Lamesa Investments Limited (LIL) is a company registered under the laws of the Republic of Cyprus. LIL is wholly owned by Lamesa Group Incorporated, a company registered under the laws of the British Virgin Islands, which is in turn wholly owned by a U.S. ‘Specially Designated National’ (SDN).
Cynergy Bank Limited (CBL) is a retail bank registered under the laws of England and Wales. The only connection CBL has with the United States is its U.S. dollar business and the maintenance of a U.S. dollar correspondent account with a U.S. bank.
LIL and CBL entered into a facility agreement in 2017 (FA) whereby, among other things, LIL loaned £30 million to CBL and CBL was contractually obliged to make interest payments twice each year during the term of the FA. The FA was governed by English law and subject to the exclusive jurisdiction of the English courts.