BE} Kroll. 24 Apnt 2917 Project Arjan Report prepared for Mauritius Financial Services Commission Report Status Final Report*} Kroll Project Ajan Private & Confidential Restricted Use Warning Ths reper was prepared by Rro!! af me request of sme cuent to whom ts furnished The repcits ana snformation recewee “om kro! confidential ane are itera using this report are st So'ely fo the prvate ana erciusive 6 ‘clon! any ® sornection wih a business investment or et PUBOSeS, cradlt evaluation of snpursnce roa! outmost Ay wring CurpOseS) +S stocty prohtted ang cient has agreed that no sven use wit Ocew Ary Dubilcation Gisciosure dissemination oF Feproauetion oF ths ‘epart ar sny Portion ot ts “4 patves witout teaovance wntian consent of Kroll cot authorizea Krol azaurves 3 consaquentia! uabity 2 vaity oF any adaressee of :nis report for the infcnmation contained herein, ae interpretation or applications or for omissions. 0° fer raance by ary Auch thied party or other verson thereon To the extent informal provided in ths ports based on a rewaN of puDiCly-avAlacle recores such information. a8 present eles upon tne accuracy and comproteness of those ‘ecards. which have not been corroborated by K’ Statements neren concerning f observations based solely on Krol's cial, togulatory oF iegal matters shau's ve undersload = be jenence as “sk consultants and "nay not be relied upes 36 finan: Snot authonzed te prowde All such ~atters should be ravenna win reguiatory & egal aavice auch Kio! approvvately quashed advisors 1s these areas This report does not constitute a rec endorsemen: opinion oF aoprave: of ony xd with vespect 10 any transaction, Secisi0n oF @vAlvation ano snovid nat be ‘eid upor a8 Buen Ure! any Cxeumatarces, Private and Contiantalé} Kroll Project Arjan Contents 1, Introduction and methocology 4 2. Executive summary 5 3. ASAfricen Asset Management Ltd, Alvaro Sobrinho and José Pinto 7 32 Sauce commentary an cepsraten inside ad ase AGO 4. Regulatory 16 42 ——-Razustoyingaton 6 Private and Coniaenta __________________4 Kroll Project Arjan 1. Introduction and methodology To support the Mauritius Francial Services Commission ( FSC") assessment of license applications on two subjects, Alvaro Soorinho and José Pinto (the subjects") The subjects are principals of regulated activives. you ("ine ) requested Krol to conduct a aus dhigence AS African Asset Management Ltd, To ensure that our work is relevant to the FSC, in addition to ‘gathering material on the two subjects, wo have focused our investigatory work on AS Atvican Asset Management Ltd. the entity seeking a license mn Mauritius ‘The objective of the investigation nas been ie cenlity material legal proceedings signficant business or personal cor porate governance issues undisclosed business interests of any other issues that migh lect on the subjects’ reputation. character or credibilty and pase 2 reputational andlor regulatory risk to the FSC Our public records research consisted af a review of information and sources meluding English French- and Portuguese -ianguage ocal, regional and international magia and interne! resources, available Ktigation and regulatory sources. as weil as international financial crimes. regulatory and compliance databases, domain we also conducted To support our analysis of information in the pun creet enquines with sources including but nat hmited to senior members of Angola's ruling politcal party MPLA (Movimento Popular de Liborieyéo de Angota) and Senior Angolan officials. in Angola we also consulted with journalist ana media sources, lawyers and representatives of the private sector mote generally. Quiside Angola, we consulted with @ Senior banking executives with experience of the subjects. an executive of 3 large pan-African banking g/oup and a risk and compliance K officer of a large Soutn Atucar The source enquires were corducted in sinct confidence ane therefore the matenals ana contents provided in this report must be treated contisentiaty, Please also note that despite our best efforts to achieve factual and accurate information, reparting, results and interpretations ot human source :nformaton are subjective wn nature and the Ghent should take this into account when reviawing our product This report sets out our key fincings. Prwate and Cantidontia! eee ee a eh41 Kroll Project Arjan 2. Executive summary Alvaro Sobrinho Alvaro Sobninho's (Sobrinho") public profile is extensive and is characterised by his connection {0 Several investigations into alleged money launcenng and cther financial misconduct, in particular those being conducted by the Portuguese authorities While the exact