We’re all used to lists and databases. There are sanctions screening systems and PEP screening systems. Within their organisations, MLROs have access to client databases. And, to a greater or lesser extent, jurisdictions are getting on board with beneficial ownership and setting up searchable registers. What all of these have in common is names: you put in the name of a client and see what comes back. If nothing comes back and you’re smart, you try a slightly different spelling, or put the name in a different order (you’ve heard before about my friend Simon Anthony and how he’s regularly recorded as Mr Simon). But it seems that some sneaky individuals are simply sidestepping the whole “being on a list” thang by changing their names.
Now that I’ve heard of it, it seems the most natural reaction in the world. But I had assumed that there would be some way of tracking through from the original name to the new one, that would make the change more of a personal preference than a successful attempt to disappear from view. And then on 20 January 2021 we read that Raimbek Matraimov, former deputy chief of Kyrgyzstan’s Customs Service, had changed his surname after being placed on the US Magnitsky sanctions list for his alleged involvement in the illegal funnelling of hundreds of millions of dollars abroad. How could this work, you might ask? After all, when someone’s name changes through marriage or divorce – or wanting to be a squiggle rather than a Prince – their financial institutions will insist on seeing proof of the official change from one to the other. But Damira Azimbaeva of the state registration service of Kyrgyzstan confirmed that both Matraimov and his wife Uulkan Turgunova had changed their surnames – and that she would not be sharing their new surnames because of data confidentiality. Thankfully, the couple have also been embroiled in a libel lawsuit, and to clarify things the judge in that case helpfully announced that Matraimov had changed his last name to Ismailov, and his wife had changed her surname to Sulaimanova. (So the names you’re after are Raimbek Ismailov and Uulkan Sulaimanova. For now at least.) Another judge, Klara Sooronkulova, told the media she believed that Matraimov and his wife had changed their names specifically to avoid sanctions: “I think after being placed under the Magnitsky Act, many doors around the world will be closed for them. Many problems may now arise for them to keep their property under their ownership.” I jolly well hope so.
So that’s yet another question for the MLRO to ask clients (along with “is this your only nationality?”): “Have you ever changed your name, and what was it before?”. When I was a girl I dreamed of being Mrs Victoria Osmond – Victoria because it was my favourite name, and Osmond because of the warbling toothsome one and “Puppy Love”. So if things ever get too hot for me in the world of AML, you know who I’ll be next.