Protect Human Rights and Investigate Possible Sanctions Evasion

An appeal by Ilgar Hajiyev concerning the SDI case and its political context

7 November 2026

I, Ilgar Hajiyev, address the authorities of the European Union, Switzerland, the United States, the United Kingdom, Canada, Japan, Australia, New Zealand and Ukraine.

The central concerns of my appeal are human rights violations and possible sanctions evasion through front men. I demand an independent investigation into the allegations of threats and coercion in the conflict surrounding SDI, its political context and the actual control of assets within the business network of God Nisanov, Zarakh Iliev and Ilgam Ragimov.

Property, personal safety and access to independent judicial protection must be considered together. Prominence and connections must not stand in the way of an investigation. But an allegation does not become proven merely because it has been made publicly: each person's responsibility and the grounds for sanctions must be established individually.

Human rights and the events surrounding SDI

A Radio Liberty report dated 5 May 2019 published videos supplied by SDI and employees' accounts of being denied access to the office. I alleged threats and a seizure of my business. Kievskaya Ploshchad's press office expressly denied Nisanov's involvement. The report confirms that these allegations were made publicly, but does not establish any particular person's guilt.

On 7 May 2019, The Bell reported that it had obtained a copy of a police order concerning the search on 24 April. It presented my statements about fears for my own life and my loved ones as my own account. I demand an examination of the grounds for the police actions and how they were carried out, the requests for protection, possible coercion and each participant's role, rather than an inquiry confined to the allocation of ownership interests.

My assessment of my experience in Russia is stark: in conflicts of this kind, the courts and the law do not provide independent protection for the individual. This is my position, based on my experience. I do not present it as a judicial finding about the entire system, nor do I conceal decisions that went against me. Their substance is set out below.

Allegations of rights violations require a separate legal assessment. The EU's Global Human Rights Sanctions Regime provides for measures against serious violations and may cover non-state actors. A corporate dispute does not, in itself, mean that these criteria are met. I demand an investigation into threats, coercion and the possible use of state authorities against an individual, rather than automatically treating every commercial conflict as grounds for human rights sanctions.

The political context and my court case in Azerbaijan

I consider my case political. I link the subsequent persecution in Azerbaijan to my criticism of Ilham Aliyev and his government, and demand an examination of the connection between the business conflict, the legal proceedings against me and my public position. This is my assessment of the motives, not an already established causal link.

The chronology must not be made to fit that conclusion. On 20 May 2019, Haqqin published my appeal to Aliyev, in which I asked for protection and spoke positively of his policies. The beginning of the conflict in Russia therefore cannot automatically be described as a response to my later criticism. The specific stages, the change in my public position and the subsequent actions against me must be examined.

My allegation is that Nisanov acted on Aliyev's behalf: the demand he made to me in connection with the VernadSKY project concerned the interests of Aliyev's son. In June 2021, EconoTimes had already reported my account concerning a share in the property on Vernadsky Prospekt for the benefit of Heydar Aliyev. This is a publication of my account, not independent documentary confirmation of a transfer of ownership or an instruction from the president. I insist on an investigation based on documents. Nisanov's representatives denied his involvement in the SDI conflict; official meetings and awards do not, in themselves, substantiate my version of events.

The Azerbaijani case has a specific procedural history. On 12 January 2026, Yeni Çağ reported that the indictment had been read out in a closed trial and identified the criminal case number as 191900199. That number is cited from a media report, not a certified copy of a court document.

According to reports by APA and Meydan TV, on 2 March 2026 the Baku Court of Grave Crimes sentenced me in absentia to 15 years' imprisonment. APA describes charges of fraud and laundering property obtained through crime. APA's Azerbaijani-language report also reports the confiscation of previously seized property in favour of the state. These are reports about the judgment and its consequences, not my assessment of the lawfulness of the proceedings.

Vladislav Yusupov's role must not be described through conjecture. On 12 January 2024, Agentstvo reported that the case in Azerbaijan had originated from his complaint. The outlet also reported Interpol's refusal to circulate an international wanted notice, citing correspondence in its possession. These reports are no substitute for primary documents and do not mean that the Azerbaijani judgment has been overturned.