extent ana current status of these matters 1s unclear (fui sequest), they represent a notable adverse feature of Sobrinho's reputational prolle Many of the ther enquines in Portugal can @ conducted on allegations against him relate to the collapse of the Portuguese bank Banco Espino Santo where Sobrinho served as the CEQ/Chauman of ils Angolan branch Between 2002 and 2012. Our research suggests tnat Sodrinho is well-connected to the Angolan political and business ehtes. Kroll regularly carries out investigatory work in Angola across a range af sectors for a diverse group of clients, We have developed an in-depth understanding of the operating environment and, specifically transparency concerns associated wih the business practices of senior members of the MPLA, We note that camments from our Indiviguals closely attilated wit network of sources in Angola relating to Sebrinne ave favourable supportive and, on occasion m. These views are in stark owectly challenge tne credien mentary sourced trom outside Angola Our enguities found that, 1 y of allegations made against + contrast te negatwe Angola, tne subjects benefit fron: an apparent level of protection” by the Angatan authorities This i¢ not unusual and in our expatiance, reduces the likelhood of adverse commentary oF legal proceedings in Angola, despite ongoing investigations in other jurisdictions Mulupie sources inside Angola, including high fovel political, legal and business executes. acknowledged that due to Sobrinho's status and connections, he has no difficulty in conducting business im Angola. The same sources expresses contiaence that despite investigations Portugal, Sobrinho is “protected” by the Angolan authorities and political establisnment, and 1s unikely to exeerience legal or regulatory consequences in Angela, One Luanda-bases expatriate lawyer provided @ view on why this protection 1s hikely so continue, explaining that Sobrinhe ‘essentially worked as jhe rubng party] MPLAS personal banker’ during his tenure at Barco Espirito Santo Angola ("BESA’) While some local sources in Angola dismissed tne investigations into Sobrinno as vindictive other contacts — including an Angotan bank airector ~ believed tne claims against him tc be vatic, [Ail sources acknowledged that authorities inside Angola were unlikely to pursue or reopen cases. against Sobrinno. This corresponds with commenis made by the Attorney-General 5 Office which has confirmed that Sobrinho will not be subject to legal proceedings wn Angola. Sources also Prvate aad Contdentai& Kroll Project Ayan believed that there would be "10 cooperation between the Angolan and Portuguese auinenties 1" elation to attempls to ciminaise” Soonmho. An Angolan banking source conchited by saying that while his bank was ‘no! worried about Soprinho’s dealings in Angola, there would ~n ‘more reluctance’ trom European nanks We also consulted some senior financial services executives who operate cutside of Angola an ‘are unconnected to the country & business and political alites. These sources were aware of tne Chent'’s matter in Mauntius ang stated that thei respective banks would not do business win Sobrinho of any businesses affliated with hun A senior pan-Alncan panking group exec further claimed that the subjects were “personae ran grata” at "is bank The banking sources the smuation y9 Portugal = believed tna! Sobrinto and his associates would nave fo wait unt relating to alleged judicial misconduct by the pubhe prosecutor Oriango Figueira who reportesiy cleared cases (incluaing Sovrinhe s) i exchange for bres ~ was resolved They aid not peleve that Sobrinho had “enough infuueae” to change the outcome of this investigation in Portugal Jose Pinto Jose Pinto (Pinto) ~ described by one source in Angola as Sobrinhos 1s0 conigani — appears to have 4 limited peafile in ine public domam ' The limited information avaiable reters to his close relationship with Sobanhe and his role 6 various entites inked tc their shared business interests AS African Asset Management AS African Asset Management AS" nas a neghgible public profile It snould be noted at sxe outset of nis report that much of the available material covering AS in the public domain relates Cent's decision to halt the company's licencing process in Mauritius 7 te press coverage of the March 2017 We dia not wentify mentions of Sobrinho, Pinto and AS on sntemational financial crmes government sanctions watch-ists Current investigations are typicaily nol part of regulatory the public record and therefore any possible cutrent involvement would not be captured in these watch ists uo to Petes common name, ee anaes of ne publ pre was ‘argeled By Amey Seated Yo AnoW deta Private and Conte a*} Kroll Project Arjan 3. AS African Asset Management Ltd, Alvaro Sobrinho and José Pinto AS African Asset Management Ltd” ("AS") was registered on 27 August 2015 in Mauritius.’ As a Global Business Category * company, information on its directors and shareholders 1s Publicly avaiaole. AS has a limited public profile The majonty of references to the company in the public domain relate to tne Client's decisicn in March 2017 to hak the licensing process of AS. ‘ano associated entities as well as press coverage in Mauritius relating to this matter We have identified matenals ir the public domain of concern involving Sobrinho and Pinto, We vngersiand that this information may be known to the Chent as a result of interactions with the Subjects te dale. We have included a bref overview of the main issues in the public domamn Perinent fo their reputations in Section 3.1, Following this section, we have provides a summary Of commentary abiained discreet human source enquines Alvaro de Oliveira Madaleno Sobrinho Pror to AS and associated entities, Sobrinho was the chairman of Bance Espinio Santo’s Angolan bank, Banco Espirito Santo Angola (BESA) from 2002 to 2012. He was also the chairman of the Angolan bank Banco Valor and a director of London-based BESA — Espiito Santo Angola (UK) Limited.‘ in addition Sobrinho is the co-founding chauman of the non-prott Plant Earth Insttule and te African Business Champions for Science Group.” According tc Globaivoces.org. Sobrinho is a shareholder of Panama-vased Pineview Overseas, which owns Newshoid media group. Newsnold media group is @ stakeholder of several mainstream Portuguese news sources including Soi ana Correio da Manha ® % stake in Lisbon-nased football club Sporting Sobrnho's other business interests include 2 ~30 "@ de Portugal's management company Sporting Clube de Portugal Futebol SAD ("SAD") through the holging company Holdimo, making him the club s largest private investor.” Saprinho 1s alse described in tne ICIJ Offshore Leaks Database (specifically tne “Panama Papers") as a Sharenalder of Samoa-based companies White Ceder (Cedar) Lid. and Sherio Management Lid Brewousty nea Ava Sapeicho Mrican Asse Management > Comeany ne 6132720 * ue ee ere coMVPUNN Aaressc:-Avocatn Sno ahuissesie Sip imectoss feuihercrspu ce * ngs oly co enkenseresie/if:22 2019 * ca ahi aout sa? doll g2esident ot anaoi seta 299.00 Prvate and Contiental# Kroll Project Anan ‘ano Seycnollos-based Ant3o Holdings Ltd." Kroll attempted to corroborate this formation with ils primary sources, but was unable to locate public record information that independently venfied the findings. Sobrinne has a high puviic grofle im Portuguese-, French- and English-language news media Gatabases ane internet sources. References primarily concerned career profiles and news articles concerning routine activites wn his current position as €o-founding chairman of the Planet tute * Summaries of adverse or visk-relevant reports about Sebrinho ave included .n Including his involvement in multiple investigations in Portugal relating to alteged money laundering and other ‘nancial misconduct Jose Pinto According 10 news sources, Pinto 1s a duai citizen of Portugal ana Switzerland from Sao Pedro do werland, He 1s a licensed attorney and vs widely identified as 2 Sul, currently tiving in Nyon, S close associate of Sobrinke This apparent close relauanship is reflected in Pinto's prmary Commercial activities Pinto manages several of Sobrinho's offshore entives. including White Cedar Limted. He is a coara member of Alvaro Soorinho Afnca Lie (ASA Group’), ana a director of Swiss asset management company Signet Weaith Management AG."° Pinto has 2 tmited public profile in Portuguese: French: and English-language news mecia alsbases and internet sources, Because Pinto nas a common name, searches were narrowee Using his known affilations References primarily concerned Pinto's involvement in the Monte 3+ below Branco investigation, summarizea in Sect * bus. ottnerensges ey uiynodes so049¢s Owectoremp ang benetcin! omneesip infrmaion for entities domeites 1 Pruate and Contaental&i Kroll Project Arjan 3.tinvestigations and allegations reported in the public domain BESA Investigation Since 2010 tne Portuguese Attorney Generai has been investigating Soorinho s activities as well as his source of wealth and acquisition of luxury assets, linked to his past cherrmanshir of Banco Espints Santo Angola ("BESA‘). As a result of this investigation Sobnaho has been subject to atleast four specific allegations concerning