VEB Fund and money laundering
1. In the last years of the Soviet Union, foreign currency transfers were carried out centrally by the Foreign Bank of the Soviet Union (Vnešekonombank, from now on VEB Bank) throughout the former USSR. In Estonia, the Tallinn department of VEB Bank used to carry out most foreign currency settlements. On 22 October, with decree No. 116, it was decided to liquidate the Tallinn Department of VEB Bank from 01.01.1991. With decree No. 30 on 29 November, a Government of Foreign Operations was established as a member of the Bank of Estonia starting from 01.12.1990. The new Government of Foreign Operations took over servicing the customers of VEB Bank Tallinn department.
For continuity, the Tallinn Department of VEB Bank and the Government of Foreign Operations worked together for one month. On 10 January 1991, the Bank of Estonia and VEB Bank signed a contract introducing correspondent relationships. With the decree No 2172/1 of the Supreme Council of the Russian Federation on 13.01.1992, the correspondent accounts of the Foreign Operations Government of the Bank of Estonia (it was reorganized into a Ldt. North-Estonian joint-stock bank, from now on PEAP) and the Baltic Ühispank (from now on UBB) were “frozen” for an indefinite period. On 20 January 1993, in connection with the sanctions imposed on Estonian banks by the Russian Federation and the resulting situation in PEAP and UBB, the Riigikogu adopted a resolution on the accounts of Estonian banks “frozen“ in the Foreign Bank of the USSR. The Riigikogu established the National VEB Fund, which would collect the PEAP and UBB claims for frozen accounts in VEB bank.
2. The situation described above resulted in the Tallinn Circuit Court verdict on October 22, 2010, according to which the complaints of PEAP and UBB clients were satisfied, and compensation for claims compensated by the State VEB Fund certificates was determined.
3. In the verdict of the administrative case no. 3-04-469 p. 17 of the Tallinn Circuit Court on 22 October 2010, the court noted that “Although the issue of certificates and the relationship between banks and its clients is a matter of private law, the state intervened with these relationships using public law measures primarily in the public interest. … in a situation where the state exercised its authority in the manner described above, it is also responsible for seeking new ways of protecting the proprietary rights of the certificate holders in the event of fund failure. ‘
4.“By interfering in private law using public-law measures, the state takes responsibility for the proportionality and effectiveness of the measures above. The state will not be relieved of liability solely because it has created the National VEB Fund, which is known to be ineffective in filing claims against this fund. There is also an unjustified objection that the applicants had obtained certificates freely. The state has all the necessary means and powers to look for new alternative solutions to the situation that has arisen. ”(The verdict of the administrative case no. 3-04-469 p. 19 of the Tallinn Circuit Court on 22.10.2010)
5. The customers (creditors) of PEAP and UBB had contractual relations only with PEAP and UBB. The relationship with VEB Bank was limited to PEAP and UBB. According to the National Audit Office report of 11 June 2014, two banks (PEAP and UBB) had accounts with VEB Bank according to correspondent account agreements. The 890.5 million kroons frozen on the PEAP and UBB accounts belonged to those banks in full. The NAO found that there was no basis for allocating frozen money to the banks and depositors in VEB bank due to the nature of correspondent banking. According to the explanations of the National Audit Office, the bank does not have to account for the customer’s assets; the customer’s deposited money is the bank’s assets used by the bank to earn an income. PEAP and UBB had to meet their obligations to their clients (creditors).
6. After the PEAP and UBB accounts (assets) had been frozen in VEB bank, it became clear that PEAP and UBB could not fulfill their obligations to the creditors.
7. There were several ways to solve the situation. The Republic of Estonia (Riigikogu) did not consider it possible to bankrupt PEAP and UBB and face the consequences.
8. Based on the facts listed above, the Republic of Estonia decided to save both the PEAP and UBB from bankruptcy, with all the legal consequences.
9. According to the decision of the Riigikogu on 20 January 1993, “Accounts of Estonian Banks Frozen in the Foreign Economic Bank of the USSR”, the VEB Fund certificates were to be used to compensate for the claims of PEAP and UBB clients related to the accounts frozen in the former VEB bank, as well as the claims of the banks themselves against the VEB fund that exceed the amount of the customer claims.
