CL-2022-000456 - [2025] EWHC 1938 (Comm)

The position in Cyprus arose because AIM Capital, Linea and Linetrust PTC are all incorporated in Cyprus. The NCA in Cyprus is the Advisory Committee on Economic Sanctions (“SEOK”). It froze the assets of AIM Capital.

AIM Capital appears to have challenged this. On 8 February 2023, the SEOK wrote to AIM Capital’s Cypriot lawyers, rejecting their application. The SEOK stated that Linetrust PTC, Linea and AIM Capital were “owned, possessed and/or controlled” by Mr and Mrs Melnichenko, but that those companies were all “considered as entities under a special sanctions regime, provided that no financial resources/capital shall be made available directly or indirectly to” Mr or Mrs Melnichenko.

On 20 July 2023, the SEOK noted that the Swiss NCA had taken a similar approach to the functioning of EuroChem AG, as had the DGT in relation to EuroChem Agro France.

In short, the SEOK regards the EuroChem group companies as owned and controlled by Mr and Mrs Melnichenko, but accepts the EuroChem AG firewall measures as satisfactory, in relation to the Cypriot entities.