fraud, embezzlement, and money laundering crimes, The most recent proceeding against Sebrinho was opened in 2014 concerning BESA loans allegedly concedes without banking guaranties. which were found in an internal banking audit afler Sobrinno left the companys board Sobrinno was suspected of naving misapproprialed ~EUR 126.5 milion (~GBP 108 milion). of which EUR 88.1 million (~GBP 75 million) was identified as having entered offshore companies controlled by Sobrinho. Due to the above-mentioned allegations, 20 assets Belonging to Sobrinho and his family were SeiZec including property in Liston, Estonl, Porto and Marco de Canaveses. This was the fourth we Fequest for sezure after the first three requests were iilted by the Lisbon Appeal Cou understand that the latest seizure is currently being appealed oy Sobnnho's defense team Similarly, the Swiss news source Swissinifo reported in Apc 2017 that the Swiss Attorney General froze more than CHF 160 milion (~GBP 128 mulisn) connected to Banco Espirito Santo's 2014 cording t0 Media reports. the Swiss Attorney General was investigating Sobricho bankruptey and his family for allegediy benefiting trom the bankruptcy. Sobrinie’s defense attorneys have denied the claims.” Im December 2014, Portuguese news source Nove Jornal reported on Sobnnho's explanations to the investigative commission concerning the collapse of Banco Espiito Santo. Sobrinho denies responsibilty for the banking group's collapse, afisming that ine group always profited from BESA operations, Amid questions regarding the large volume and pattern of credit granted by BESA, Sobrinne reiterated that the bank was compliant with all regulations during his tenure with the ‘bank. Sobrinho further denies cisims that BESA general assembly meeting minutes accounted tor the lack of knowledge of the creat operation recipients, : intra Rs ltatae dg sneteonye- or igs nina secs crvoauess's 03% Aznaolo bance cateai Sc ANGIR AIT * pun unavawinal ce assure aluare-asbe Prete and Confsantiai a4 Kroll Project Arjan In Apri 2015, Attica News Latest reported that the allegations of misconduct against Soorinno were a'smissed. Portuguese authonives decined io bring formal charges against Sob-inno due to lack of evidence. Sobrinho subsequently fied lawsuits against newspaper group imoresa Pubsning S.A, (impresa’) (wmeh had reported on Sobrinhe’s involvement). in several jusdictions seeking damages fegaraing the clams of tinarcia! misconduct."*in February 2018, Pressgazette reported tha: @ ch 18 the owner of the weekly Portuguese newspaper Exp London-based judge denied Sobninho's lawsuit after declaring that the dispute was an abuse of Court process.” Later in February 2016, Africa-Nawsroum reported that Sobrinho is set to Continue his claim for damages against Impresa in London {In August 2015, Portugal Press reported that Sobrinho was under investigation for EUR 4.2 bilian (-GBP 3.59 cillion) that was reportedly missing from the bankrupt BESA. After the bank wer bankrupt. Soorinho want on to invest money in various Portuguese ventures including SAD. the management company of Lisbon-based footbait ciub Sporting Clube de Portugal. The Porluguese Secunties Market Commission (CMS) contunied that Sobrinhe's multiple invesiments in Portugal were under scrutiny ir collaboration with the Bank of Portugal Sobrinho entered SAO through investment company Holdima. which is quoted as owning nearly 30% of the company having invested EUR 20 millon (~GBP 17 mition), Angolan website Rede Angola reported in 2014 that Sourinho hac ‘around 150 bank accounts, spread over six Portuguese banks, CGI) Mittenaum BOP BES Best, Sar IS in Ne Portuguese cites of Cascais and Eaters IS andl Eamon de Rovhschid Europe” and nas several kin'y aba |In February 2017. media scurces reported on the ongoing investigation by the Portuguese Criminal tnvestigation and Penal Action Department (OCIAP) which uncovered a pattern of unsecured loans by BESA to companies linked Io Sobrinno * Related to the BESA case. forme, DCIAP prosecutor Orlando Figueira was previously arrested in 2076 under suspicion of recening bribes up t¢ EUR 1 milion (~GBP 860.000) to archive lawsuits against high ranking Angolan officials” Figuera allegedly ordered the closue of as many as 10 cases including that of ‘Sobrinno, In March 2617 inte Maurice reported that the FSC was informed that Sobrinno was longer investigated by Portuguese authorities for his alleged involvement in coruption saat passe: ccwnpapes ermiansandcng cs " Liposome! alrcan torn alas " hte tuatunai esi somone, ‘AEz ava mssucae At * serra naan. 368 ri en soups tte unease suse 9 