10. With the creation of the VEB Fund, the issue of how the Republic of Estonia would fulfill its obligations to the certificate holders was postponed indefinitely. At the same time, when dealing with the crisis, groups of depositors were treated differently and unequally. The unequal treatment of creditors is indicated, among other things, by the fact that, over time, the quantity of the register of the VEB Fund decreases significantly, mainly through meeting the claim of TSL International (from now on, TSL), which accounts for nearly half of the quantity of the VEB Fund and is essentially equal to the funds of the other people in the VEB Fund.
11. The claim of TSL International to 32.3 million USD was received from VEB Bank with the help of the Bank of Estonia and the Bank of North Estonia, who made the payment possible for TSL with respective payment orders and confirmations. By only meeting the claims of the Government of the Republic, the Bank of Estonia, and narrow circle companies, the Bank of Estonia treated the creditors unequally, which was contrary to the obligation of the VEB Fund and the Bank of Estonia to contribute to the protection of the interests of all creditors. (The Committee of Inquiry of Riigikogu. For finding out the circumstances of processing and satisfying the claims of the VEB Fund, Final Report, p. 50)
12. After establishing the VEB Fund, a situation arose when the Republic of Estonia had to fulfill its obligations and simultaneously decide how it should be done. In this situation, there were errors and delays in fulfilling the obligations described above, among other things, and attempts to neglect their obligations. This statement is vividly confirmed by a standpoint stated by the Minister of Finance, Jürgen Ligi, on 15.02.2012, “According to the resolution of the court decision, the state has no obligation to pay a specific compensation for the claims secured by VEB Fund certificates, but there is only a
question of compensation for claims to be decided. ”(Verbatim Report of the 12th Riigikogu, 3rd Session, Wednesday, January 11, 2012).
13.By now, the VEB Fund’s activities have been terminated, and it has been liquidated without the owners of the VEB Fund certificates being compensated for the assets they have been deprived of, which they have contributed to saving the Republic of Estonia’s economy.
14. Data indicating money laundering in the management of the VEB Fund has been received in connection with the investigation of its activities and later with the leakage of the so-called “Panama papers.” Unfortunately, however, this issue has not been adequately studied so far.
15. It may be related to the fact that “the representatives of the Financial Intelligence Unit of the Police and Border Guard Board reported that they had no data on TSL transactions. The Money Laundering Prevention Act came into force on 1 July 1999, but the transactions of
TSL noted that the Bank of Estonia audit took place in 1997-1998.” (Riigikogu Research
Committee. To determine the circumstances of processing and satisfying the claims of the VEB Fund, Final Report, p. 8)
16. Meanwhile, the fact that essential requirements for preventing money laundering were already established in the Credit Institutions Act 1995 (from now on, ECA 95) has been neglected.
17. According to § 54 of KAS95, money laundering is considered to be the placement of money acquired through criminal activity in legal business or investment. A credit institution is required to avoid using the banking system for money laundering.
18. Since the Bank of Estonia, as well as UBB, PEAP, PEP, Eesti Ühispank (The United Bank of Estonia), and other banks operating in the European Union economic area were involved in the activities of the VEB Fund, they had to rely on the requirements of prevention of the use of money laundering, including the corresponding requirements of the European Union. This is because the explanatory memorandum to the draft of KAS95 indicates that, among others, the EC Money Laundering Directive (91/308 / EEC) has been a guiding principle for developing KAS95.
19. In our opinion, VEB’s money laundering refers to at least the following circumstances.
20. With the Decree No 2172/1 of the Supreme Council of the Russian Federation on
On 13.01.1992, the correspondent accounts of the Government of the Foreign Operations of the Bank of Estonia and the Baltic Bank were frozen for an indefinite period in VEB Bank. Based on the abovementioned regulation, no one could use the funds from the respective correspondent accounts in VEB Bank.
21. On 7 December 1992, with the President of Russia’s permission, VEB Bank was authorized to make payments to civilians and legal entities that were residents of Russia.
22. On 5 April 1995, a letter with counterfeit data with the signature of Vahur Kraft was sent from the Bank of Estonia to VEB bank, according to which, as of 1 January 1995, VEB Bank was holding the assets of a Russian resident, more specifically a Russian-Singapore joint venture, TSL, with a total amount of 32.3 million USD.
23. It has currently become clear that the information in the letter dated 05.04.1995 concerning the TSL claims was falsified (Riigikogu Research Committee. The VEB Fund for the investigation and settlement of claims dismissed, Final Report, p. 35). Among other things, there is no other evidence that TSL had ever had funds of the size of US $ 32.3 million before buying VEB Fund certificates.