The evidence available for this article does not include the full text of the judgment, Yusupov's complaint or a verified, up-to-date account of the status of any appeal. I therefore do not present the proceedings as having undergone final review at every judicial level. I demand an independent assessment of access to a defence, the trial in absentia and behind closed doors, the grounds for confiscation and a possible political motive. A judgment delivered in absentia does not automatically prove a violation of rights; nor is my criticism of the authorities a substitute for evidence of a causal link.

Meydan TV, on 18 March 2025, included me in its reporting on prosecutors' demands that government critics living abroad return for investigative proceedings. Lawyer Samad Rahimli described the developments as pressure on people in exile. This published context is important for examining my account, but it is not a judicial finding of political motivation in my case.

Front men and possible sanctions evasion

My position on SDI is known: I consider Albert Imanilov a front man in this affair. I demand that this allegation be tested against corporate documents, payments and the instructions actually given. A formal ownership interest, kinship or a business partnership does not, in itself, prove that someone is a nominee. Below, the facts recorded in documents are distinguished from my allegation that he represented another person's interests.

Two questions must be distinguished: whether an asset is subject to a freeze because a sanctioned person actually controls it, and whether specific acts were committed to circumvent restrictions. European Commission guidance addresses these questions separately. The existence of an intermediary company is no substitute for evidence of control and of the circumstances of a particular transaction.

Chronology is essential. The transfer of ownership interests in SDI in 2016 preceded the sanctions against Nisanov considered here, which were introduced from 2022 onwards. That transfer cannot, in itself, be described as proven evasion of subsequent restrictions. Yet a transfer made years earlier does not settle the question of present control. SECO explains that, where a sanctioned person retains control, the date of a formal change of ownership does not, in itself, preclude an asset freeze.

I demand that, for each jurisdiction, it be established which prohibitions applied, from what date, who made the decisions and who received the benefit. Switzerland requires a separate basis in Swiss law: foreign sanctions do not apply there automatically. These questions cannot be answered by a list of acquaintances or by asserting that every registration of ownership in another person's name is already a crime.

Who makes decisions and who is registered as the owner

In an interview with RBC on 10 July 2019, Nisanov himself described the group's structure: he, Zarakh Iliev and Ilgam Ragimov handle strategic management; relatives act as the companies' founders and also participate in operational management.

This is an important public explanation. Checking sanctions risks requires more than finding a surname in a single registry extract. It is necessary to establish who gives binding instructions, finances transactions, receives income, bears risks and has the power to dispose of an asset.

A family business is lawful in itself. But a family structure does not remove the need to examine actual control. At the same time, the Kievskaya Ploshchad group and the individual limited liability company of the same name are not identical: a conclusion about one company cannot automatically be applied to the entire business.

Ilgam Ragimov and the importance of chronology

The account of Ragimov's involvement cannot end with the report that he withdrew from several companies in 2018. RBC reported in August 2025, citing SPARK, that the stakes had returned to him in 2019 and remained with him as of publication. This information relates to a particular point in time and is not a substitute for a current registry extract.

Ragimov has spoken publicly about his long-standing acquaintance with Vladimir Putin. In 2012, Forbes described their time as fellow students. In the same article, Dmitry Peskov confirmed that they knew each other as students, but said he was unaware of regular contact. A representative of Nisanov and Iliev denied that the connection was used for business, explaining Ragimov's involvement in terms of investment and legal work.

An acquaintance does not establish a corrupt arrangement. Specific decisions, transactions and benefits should be investigated where evidence warrants it. Any claim that someone holds property belonging to Putin himself requires separate evidence, which the materials presented do not provide.

SDI and Albert Imanilov

In an article published on 7 May 2019, The Bell reported that it had verified through SPARK the transfer to Albert Imanilov in August 2016 of half the ownership interests in several SDI companies. My explanation was that he represented Nisanov's interests. It is precisely this second part that remains my allegation, rather than an independent finding of the registry.

