The Klyuev Group, which U.S. Senator John McCain in 2012 urged President Obama to use an executive order to sanction wholesale as a “dangerous transnational criminal organization,”concocted its first nine-figure refund scheme in 2006, according to Magnitsky and others. The conspirators allegedly included the heads of Moscow Tax Offices 28 and 25, Olga Stepanova and Elena Khimina, respectively; Klyuev’s own attorney, Andrey Pavlov; and an Interior Ministry official, Major Pavel Karpov, who had previously investigated Klyuev for attempting to steal $1.6 billion worth of shares of a profitable Russian iron ore company. (Klyuev received a two-year suspended sentence in that case.)

Together, the Klyuev Group allegedly stole $107 million from public coffers—and therefore from the Russian people—using dummied-up registrations for companies that formerly belonged to a Renaissance subsidiary, Rengaz Holdings Limited. The Group then allegedly used these companies to file bogus refund claims in Kazan and Moscow. All the money was duly refunded thanks the accomplices in the Moscow tax offices, according to the investigative website Russian Untouchables, then wired to accounts at the Universal Savings Bank, an institution which Klyuev owned and operated. Then Klyuev, Stepanova and Stepanova’s husband Vladlen Stepanov all went on holiday together to Dubai, as plane records obtained and published by Russian Untouchables demonstrate. From there, Klyuev and the Stepanovs traveled to Switzerland, where the husband-and-wife team reportedly kept deposits at Credit Suisse in the names of their offshore shell companies. They all returned to Moscow on the same flight. Karpov, Pavlov and Pavlov’s wife, Yulia Mayorova, meanwhile, took a five-day trip to London. Mayorova’s visa application with the U.K. border agency attested to their joint travel plans.