24. According to § 166 (1) of the Criminal Code in force in 1995 (CrK95), the forgery of a document, if it caused significant damage to the rights or interests of a person, company, agency or organization, or the interests of the state, is punishable by a fine together with depriving a person of a particular position or a specific occupation, or imprisonment for a maximum of three years, together with depriving a person of a particular position or of the right to pursue an occupation.
25.According to § 186 of the Criminal Code 95, a person is punished with up to two years’ imprisonment for falsifying a document certifying nationality, other official documents, or a seal and for knowingly using a falsified official document or a seal to acquire rights or avoid obligations, fines, or arrest.
26. Thus, the Bank of Estonia has created and used the letter of 5 April 1995, or documentary evidence mentioned above, which served as the basis for receiving USD 32.3 million by unlawful means by TSL, as a result of the use of professional counterfeiting and falsified documents. The fact that without the commission of the crime described in §§ 166 and 188 of KrK95, i.e., without Vahur Kraft’s signature on 05.04.1995, it would not have been possible for TSL to receive USD 32.3 million from VEB Bank, is confirmed by the point that only after the relevant letter receipt by VEB Bank in July 1996, the Ministry of Finance of the Russian Federation agreed to issue bonds corresponding to the amount and only to TSL. The bonds issued by the Russian Federation to TSL, however, are freely tradable securities.
27.Based on the facts mentioned above, it can be seen that the Bank of Estonia’s activities regarding money laundering, i.e., the acquisition of money (nonTSL funds by VEB bank) acquired through criminal ways (professional counterfeiting and falsified documents), were put into legal business activities or investments (state securities/ bonds of the Russian Federation), already in 1995.
28. Additionally, we would like to draw attention to the activities related to TSL’s acquisition of USD 32.3 million and the subsequent use of the funds mentioned.
29. Although TSL has obtained certificates for a total of USD 32.3 million, with certificates purchased far below the market price, after the letter on 05.04.1995 and the approval of the Russian Federation in July 1996, the entire counterfeit scheme was launched by the letter from the Bank of Estonia on 05.04.1995, which contained counterfeit data.
30. This is evidenced by the fact that TSL has become the owner of certificates as follows:
a. On 28 April 1997, TSL obtained certificates for USD1,914,817.42, which received bonds for USD1,827,675;
b. On 8 December 1997, TSL received certificates for USD10,000,000, with the same amount of bonds;
c. On 28 May 1998, TSL obtained certificates for USD20,500,000 and received bonds for the same amount.
31. Thus, TSL acquired all the certificates only two (2) years after the letter was sent by the Bank of Estonia and nine (9) months after the consent of the Ministry of Finance of the Russian Federation. This means that money laundering schemes were initially tested with only USD 1.9 million in funds to determine whether the false information in the letter allowed the Russian Federation to agree to receive funds from the VEB Fund. When the scheme worked successfully, the second phase of the money laundering scheme and the third phase of its implementation were carried out in the Republic of Estonia.
32. In addition, we note that at least USD 914,817.42 of the claim received by TSL on April 28, 1997, was obtained as a result of the embezzlement, which corresponded to the composition of the secret theft (§ 139 of the Criminal Code).
33. As of 01.01.1992, the state of the TSL UBB account was zero (0). On 3 April 1992, TSL’s UBB Frozen Account received USD 3.5 million of the North West River Shipping money. This amount was erroneously entered into the TSL account by VEB Bank. The North
Sea Shipping did not want to transfer the money to TSL’s account. Northwest Sea Shipping demanded the money back, but by then, TSL had already taken over the money. It means that on 10 April 1992, TSL transferred the unduly received USD 3.5 million to Belka Trading Corp., registered in a low-tax area. TSL also transferred EUR 914 817.42 to the United Russian Finance (URF), which it subsequently recovered on 28 April 1997. There were no problems with the repurchase as both companies belonged to the same person, i.e., TSL and URF belonged to Alexander Matt.
34. According to § 139 (1) of the Criminal Code 95, the secret theft of foreign property is punishable by a fine, detention, or up to three years’ imprisonment.