Imanilov's connections with other projects merit comparison. Kommersant reported on 24 May 2019 that Imanilov and Roman Agababaev had appeared among the owners of Bereg, a company associated with the Ilyichevo estate. The newspaper also linked them to other acquisitions in the market; the suggestion that they acted in the interests of Kievskaya Ploshchad's owners came from one of its sources.

There is also a later document. The Pirogovskaya Riviera project declaration dated 22 September 2025 discloses Salomon Rashbilovich Zakharyayev as the owner of 70% of the developer KomfortInvest through Marvel Fing, and Albert Shamailovich Imanilov as the direct owner of 30%. This is a specific corporate connection. It does not yet answer the question of who actually controls all the funds and ownership interests.

The court outcomes must also be stated plainly. In 2021, the court granted Imanilov's claim to expel me and Stil LLC as members of KomfortInvest and rejected the counterclaim to expel Imanilov. The appellate and cassation courts upheld the outcome; the Supreme Court declined to refer the appeal for a hearing and did not examine the merits of the dispute. This history is reflected in the court materials in case A40-330636/2019.

In another dispute, a cassation ruling of 3 April 2023 reinstated KomfortInvest's claim for RUB 583.8 million in the third priority category of Akkord Spetsstroy's creditors. It would be wrong to use an overturned intermediate outcome instead of that ruling.

I do not conceal these decisions. They must be taken into account when assessing the conflict. But a dispute over expelling a company member and the priority of a claim does not replace a separate examination of who actually controlled the companies, gave instructions and received the economic benefit.

The Zakharyayev family and specific business roles

A family publication by STMEGI lists six brothers: Solomon, Telman, Maxim, Eduard, German and Isay. Corporate documents contain different spellings of the surname, and Solomon is listed as Salomon Rashbilovich Zakharyayev.

Individual roles matter to this analysis. Salomon is disclosed in the KomfortInvest ownership chain. Isay is publicly identified as a shareholder of Sezar Group. German and Maxim have public roles in STMEGI. Corporate records have been found concerning Telman and Eduard, but they do not prove that these individuals were involved in every disputed SDI episode.

The actions of one participant cannot be attributed to an entire family circle. Nor can all Sezar companies be declared Nisanov's property without documents establishing control.

Particular care is needed regarding claims of kinship between the Zakharyayevs and Nisanov. Media reports have described the relationship differently. In an interview on 25 July 2019, Isay expressly denied being related. He also rejected the allegation of a business seizure, confirmed his former partnership with me on Pirogovskaya Riviera and made allegations of his own. These statements represent the other side's position, which readers must be able to see.

A clear example of the need to check dates is that Mondi confirmed the sale of its Syktyvkar operation to Sezar Invest for RUB 80 billion in October 2023. Yet AK&M reported in March 2025, citing financial reporting, that Isay held 25% of the buyer at the end of 2024, rather than the earlier 70%. An old ownership structure must not be presented as the current one.

Vladislav and Oleg Yusupov are different people

In its 2019 interview, RBC described Vladislav Yusupov as Nisanov's cousin; Nisanov himself credited him with the idea for Depo. In 2021, Kommersant quoted Vladislav as a representative of the group when the Depo Three Stations project was announced.

There is a separate historical international ownership chain: ICIJ's database of Appleby records identifies Vladislav Yusupov as the ultimate beneficial owner of Kutus Limited. A published historical Isle of Man aircraft register lists that company as the owner of Airbus A318 M-HHHH, manufacturer's serial number 4650. This provides grounds to examine the history of ownership and financing, but does not establish the present owner or that the structure was unlawful.

A different person, Oleg Yusupov, appeared in the restaurant business connection involving Alexander Kolokoltsev, the minister's son. Vedomosti described their interests in Il Forno LLC in 2016. Nisanov's representative acknowledged that Oleg was a distant relative but denied that they had a joint business. These ownership interests are historical; they do not establish that the minister himself participated in the company or prove corruption.