RD oad socsecaMtunoN ame Lega dO ek angaaa ete, Na/iwotuaeteren corset isas woseeuie dalaaiesij Kroll Project Arjan allegations. Further research in Portugal can be conducted on request in an attempt to confirm the current status of Sobrinho in relation to past anc present investigation by the Portuguese“! authorties Monto Brance Investigation In 2011, Sobrinho was also sivoived in a Portuguese investigation known as Monte Branco as a shareholde: of Swiss asset management company Akoya, The investigation’s code name seemingly aerived trom Mont Bianc, tne highest peak in the Alps, and focused an Axoya’s alleged money laundering and tax evasion actwities in Switzerland on behalf of seversi Portuguese politicians and businessmen On 2 July 2016, Portuguese news source Sabado reported on 3 confidential notice from the Judiciary Police (PJ) to the DCIAP ana the National Anti-Corruption Unit (UNCC) concerning isle of Man authorities’ detection of an alleged money laundermg operation conducted by Sobrinho. The negotiatian in question concemed the purchase and sale of an airplane. Authonties uncovered tnat in October 2014, Altitude Aviation of which Sobrinne is a beneficiary. purchased an anplane for EUR 25.7 milhon (~GBP 21.98 milion) trom BVI-based White Cedar Limited, which i also owned dy Soprinho. Altiude Aviation then sold the airplane in December 2014 to US-based Jetctaft Corporation for EUR 23.1 milion. Sobrinho became @ suspect for having lost EUR 2 842 milion (~GBP 2.52 milion} in three months, which the article considered @ common practice to legitimize iliet capital gains Sobrinho confirmed with the authorities that he was the owner of White Cedar Limited and of a oat registered in the company's name Through recorded telephone conversations, the Monte Branco investigators heard Akoya managers Michel Canals (“Canals”) and Nicolau Figueiredo inais was allegedly heard saying that the amount chocolate * referring to Sobrinho's money as ilictly moved was EUR 500 million (~GBP 427.65 millon) Ounng the Monte Branco investigation, Canals revealed numerous offshore entities allegedly linked to Sobrinho ang the ructions from Madaleno family as well as indications tat Akoya may have received in Sobrinho's attorney Ana Bruno te receive several millions of euros for Sobrinho and his fasily ‘According to Canals. these exchanges were mode by former money changer Francisco Canas and were meant to evade Portuguese financial authorities, On 24 March 2017 LExprass reported that i= May 2012 Pinto was arrested by the Public Ministry, Portugal's public prosecution service. for his alleged involvement in the Monte Branco Pinto was released after posting a USD 200,000 (-G8P affay for tax evasion and financiat fra yu inns sivas son puso. ne os wm re ere Prvate and Confident! ————————————31 Kroll Project Arjan 161.642) cond two cther Akoya executives went to prison. The article also poms out tat desoite his unin with the Portuguese yustice he was stil granted an Occupational Permit to be 2 board director of ASA in Mauritius, because he was not formally convicted of a crime, The article further added on 23 March 2017 that Portuguese auihonties raided the Lisbon offices of Sobninnos lawyer in connection to the Banco Espiito Santo Angola case, delavied previously in his report Pinto's questioning by Mauritian authorities in March 2017 The Mauritan newspaper Lo Mauncien reported in March 2017 that the Maurtius’ Central Investigation Division (CID) allegedly questioned Pinto regarding CiD's investigation into misleading information furnished by the ASA Group to the FSC for the oblainment of 2 Gioeal Business Licenses and an Investment Banking License, The article noted that, Pinto could pe charged provisionally under the Financial Services Act. According fo the articte, Pinto is central to the misleading information investigation baie ‘The FSC ings reportealy noted that the law fum BCL Robert & Associates and Iqoal Ray were associated with the ASA Group s attempts 10 obtain a permit acting as the groups loal representative However, cn 21 March 20:7 Defi Mowia reported that the law firm ano Rajanoalee distanced themseives from Sobrinno and denied being involved the ASA Groups license flings with the FSC The firm also noted that any allegations contrary to this were false and misled both the public and the authorites According to Le Mauricien, Pinto's nterrogation reveived around a series of emails exchanges between hum and BCL Robert and Aeseciates. the nature of the ASA Group's contract with the law firm, and payments made to the fier sn Fet The results of the interrogation, however were