasi made two large transfers from its Gazprombank account to Culloden's accounts at The Pictet Group and Societe Generale in New York on January 9, 2014 for $41,711,697.34 and $19,999,963.34, respectively. Both payments included the wire instructions "Dividends for 2012 Year." DBAG00000019, lines 34 & 35. Mr. Omelnitski admitted to Barclays during its investigation that Culloden was owned by Boris Rotenberg, and explained he was in the process of transferring Culloden to Cyprus in May 2016. See BARC_006811-17.