A company linked to a major Trump donor received authorization from the Treasury Department to complete an acquisition involving a sanctioned Russian bank, according to public records.
The Texas-based Dynamic Frontier Holdings purchased Teghut, one of Armenia’s largest copper mines, this summer. Dynamic Frontier’s manager is Konstantin Sokolov, a Russian-American businessman who was one of three dozen private donors to President Donald Trump’s $350 million White House ballroom project.
Photo: Donald Trump (impersonator) at the White House, Washington DC. Credit: Darren Halstead / Unsplash Source:Unsplash
Russia’s state-owned VTB Bank was Teghut’s primary shareholder and creditor prior to the purchase. The U.S. Treasury Department sanctioned VTB Bank following Russia’s invasion of Ukraine, describing it as a “critical artery” of the country’s financial system.
The sanctions prohibit U.S. companies and individuals from transacting with VTB Bank. But on Sept. 3, Dynamic Frontier said in a press statement that it had “received authorization from the U.S. Department of the Treasury” on June 1 to acquire all of Teghut’s shares and outstanding debt.
The Treasury Department’s Office of Foreign Assets Control, known as OFAC, can grant a license to individuals or companies to complete transactions that would otherwise be prohibited by sanctions. OFAC states on its website that it may grant a license to do business with sanctioned Russian entities when it is in the interest of the applicant and the U.S. government.
A spokesperson for Sokolov confirmed to ICIJ that OFAC granted a license to Dynamic Frontier to complete the acquisition of Teghut’s shares and debt. The spokesperson also said there was “no evidential basis” to draw any link between Sokolov’s donations and the approval of the license, and that any suggestion otherwise “would be incorrect and wholly misplaced.”
The Treasury Department did not answer questions about the license.
Armenia’s competition commission formally approved Dynamic Frontier’s acquisition of the mine on July 7. However, VTB’s deputy chairman said in an interview with Russian news agency Interfax that the bank sold its interests in Teghut to a “group of international investors” in June. The proceeds from the sale, the deputy chairman said, was 4 billion rubles, or roughly $46.5 million.
As far back as April, VTB’s chairman said that his bank was in “the final stages” of selling Teghut and Armenia’s Radio Azatutyun identified Sokolov as the mine’s likely buyer. In July, the buyer was reported to be a company founded by Sergei Virabyan, a former Armenian government official and banking executive. Virabyan refused to answer when asked whether Sokolov was the true owner of the mine, describing the information as a “commercial secret.”
In a statement, the spokesperson for Sokolov said Dynamic Frontier’s acquisition of Teghut “represents a long-term commitment to one of Armenia’s most strategically important mineral assets,” and that the company’s goal is to revitalize the mine and significantly increase its production. The transaction, the spokesperson said, “will help secure Armenia’s position and sovereignty in the critical minerals space.”
Sokolov was born in the Russian city of St. Petersburg in 1975 and immigrated to the United States at 21 years old, according to his personal website. In the late 2000s, he helped launch an investment fund that backed Russian real estate and hospitality projects.
Sokolov gave $2,300 to support Barack Obama’s presidential campaign in 2008, according to public records. But in more recent years, he has made large donations to Republican political causes. He donated $11 million in 2025 to MAGA Inc., a major pro-Trump super PAC, as well as making over a dozen other donations to other Republican campaigns and political groups. He also donated an undisclosed sum toward the new White House ballroom.
Sokolov was also appointed chairman this summer of a new $200 million State Department enterprise fund to oversee investments in the south Caucasus and central Asia. Armenia is expected to be a primary beneficiary of the fund.
In addition to Teghut, Sokolov has extensive business interests in Armenia’s banking and telecommunications sectors. In Armenia, some politicians have criticized the lack of transparency in his companies’ ownership structures and how he will manage his overlapping public and private roles.
Mesrop Manukyan, a member of Armenia’s National Assembly, told ICIJ that Sokolov’s position “create[s] legitimate questions about…the separation between private commercial interest and decisions involving public or government-backed funds.”
