SEC charges U.S. investment adviser for sanctioned Russian billionaire Roman Abramovich

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A secretive U.S-based financial manager who handled over $7 billion in investments for sanctioned Russian billionaire Roman Abramovich, has been charged by the Securities and Exchange Commission with failing to properly register with the regulatory agency.

Russian emigré Michael Matlin and his Concord Management LLC, which operated out of a nondescript office in Tarrytown, N.Y., allegedly placed billions of dollars in investments for a Russian national who was a former Russian official between 2012 and 2022, when the billionaire was sanctioned by the European Union and the United Kingdom, the SEC said.

The SEC complaint doesn’t directly name Abramovich but describes the person in question as a “wealthy former Russian official widely regarded as having political connections to the Russian Federation,” who had $7 billion in assets frozen in April 2022 by the Royal Court of Jersey. 

Abramovich had $7 billion in assets frozen by that court at that time, shortly after being sanctioned following Russia’s invasion of Ukraine. Abramovich is considered one of Russia’s wealthiest men and has close ties to the Kremlin. Soon after Abramovich’s assets were frozen, the U.K. government forced the sale of his interest in the Chelsea Football Club, one of his highest-profile assets.

From the archives (June 2022): U.S. investor purchase of Chelsea Football Club from Putin associate Abramovich puzzles Wall Street

In March 2022, the New York Times reported that Concord had operated as a money manager for Abramovich and other wealthy Russians. The SEC complaint stated that Concord had only one client and had raked in more than $80 million in fees for managing $7.2 billion of his investments in various hedge funds and private-equity funds in the U.S. and elsewhere.

Concord and Matlin stopped operating when the client’s funds were frozen, the SEC said.

“We allege that Concord flouted the registration requirements of the federal securities laws for over a decade, earning more than $80 million for providing investment advice to its billionaire client during that time,” said Gurbir Grewal, the SEC’s head of enforcement. “By failing to register as an investment adviser, Concord not only undermined the commission’s ability to exercise effective regulatory oversight over billions its client invested in the United States, but also skirted rules crucial to the commission’s ability to monitor the market for abuse.”

Messages left with attorneys for Concord Management and for Abramovich weren’t immediately returned.

The complaint said Concord’s Russian client funneled the money through Matlin’s firm via a nest of entities registered in the British Virgin Islands and later through the British offshore territory of Jersey. In February 2022, the SEC said the Russian client transferred control of the assets to his five children.

Concord has a staff of roughly 10 investment managers handling the client’s money, the SEC complaint said. The SEC said Matlin took pains to hide the identity of his client from his own staffers and discouraged any speculation as to who he might be. 

Many of the investments that Concord made were intentionally set up to obscure whose money it actually was, the SEC complaint said.

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