The key challenge was to determine whether the declared owner independently controlled the Holding or acted within a broader group of related parties.

Anahata Solutions needed to examine the relationships behind the formal corporate structure, identify potential third-party economic interests and establish whether those interests were connected to sanctioned individuals.

This required moving beyond registry ownership and analysing the wider network of management roles, corporate relationships, assets, commercial activity and transactions involving the declared owner and related entities.

—  Establish whether the declared 100% owner independently controlled the Holding.

—  Identify the actual ultimate beneficial owner behind the buyer.

—  Examine direct and indirect corporate, management and commercial relationships involving the declared owner.

—  Identify potential links with individuals subject to international sanctions.

—  Assess the regulatory, sanctions and compliance risks associated with the transaction.

Anahata Solutions conducted a corporate investigation to verify the independence of the declared UBO and identify the broader network of related parties behind the Holding.

Cross-analysis of corporate relationships, management roles, assets and infrastructure identified several consistent indicators that the declared owner was connected to a wider group of commercial interests.

The declared owner simultaneously held management positions within investment group X, fintech company X1 and other companies associated with the group. Several of these companies operated from the same address, while their teams partially overlapped.

In March 2026, the Holding acquired an interest in a commercial project, replacing two oil-trading companies that had been under the direct control of the beneficiary of group X. The declared owner participated in the management of entities on both sides of the transaction.

The investigation also identified links between group X, the related oil-trading companies and a government representative who served on the boards of the relevant entities, held a senior diplomatic position and simultaneously sat on the board of a major sovereign holding company, X2.

— Analysed the formal ownership structure of the buyer and the Bank’s key subsidiaries.

— Verified the declared UBO’s corporate and management roles.

— Cross-analysed corporate relationships, management, assets and shared infrastructure.

— Identified links between the declared owner, investment group X, fintech company X1 and other related companies.

— Analysed the Holding’s March 2026 investment in a commercial project and the replacement of two oil-trading companies controlled by the beneficiary of group X.

— Examined management relationships involving entities on both sides of the transaction.

— Identified links involving group X, related oil-trading companies and a government representative connected with the relevant corporate structures.

— Assessed the wider network of commercial interests behind the formally declared ownership structure.

Data Research focused on testing whether the declared owner of the Holding exercised independent control or operated within a broader group of related commercial interests.

The investigation identified consistent management, corporate and commercial relationships between the declared owner and the beneficiary of investment group X. These included overlapping management roles, shared corporate infrastructure, movement of assets between related structures and joint projects involving UAE state financing.

Taken together, these findings indicated that the declared owner did not operate as an independent investor but managed businesses in the interests of other UBOs. His management roles, asset movements and connections with group X indicated participation in a common group of commercial interests that also included the beneficiary of group X and the related government representative.