Between April 2019 and May 2021, FTI Consulting provided expert economic consulting services to VTB through a Singaporean law firm intermediary. Invoices went unpaid for 90, 99, and even 198 days, which OFAC classified as prohibited “new debt” . OFAC’s message was clear: you cannot do indirectly what you cannot do directly .
FTI agreed to pay $1.05 million to settle the case.
Now, the Punchline
On the very same day — June 1, 2026 — OFAC publicised the FTI penalty. And on that same date, Dynamic Frontier Holdings stated it had received authorization from the U.S. Department of the Treasury to acquire 100% of Teghout CJSC’s shares and its outstanding debt .
One American company was fined for indirectly dealing with VTB. On the same day, another American company says it received Treasury authorization to acquire a VTB-linked asset worth hundreds of millions of dollars. The first decision is public. The second is not.
We searched the Treasury and OFAC records for June 1. What we found was the $1.05 million FTI Consulting settlement. What we did not find in the public OFAC records was the Treasury authorization that Dynamic Frontier says it received that day.
The authorization may exist as a private license, which OFAC does not publish. But until it appears, the contrast is striking.
Bottom line: One company was penalized for indirect VTB dealings; another says it was authorized to acquire a VTB-linked asset. On the same day. Make it make sense.
YEREVAN, Armenia–(BUSINESS WIRE)–Dynamic Frontier Holdings LLC, a U.S.-registered company, has received the necessary regulatory approvals to proceed with the acquisition of 100% of the shares of Teghout CJSC, operator of the Teghout copper-molybdenum mine in Armenia.
The transaction will be completed through Cuprar RA LLC, a subsidiary of Dynamic Frontier Holdings.
The Competition and Consumer Protection Commission of the Republic of Armenia also approved the acquisition by Cuprar RA LLC on July 8th, 2026.
Following completion of the transaction, Dynamic Frontier Holdings will become the ultimate parent company of Teghout CJSC through Cuprar RA LLC.
The transaction represents an important step in the continued development of the Teghout mining operation and provides a new ownership framework for one of Armenia’s largest copper-molybdenum assets.
About Teghout CJSC
Teghout CJSC operates the Teghout copper-molybdenum mine in Armenia’s Lori Province. The Teghout deposit is one of the country’s largest copper-molybdenum deposits.
Update: After this article was written, Dynamic Frontier Holdings, a shareholder of KUPRAR RA, announced that it had received U.S. Treasury (OFAC) authorization on June 1, 2026, to acquire Teghut CJSC shares and outstanding debt. This was the key regulatory approval for the transaction. Source:Dynamic Frontier Holdings (USA) received approval to acquire Teghout Mining
Media reported that Konstantin Sokolov, a U. S. investor and head of TRIPP+, was the architect and public face of the Teghut copper mine transaction from sanctioned VTB control to “friendly” Western control. [Paragraph deleted at the request of Sokolov’s legal representatives, LOGOS Legal Services.]
In our two previous publications, we reviewed the decision of the Armenian Competition and Consumer Protection Commission dated July 7, 2026, approving KUPRAR RA CJSC’s acquisition of TEGHUT CJSC shares. We found that the publicly available version of the document redacts all substantive information — from the size of the stake to the ownership structure and financial indicators. We also noted that the signatory from the Commission and Sergey Virabyan — the businessman associated with Teghut’s deal — had previously worked together in the Armenian government and Armenian banks on top positions. We further suggested that the share purchase price was likely nominal, given Teghut’s negative equity.
We also analyzed the interview with Dmitry Pyanov, First Deputy Chairman of VTB Bank, and concluded that the debt was sold in June 2026 — before the Commission’s approval — as a separate transaction. However, neither the sale price nor VTB’s actual profit could be determined from the available data.
