In 2025, journalists uncovered a scheme by which a Russian company transferred €11 million to Cyprus using a Kazakh shell company and Bank RBK. Furthermore, it was discovered that Bank RBK has a litany of fines for numerous violations of banking laws.

Just think about it: in 2024 alone, 364 administrative violation cases were pending against Bank RBK! That’s essentially one violation per day.

For example, during an audit by the Agency of the Republic of Kazakhstan for Regulation and Development of the Financial Market, it was established that on December 11, 2023, a financing agreement was signed between Bank RBK and the borrower, AQNIET Capital LLC, for investment purposes with a subsequent increase in the credit line  by $395.2 million . However, the average headcount ranged from two to five people at different times, and the company owns no assets. The founder of the LLC is Kairat ITEMGENOV, who, according to Forbes , ranked 35th in the list of the 50 most influential businessmen in Kazakhstan  in October 2025  .

The investigation also revealed that Bank RBK  conducted transactions  totaling 16.24 billion tenge, or over $31.2 million, for two clients—SYNTECH FZE and VNSV TRUSTEE PTE. LTD—resulting in the transfer of funds to cross-border countries.

As stated in the court ruling, the audit revealed that Bank RBK had failed to send notifications to the Agency of the Republic of Kazakhstan for Regulation and Development of the Financial Market regarding client transactions: "These facts indicate the bank’s violation of the requirements for sending information under codes 7006, 1046, and 1058, as per the Rules. Based on the analysis of the bank’s procedures for recognizing a bank as suspicious, in violation of Parts 3 and 5 of the Law, Bank RBK did not reflect the suspicious codes specified by the Rules.

Furthermore, since the above-mentioned transactions using the specified codes were not tracked in Bank RBK’s information system, it should be noted that the bank did not conduct timely monitoring, indicating an increased risk of Bank RBK’s involvement in money laundering and terrorist financing. (Spelling and punctuation preserved hereinafter.)

But all the above transactions pale in comparison to the operations of another client of Bank RBK - EBF Investment LLP, which transferred a contribution to pay for closed-end units in the amount of 262.6 billion tenge, or almost 615 million US dollars, to Skybridge Invest JSC: “The authorized body, based on the results of the inspection carried out in accordance with the act of appointing an inspection dated February 5, 2024, No. 01-4-01/1, revealed that the bank did not send FM-1 messages to the Agency of the Republic of Kazakhstan for Financial Monitoring on two client transactions for which it was necessary to send FM-1 to the AFM, namely, on the operations of the client of EBF Investment LLP - Skybridge Invest JSC, a contribution to pay for closed-end units in the amount of 319,427,780 US dollars (136,443,576,227 tenge) and a contribution to pay for closed-end units in the amount of 295 572,220 US dollars (126,191,603,606 tenge).

Incidentally, for this violation, Bank RBK was brought to administrative responsibility under Parts 2 and 8 of Article 214 of the Code of Administrative Offenses with the imposition of an administrative penalty in the form of a fine of 182,574 tenge.

What kind of client of Bank RBK is EBF Investment LLC?

According to  adata.kz , EBF Investment LLC was registered on May 16, 2018, but was initially known as EBS Investment LLC. The company was deregistered on October 9, 2024. That is, approximately a year after 262.6 billion tenge, or almost $615 million, was withdrawn from the accounts.

The last listed founder of EBF Investment LLC was BEST CAPITAL INVESTMENT LLC, from July 19 to October 9, 2024. Before that, the company, whose main activity is stated as "other financial services, financing in various sectors of the economy, investment activities (OKED: 64992)," was founded at various times by private funds: Elbasy Fund, Nursultan Nazarbayev Foundation, and the Foundation of the First President of the Republic of Kazakhstan – Elbasy.

JSC Skybridge Invest, where 262.6 billion tenge, or almost 615 million US dollars, were transferred from the accounts of EBF Investment LLP in Bank RBK, has a primary activity - brokerage activities in transactions with securities and commodities, with the exception of activities related to the management of assets of the National Fund, gold and foreign exchange assets of the National Bank, and pension assets (OKED: 66122).

The shareholder that owns 100% of Skybridge Invest JSC is SB SOLUTIONS LLC, which in turn has six co-founders: Azamat BERLIN, Damira BIISENBAYEVA, Almaz IRISHEV, Inara ZHAKHANOVA, Bauyrzhan Isengaliev, and Temirlan OMARZHANOV. According to the 2024 audit report, Almaz Irishev holds the largest stake – 30%; the others hold between 6% and 18%. Each of these co-founders holds stakes in other companies, the details of which would take a very long time to cover. However, the most important thing is that they were entrusted with the management of 262.6 billion tenge, or almost $615 million, from a company owned by the Elbasy Foundation. Well, the sole founder of the "Elbasy Fund", like the "Nursultan Nazarbayev Foundation", as you may have guessed, is the first president of Kazakhstan – Nursultan Nazarbayev.

So it’s safe to say that Bank RBK was fined 182,574 tenge for simply transferring 262.6 billion tenge from the accounts of a company once owned by the first president of Kazakhstan.