not reported" 3.2 Source commentary on reputation inside and outside Angola Inquiries were conducted with sources inside and cutside Angola to ascartain the inho, and Pinte. Sources includes executives from the financial Oiser generat reputation of AS, So services sector outside of Angola as well as banking executives, legal ang political sources insise Angola. As 1s apparent from the commentary detailed below. the sunjects reputation is generally perceives win concern among financial Services executives ouiside Angola, while at the same oe vou jsncar wise paca 98 OU aM G Private and Confident#) Kroll Project Arjan time, high-level contacts in Angola expressed confidence that there was ite risk to the subjects ability to operate inside the country This commentary is reflective of the level of political support and “protection” enjoyed by Sobran. ‘and Pinto in Angola, due to their political conne that despite the lower risk of -eguiatory or lega! action against them in Angola, the nature of the Subjects’ reputations is sufficient to create percewed risk for counterparties considering 98 inside the country, However, sources noted engagement with them outside of the country Positive reputation, ability to do business and high-level support in Angola Local banking and political sources in Angola reported that Sobrinno is considered a wel ‘Several high-profile connections. including past respected and prominent ingividual n Angola wi and present finance ministers and top bankers Sources sharing this View included @ senior ‘member of the ruling MPLA party (Movimento Popular de Libertagac de Angola). a Luanda-based Senior national security official, an Angolan bank director, and a senior National Bank of Angola (Banco Necional de Angola; BNA) official The sources added that there are “no obstacles” in ‘conducting business with Sobrinho in Angola According to the senior MPLA official, Sobrinho has 2 positive reputation in Angola and the country’s government and banks continue to “have fait inn. The senior BNA executive reported thai the Natonal Bank of Angola “would not have avy problems® in doing business with AS. Sobrinho and Pinto The source claimed that the Angolan state will “assist” those who conduct business with Sobrinho The Angolan vank director who Nas strong connections {o the MPLA, reported thai Sobrinho and anyone connected to him could continue to do business in Angola The Luanda-paged jouralst reported that Sobrinho and any companies affliated with him are “considered central to the Luanda elites While the majority of sources ~ reflective of Angola's political economy — believed that there were ‘no concerns in terms of Sobrinho and Pinto's status and capabilty to do business in Angota 'Solated local sources were also critical of them One Angola based expatriate lawyer desenbed Sobrinho as being “extremely close" to the MPLA and having “essentially worked as the MPL personal banker" at BESA and added that this role would allow him considerable support anc protection in Angola, The lawyer alleges inet uring Sobrinno’s tenute at BESA, he made large (unspecified amoun!) loans without collateral to companies linked to the current Angolan Vice President tanuel Vicente and several ethers that were largely not pas back ‘The above-mentioned Angolan iawyer provided an example from five years ago mn which one of the sourcess clients was allegedly solicited by Sobrinho to pay a EUR 180,000 bribe to secure a Private and Confidential£ Kroll Project Aqan large loan to purchase a property. We have been unable to corroborate this clam, and note that it ' single-sourced The lawyer aise uncerstood f from BESA after “a fating-out” wth former BES group CEO Ricardo Espirito Santo Siva Salgado in 2013. Th “should be avoided. seemingly duo to this sezcciation, m a BES employee that Sobrinno was removes lawyer added that Pinto is “a close confidant" of Sobrinno and adused that he 100 Apparent negative reputation among financial services sources outside of Angola Banking sources, including a senior South Atvican banking executive (who is responsible for Meuntius banaing activities) and the executive of a large pan-Alrican banking group, were aware of the Mauritius Financial Securities Commission matter and its imeact on AS and Sobrinnas activities Mauntivs The executives did not believe the allegations that Sobrishe received special treatment from Mauritian authorities and viewed the authoriies as having acted in compliance with the law The above-mentioned banking seurces stated that their respective Oanks would not do business wih Sobnnho or any businesses alfitated with him. The