35. Due to the facts mentioned above, on 5 April 1995, TSL received bonds worth of USD 827 675 from VEB Bank, which were obtained with the help of a counterfeit letter from the Bank of Estonia through money laundering (criminal theft, including embezzlement) (non-TSL funds in VEB bank) by investing in legal business or investing (government securities or bonds of the Russian Federation).
36. Similarly, TSL’s acquisition of certificates worth USD 10,000,000 on 8 December 1997 already infringed the money laundering legislation of KAS95 and KrK95. However, this fact only recently emerged as a link to the so-called leak of “Panama Papers.”37.The acquisition of the certificates received by TSL on 8 December 1997 (USD 10,000,000) was preceded by a transaction based on which the duplicate certificates were sold for USD 10 million on 29 October 1997 by Eesti Ühispank (The United Bank of Estonia) to Universal Financial Services Consultancy Ltd (UFSC). Later, UFSC handed the duplicate certificates over to TSL.
38. To meet the requirements of preventing money laundering, among other things, under § 55 (1) and (2) of the KAS95, a credit institution was prohibited from entering into contractual relations and conducting transactions with anonymous and shadow persons. A credit institution was obliged to identify all persons who executed settlement transactions of more than 15,000 ECU or cash transactions over 7,500 ECU at the rate of the Bank of Estonia.39. The purpose of those requirements was, among other things, that the transaction should not be carried out with shadow persons, including non-existent companies.
40. The Panama Papers database also contains the name of the UFSC registered in the British Virgin Islands. The database shows that the UFSC was registered on 2 February 1995 and deleted from the register on 31 October 1996.
41.Thus, on 29 October 1997, Eesti Ühispank (The United Bank of Estonia) entered into a business transaction with a non-existent company to sell the VEB Fund certificates.
This, in turn, means that Eesti Ühispank (The United Bank of Estonia), on 29 October 1997, sold certificates worth USD 10 million in violation of KAS95 requirements of money laundering, which lay in not identifying the person who the transaction was made to.
42. According to § 97 of the KAS95, disobeying the anti-money laundering rules by a credit institution manager or other employee is punishable by disciplinary procedures in accordance with the Employees Disciplinary Act or with or without the deprivation of the right to work or exercise a particular occupation.
43. According to § 1488 of the CrC95, non-compliance with the anti-money laundering rules provided by the Credit Institutions Act by the head or employee of a credit institution can be punished by a fine with or without the deprivation of the right to work on a particular position or of the right to engage in a specific activity.
44. Based on the facts mentioned above, the TSL received bonds worth USD 10 million from VEB Bank on 5 April 1995 as a result of a violation of the anti-money laundering rules, which was punishable as a separate offense.
45.“VEB Bank did not recognize the Fund as the owner of frozen accounts, but the Bank of
Northern Estonia. Therefore, in April 1993, the Fund entered into a contract with the Bank of Northern Estonia, according to which the Bank of Northern Estonia was obliged to represent the Fund in its name and account with VEB Bank and other persons. In the agreement, the Bank of Northern Estonia serviced the fund’s accounts and kept a register of creditors using its technical means, staff, and payment document forms. The Bank of Northern Estonia held all the archives and documents of the creditors of the Fund. /… / In 1997, the Bank of Northern Estonia was merged with AS Eesti Ühispank (from now on Eesti Ühispank). This led to the transfer of the funds to the legal successor of the Bank of Northern Estonia, Ühispank, and then to AS SEB Bank. (Riigikogu Research Committee. To find out the circumstances of processing and satisfying the claims of the VEB Fund, Final Report, p. 20). 45. Since Eesti Ühispank was the legal successor of PEP and was also responsible for the administration of the VEB Fund, it had to take into account, among other things, the interests of protecting the holders of the VEB Fund certificates when conducting the transaction with the VEB Fund certificates. This means that the certificates had to be traded at a price close to the market value of the certificates.
46. In a situation where TSL wanted to acquire certificates for the third time, for the amount of USD 20.5 million, a prudent and credible credit institution had to realize that if a person wanted to acquire certificates for another 20.5 million after acquiring certificates for USD 10 million USD, which represented 1/3 of the total assets of the VEB Fund. However, in the amount of USD 1/3 of the total assets of the VEB Fund, TSL succeeded in getting money from VEB Bank based on the certificates received. However, this means that at least the value of the corresponding certificates for TSL was close to USD 20.5 million. Therefore, based on the principle of reasonableness, it must be assumed that a reasonable entrepreneur is prepared to pay more than 10% of the corresponding amount to acquire USD 20.5 million. In the situation that had arisen, it could be asserted with great certainty that an impartially, diligently, and lawfully acting certificate vendor would have entered into a transaction on significantly different terms (at a higher price) than it had been done.