Public political contacts

Official sources confirm Nisanov's presence at the Azerbaijani president's meeting with a delegation in September 2016, as well as his receipt of an award in 2016 and the Dostlug Order in 2022. Ragimov received the Shohrat Order in January 2021.

Nisanov's public contacts with the Russian leadership are also documented: his receipt of the Order of Friendship in 2014 and his participation in the opening of Moskvarium in 2015 were described by JTA and Kommersant.

In Proekt's 2020 investigation, journalists described observed visits by Sergei Naryshkin and other connections. The article also published responses: the Foreign Intelligence Service declined to discuss the family's private life, Veronika Naryshkina denied working at Depo, and a representative of the Rotenbergs denied close friendship and involvement in Food City.

An official meeting, an award, business involvement and an allegation that a service was provided to an official carry different evidentiary weight. I demand an examination of specific transactions and conflicts of interest. A photograph together must not substitute for that work.

International assets and sanctions decisions

In-Spi's investigation into Château de Mirambeau adds a European line of inquiry: buyers, corporate chains, loans and the source of funds. The materials presented do not establish that the château is Nisanov's personal property or that it was financed with unlawful proceeds.

Even a confirmed absence of revenue or a small share capital is no substitute for analysing payments. The questions must be specific: who provided the money, on what terms, who receives income and who has the power to dispose of the asset.

Sanctions decisions concerning Nisanov have been verified for the United States, United Kingdom, Canada, Japan, Australia, New Zealand, as has Ukraine's 2022 act imposing measures for ten years. For Zarakh Iliev, the US OFAC entry, UK list and Ukrainian decision of 2022 have been verified. For Ragimov, decisions have been verified in Canada and Australia.

The review did not confirm an individual sanctions entry for Vladislav Yusupov. Nisanov's sanctions status cannot be extended to every relative and partner without a separate basis. Nor can an incomplete search justify declaring that no restrictions exist anywhere in the world.

My appeal to human rights and sanctions authorities

To the European Union and Switzerland. I demand urgent consideration of individual measures against Nisanov and others for whom the grounds required by law are established. I ask for a separate assessment of the human rights dimension of my case: reports of threats and coercion, protection of property and access to independent justice. The Council of the EU and the Swiss Federal Council must assess the materials within their respective powers; the European Parliament should demand a reasoned response and exercise political scrutiny.

To the United States, the United Kingdom, Canada, Japan, Australia, New Zealand and Ukraine. I demand a review of the enforcement of existing sanctions, including assets, income, fiduciary asset management arrangements, intermediaries and transactions involving sanctioned persons. I ask for an examination of actual control and possible acts of circumvention, rather than an inquiry that stops at the registered owner's name. The applicability of human rights mechanisms should be assessed separately against their own criteria.

To the competent authorities of France, Luxembourg, Spain and Switzerland. I call on you to establish the sources of financing for European companies and assets, the people who actually control their use and disposal, and those who receive the benefits. Where grounds exist, the legally prescribed checks on the origin of funds, sanctions compliance and the prevention of money laundering should follow.

Regarding my cases in Russia and Azerbaijan. I demand a comparison of the court decisions and their final status, the parties' statements, corporate documents, payments and the chronology of my public criticism of the authorities. My allegation of a political motive and my account of the demands surrounding VernadSKY must be investigated, rather than suppressed. The assessment must focus on specific evidence and the roles of specific individuals, including Vladislav Yusupov's actual, rather than presumed, role.

Regarding Imanilov and other possible nominee owners. The agreements transferring ownership interests, sources of funds, powers of authority, correspondence, income and subsequent transactions must be examined. If another person's control persisted, its legal consequences must be assessed. If acts of sanctions circumvention are uncovered, they require a separate assessment. A relative, partner or foundation head does not become a violator merely through proximity to a sanctioned person.

I demand a public position to the extent permitted by law, an independent investigation and consistent action by the competent authorities. Insufficient grounds should be explained. Established violations must carry legal consequences, regardless of wealth or political connections.

Protecting human rights and enforcing sanctions must involve concrete work: examining documents and testimony, and holding people accountable for proven acts.

Ilgar Hajiyev