Ben Keith & Rhys Davies in Forbes, published on 30 March 2023.

Lawyers acting for a Ukrainian citizen have called on the U.S. government to open an investigation into a senior member of the Abu Dhabi ruling family over claims that he may have assisted Russians in evading U.S. sanctions.

The request has been made to the Department of State and the Department of the Treasury and the latter’s Office of Foreign Assets Control (OFAC) and concerns Sheikh Mansour bin Zayed Al-Nahyan, deputy prime minister of the United Arab Emirates (UAE).

Sheikh Mansour is a prominent figure in the UAE and beyond. He is a brother to UAE president Sheikh Mohammed bin Zayed Al-Nahyan and is married to a daughter of Dubai’s ruler Sheikh Mohammed bin Rashid Al-Maktoum. He is also the figurehead for Abu Dhabi’s ownership of Manchester City football club and was recently appointed as chairman of the Mubadala Investment Company, a $285 billion sovereign wealth fund.

The request for the U.S. to investigate him has been made by British barristers Rhys Davies and Ben Keith on behalf of a Ukrainian human rights activist, whose name has been withheld due to safety concerns.

“There can be little doubt that the UAE is now the destination of choice for sanctioned Russians from around the world to hide their assets,” said Davies. “It is clear that a number of ultra-high net worth and high-profile Russian oligarchs who have been sanctioned by the United States (and other jurisdictions) transferred highly visible assets to the UAE after being sanctioned. We are asking the US government to investigate the matter urgently.”

According to a spokesperson acting for the lawyers, their request “sets out widely documented evidence indicating the apparent facilitation by Sheikh Mansour specifically – and the UAE in general – of the transfer of assets by Russian oligarchs to the UAE.”

Official concern

It follows signs that officials in Washington D.C. are concerned about the UAE’s record in dealing with Russia in the wake of its invasion of Ukraine in February 2022.

Earlier this year, the Treasury Department’s undersecretary for terrorism and financial intelligence Brian Nelson visited the UAE and held talks with a wide range of officials. According to the official readout of the trip, Nelson “shared Treasury’s focus on rooting out evasion of U.S. sanctions, particularly on Russia and Iran, and its commitment to take additional actions against those evading or facilitating the evasion of sanctions”.

Since then, other U.S. officials have visited the Gulf country, including James O’Brien, who heads up the Office of Sanctions Coordination at the State Department.

The request made to the State Department and Treasury Department points to the “significant wealth controlled by Russian oligarchs sympathetic to President [Vladmir] Putin … transferred to the UAE immediately following the invasion of Ukraine in February 2022.” It also includes the names of some of the oligarchs who have transferred assets to the UAE since being targeted by international sanctions, including steelmaking billionaire and member of the Russian parliament (Duma) Andrei Skoch.

The two British lawyers say that, if Sheikh Mansour is found to be helping individuals to evade sanctions, he could also be targeted by the U.S. sanctions program.

The lawyers made a similar request to the UK government in October 2022, in regard to Sheikh Mansour’s alleged involvement in helping Russians bypass British sanctions. To date, the UK authorities have not responded publicly to the request.

This article first appeared in Forbes and can be read in full, here.

Ben Keith is a leading barrister specialising in cross-border and international cases. He deals with all aspects of Extradition, Human Rights, Mutual Legal Assistance, Interpol, Financial crime and International Law including sanctions. He represents governments, political and military leaders, High Net Worth individuals, human rights defenders and business leaders in the most sensitive cases.

He has extensive experience of appellate proceedings before the Administrative and Divisional Courts, Civil and Criminal Divisions of the Court of Appeal as well as applications and appeals to the European Court of Human Rights (ECHR) and United Nations. Ben is recognised in Chambers and Partners and The Legal 500.