47. According to § 1482 of the Criminal Code, a fine or an arrest is assigned for deliberate reduction of one’s solvency or making one insolvent by destroying or violating one’s property, giving unjustified donation or assignment, or placing it abroad or taking unreasonable obligations, as well as favoring one creditor to another debtor who is aware that due to current or anticipated economic difficulties, his actions may damage the creditor’s interests.
48. We consider that when the transaction was carried out significantly below the market price, ie, VEB Fund’s 28.05.1998 certificates worth USD 20.5 million were sold to TSL for
USD 2 428 841.79, the VEB Fund’s solvency was significantly reduced (at least ¼ of the volume of VEB Fund assets), which seriously undermined the interests of creditors.
49.Due to the facts noted above, TSL received bonds worth USD 20.5 million from VEB Bank with the help of the letter on 05.04.1995 by money laundering, i.e., by means of a substantial reduction in the solvency of the VEB Fund into legal business or investments (State Securities or Bonds of the Russian Federation).
50. Please note that everything mentioned above was made possible by the involvement of a certain group of people in the above-mentioned activities.
51. Aleksander Matt, the company’s owner and a board member, was associated with TSL and URF.
52. Riho Remmel was associated with UBB, PEP, UFSC, and OÜ Markent, who was UBB at the time of freezing the accounts at VEB Bank and UFSC and a representative of OÜ Markenti when conducting transactions with the requirements of the Management Board of VEB and later with the requirements of the VEB Fund.
53. It should also be noted that TSL transferred USD 2.5 million to Belka Trading from the USD 3.5 million illegally obtained from Northwest River Shipping.
54. Belka Trading fell into media attention in 1999 when the US Federal Tax Administration began investigating Alexei Dashenko, accusing him of tax evasion. This happened after an investigation initiated by the US Congress revealed that a Russian businessman had money in two accounts in the branch bank of the Bank of New York on the Cayman Islands, of which he had not paid taxes. During the investigation, it turned out that Belka Trading transferred money to Alexei Dychenko, among others. The Russian investigation also revealed that, in essence, money was being laundered from Russia, among other things, through Belka Trading and the branch of the Bank of New York on the Cayman Islands.
55. Belka Trading Corp. was registered at 515 Madison Avenue, New York.
56. Based on the evidence available to the National Audit Office, TSL received USD 11.8 million in bonds from the Russian Federation, the remaining amount, i.e. USD 20.5 million, could have been obtained in cash or bonds. In addition, since the right to dispose of the VEB Fund’s claims (account) was only with the Bank of Estonia and the former North Estonian Share Bank, it is not realistic that the transfer, incl. claims of USD 20.5 million, could be realized without the knowledge of the managers of the Bank of Estonia. The account statement of VEB Bank shows that by 1998, TSL received claims for USD 32 327 675 (1 827 675 + 10 000 000 + 20 500 000), i.e., in the same amount as the letter of 5 April 1995 from the Bank of Estonia. No information is available to the committee of inquiry about the further movement of the money. The investigation commission did not receive any data from the Russian Court of Auditors on the reimbursement of frozen funds on correspondent accounts of Estonian banks. The representatives of the Financial Intelligence Unit of the Police and Border Guard Board reported that they had no data on TSL transactions, and it was unlikely that the data would be received from Russia. Moreover, the committee had no information on whether the realization of claims by VL in the VEB bank was by the Russian legislation because the National Audit Office of Russia did not receive any data on compensation of frozen money on correspondent accounts of Estonian banks. We note that, as customary, the movement of legal money can be traced back to the endpoint retrospectively. In general, it is impossible to track the movement of money after it has reached an account registered in the Offshore region.
57. Due to the facts above and considering the association of TSL and its owner Alexander Matt with Belka Trading and other companies registered in the Offshore region (UFSC, etc.) as well as the fact that the future fate of the bonds received for the VEB Fund certificates is unknown
(further cash flow has not been possible to date), it cannot be excluded that it has returned to
Estonia via offshore companies.