pan-Afican banking group execi furtrer described Soprinno, Pinto and AS as porsonee non grata” at his bank. The source reported that the allegations in Portugal (see Section 31) are “serious enough to deter any business” wth them. The banking group executive reported that Sobrinho and his associates wil have ‘0 wait until the situation in Portugal 's resolved, specifically the investigation ito Orlando fecewving bribes to clear Angolans from money iaundenng investigations. The source did not believe thal Scbrinho has “enough influence” to change the Figueva who was suspectea o outcome of ine Portuguese investigation Recognition of the subjects’ “protection” inside Angola Refering to the Portuguese investigations specifically, the above-mentioned senor MPLA otfiial refutes the negative meaia surrounding Sobrinho in Portugal and clammed that t was a -vindastve attempt by the Portuguese government to have Sobrinha prosecuted in Portugal and Angota The Source added that “thers 18 9 proof” that Sobrinna has commited any wrongdoing. A sen ‘officisi within the Angolan Attorney-General's Otice repeatedly :ndicated that the Attorney Genera's Otice nas “no interest” in pursuing ary cases against Sobrinho and that alt previous cases nave been closed and will not be reopenea. The senior BNA official and an Angolan bank director believed that there was no cooperaticn Between Angolan and Portuguese authorities ‘elating to Portugal's attempt to “eviminaise” Sobsivho, Notably. the above-mentioned Angolan bank director beloved the charges agains! Sobrinho to Bolentially have some substance. However the source claimea that no evidence agains! Sobrinho would be passed from Angola to Portugal. The bank director explained that they ware Private and Contcsentiat#1 Kroll Project Arjan not worried” about previous dealings between Sobrinno ans thelr bank The source nevertheless conceded that there would be “muct more reluctance" from European banks, The Luanda-based senior official believed that the Angolan government would continue to manage the aftersnocks of BESA with as Intle publicity as possible. The source added thet the government would work hart!” to assist Sobrinno in evading any problems related to the case The source did not expect Sobrinho to be found guilty of the BESA allegations and was contident that there would be ne criminal conviction. The source speculated that fines could be “the worst possible oufcome, Prvate and Contaantat8} Kroll. Project Arian 4. Regulatory 4.1Compliance and Sanctions databases No references {© AS. Sobrinhe or Pinto were foue on sanctions ists / wate and individuals involved in impioper or egal business practices such a¢ money laundering lists of companies terrorism financing. corruption. o: fraua 4.2Requlatoryilitigation No information was found volving AS in searches of the folowing ania regulaloryigovernment and ittgation database resources Angola Angolan Constitutiona! Coun Angolan Audit Court Ango‘an Minssiry of the Interior ‘Angolan Ministry of ‘Angolan Ministry of the Economy Angoian Mmnisiry of Justice NNationat Bank of Angota United Nations Development Programme ~ Angola National Directorate of Commerce Angolan National Private investment Company Angolan institute of Communications Angolan Citizens Porta Angoian Government Portal Ango‘an Corporate Portal Mauritius + Supreme Court of Maurtius26 + Southern African Legat information institute SAFIN) database: # Sotec: wogmerts ony Libgaton emasks In Angoin ave nat co * Seietjuagmeras ony Litgaivancheoxs in Angola are nol eo * coworage negyrs in 2014 Prvate and ContentatCOMMUNIQUE Alvaro Sobrinho and related entities The Financial Services Commission (the Commission’) relers t0 its communique dated 2 March 201 - whereby the Commission inter-alia conveyed the following: (a) That i) AS AFRICAN ASSET MANAGEMENT LD: Hi) ASA Bund: (iii) PASE Fund; and Gv) ALVARO SOBRINHO AFRICA TD (the ‘Companies’) have been requested not to start operations without the prior clearance of the Chiet Executive, (b) The Commission has been closely monitoring the matter The Commission reviewed the status of the ongoing, the Companies and has decided to lift the restriction subject to the condition that the Companies shall aot raise funds from Mausitius for their operations \quiry into the allegations ayainst The above is without prejudice to the Commission's right to initiat any actions arising from any averse findings Financial Services Commission, Mauritius FSC House, 54 Cyberrity, Ebene 72201, Republic of Maurits et (230) 403 7000 Fax 4230) A67 7172 E-mati: fremauritius@intnet.my, Website: wavw Fyerauritius org