…Canoccord sure was in the thick of it. 🧐
>>In particular, Canaccord’s CDD records for Customer B do not reflect reporting alleging that Individual 2 aided certain
oligarchs in hiding their assets, including Konstantin Malofeyev. In December 2014, OFAC designated Malofeyev as a
Specially Designated National (SDN). In sanctioning Malofeyev, OFAC described him as “one of the main sources of
financing for Russians promoting separatism in Crimea” and, through its designation, prohibited U.S. citizens from
working for or doing business with Malofeyev. OFAC, Press Release, Treasury Targets Additional Ukrainian Separatists
and Russian Individuals and Entities (Dec. 19, 2014). On April 20, 2022, Malofeyev was sanctioned again for acting, or
purporting to act, on behalf of, directly or indirectly, the Government of Russia. OFAC, Press Release, U.S. Treasury
Designates Facilitators of Russian Sanctions Evasion (Apr. 20, 2022).
Additionally, publicly available information pre-dating this 2023 reporting linked Individual 2’s business to Russian
oligarchs; as early as 2012, Individual 2 was linked to an oligarch’s Cypriot trust. References to this information remained
absent from Canaccord’s CDD files in the roughly five-year period between account opening and the third quarter of
Market Data 
Markets 