58. It has been argued that on 5 April 1995, with the help of the fake letter and TSL, the USD 32.3 million received from the VEB Fund has at least partially returned to Estonia. At the same time, traces of this money have been sought from the East (from Russia). In reality, however, the VEB Fund’s money-laundering traces lead to money-laundering cases by the Bank of New York. This means that the assets of the VEB Fund may also be part of the money laundering cases of the Bank of New York, more precisely, its branch office in Cayman.
59. The transactions in the VEB fund give reason to suspect that the money from the fund was channeled through TSL International and Belka Trading to the Bank of New York accounts, where it was “washed clean” before returning to Estonia.
60. In the late summer of 1999, a gigantic financial scandal erupted in New York – the prestigious Bank of New York (BNY) allegedly helped wash out billions of dollars of outflow from Russia. The New York Times wrote on its front page that an international investigation in a large-scale money laundering sphere had been launched against one of the oldest and most solid banks in New York. “From October (98) to March (99), an account with USD 4.2 billion was opened in the bank, and over a thousand transactions were made through this account,” wrote the Times. According to the newspaper, up to $ 10 billion could have been wasted, and at least part of that money could have been for the Russian criminal world. After the investigation, BNY sent two Russian-origin workers forced to leave, Natalia Gurfinkel Kagalovsky and Lucy Edwards, who had looked for clients from Eastern Europe. A few years later, this affair, the most significant financial scandal of the decade, was virtually forgotten. In the international media, it has been pointed out that US troops killed this issue because too many distracting facts could have swung into the light, and the threads would have led to high political circles.
61. Let us mention that, according to former Governor of the Russian Central Bank Viktor Geraššenko, most of the Russian dollar transactions through the Bank of New York were made since 1993. As USD is the currency of the US Federal Reserve, all foreign residents should have a USD correspondent account with a US bank. This was also the case with the St Petersburg department of VEB Bank in the Bank of New York, where USD 20.5 million was transferred from VEB PEP’s frozen account. At least in the payment order, the Bank of New York was indicated as the intermediary bank.62. As dollars are the property of the US state, as has already been mentioned, all dollar transactions worldwide go through correspondent accounts of US banks. Thus, such transactions become subject to US jurisdiction. Since many of the circumstances related to the VEB Fund have only become evident, among other things, through the leakage of the Panama Papers”, money laundering by the VEB Fund may also be subject to US jurisdiction. The fact that the US institution could solve the problem of VEB Bank and could go under US jurisdiction has been notified to Eesti Pank as early as 19 August 1996 in the written proposal of the Estonian Innovation Bank. For unknown reasons, the Bank of Estonia has neglected such a proposal. Based on currently available data, we could see that it was ignored, as it was contrary to the embezzlement scheme of 5 April 1995. This means that, on 05.04.1995, the purpose of the fraud was, with the help of the letter, to take USD 32.3 million from the VEB Fund and wash it clean in US offshore banks and then let the VEB Fund go down to hide any money laundering. If a similar investigation had already been conducted in the US in 1996, the whole scheme on April 5, 1995, would have failed since all the activities of the VEB Fund would have received too much attention from too many people.63. The doubts connected with money laundering related to the VEB Fund mentioned above are also supported by events that have taken place in Estonia in recent years. Namely, on the grounds of refusal to disclose the sound recordings of the VEB Foundation’s inquiry committee, the Chancellery of the Riigikogu refers to the Money Laundering and Terrorist Financing Prevention Act. According to the Financial Intelligence Unit’s request for information: “Partial access restrictions apply to recordings according to § 35 (1) 19) of the AVTS, § 43 (1) of the Money Laundering and Terrorist Financing Prevention Act and § 43 (2) and 45 (1) of the Bar Association Act.”
64. According to § 43 (1) of the Money Laundering and Terrorist Financing Prevention Act, access to information in the Financial Intelligence Unit database and the right to process it is restricted to an official of the Financial Intelligence Unit.
65. If the sound recordings of the investigation committee of the VEB Fund have no connection with money laundering, then it is incomprehensible why such information is stored in the FIU database and is classified under the Money Laundering Prevention Act.66.Based on the facts above, it could be assumed that the withdrawal of USD 32.3 million from the VEB Fund by the Bank of Estonia on April 5, 1995, may be closely related to other countries, including Estonia and Russia, with the USA and US banks and the much larger money-laundering incidents there.