Araik Tsaturyan Vazgeni was appointed Director of KUPRAR RA CJSC on July 31, 2026. This choice is telling. The individual bears the same full name as Araik Tsaturyan, whose professional background, according to publicly available sources, includes several years at KPMG Armenia and a period at PwC Middle East as a Senior Auditor in Banking and Capital Markets.
Worth Noting #1. KPMG Armenia audited TEGHUT CJSC for at least 2022, 2023, and 2024 — during the period when Araik Tsaturyan was a Manager at KPMG Armenia.
This fits the pattern we have observed in other Sokolov-linked structures, where financial professionals from top-tier audit firms are brought in to prepare assets for international investors.
The Mirror Twin — KUPRAR AR CJSC
These were our boldest hypotheses. But then we found something else entirely by accident while digging through the karg.am database of Armenian companies, and it was later confimed by Armenian company registry.
Worth Noting #2. Two weeks before KUPRAR RA was registered, another company with a strikingly similar name was incorporated:
Field
Details
Full Name
«ԿՈՒՊՐԱՐ ԱՐ» (KUPRAR AR)
Legal Form
Closed Joint-Stock Company (CJSC / ՓԲԸ)
Registration Date
26 January 2026
Status
Active; no records of liquidation
Tax ID
02939895
Registration Number
999.120.1554655
Unique Identifier
56420771
Business Activity Code
64.2 — holding companies
Authorized Capital
10,000 AMD
Registered Address
Yerevan, Kentron, Vazgen Sargsyan 2/2
Email
n.sabanadze@igdevelopment.ge
Director
Nodar Sabanadze (Նոդար Սաբանաձե)
Residence
Georgia
Nodar Sabanadze is a top manager in the business of Mindia Sabanadze. He serves as Deputy Chairman of the Supervisory Board in all key structures of the holding (including IG Development Georgia and City Development). He is a graduate of King’s College London. The construction business is consolidated under the diversified international holding IG International. 100% of the main development company — IG Development Georgia LLC — is owned by the parent offshore structure, IG International LLC, registered in Delaware, USA.
The group operates across commercial real estate, shopping malls, residential and mixed-use development, and energy-related projects. They are among the largest players in Tbilisi’s retail space sector. Key mega-projects include: City Mall network (Tbilisi), Shopping centers in Saburtalo and Gldani districts, CITYZEN: a large-scale premium residential and commercial quarter in a prestigious area of Tbilisi.
In 2025, Sabanadze’s structures joined the management of the legendary Tbilisi exhibition complex Expo Georgia, integrating it into the holding’s development plans. In the energy sector, through affiliated structures (such as historical projects like Pshavi Hydro), the group has been involved in the construction and assessment of small hydropower plants in Georgia’s regions.
We have no information about Sabanadze’s structures having any business in Armenia.
Someone in June 2026 had to transfer a payment of $100+ million to VTB Armenia under a deed of assignment. This required financial institutions willing to take on the risk of such settlements.
Bank of Georgia is the largest commercial bank in Georgia, whose shareholders include major global investment funds and asset managers, including Fidelity Investments, Van Eck Associates, Harding Loevner, Schroders, and Vanguard Group. Its parent holding company (Lion Finance Group PLC) has a premium listing on the London Stock Exchange (LSE) and is included in the FTSE 250 index.
The route of the VTB debt settlement remains unclear. Bank of Georgia, which acquired Ameriabank in 2025, could be one avenue to examine, but no public evidence confirms either bank’s involvement or the payment route.
Sergey Virabyan is a former Armenian government official (Director of the Rural Economic Development Program Implementation Office / PIU under the Government of the Republic of Armenia) and a banking executive — Worth Noting #3: his career includes membership in the Directorate / Board of Ameriabank, formerly Armeconombank, as well as Ardshinbank and IDBANK. This combination of government and banking experience could have made him a potentially useful intermediary for a transaction of this kind.
Why would Sabanadze help? For a substantial commission.
Someone had to finance this operation — preferably through a structure that, while empty, would be familiar and credible to a Georgian bank as a borrower/counterparty. Sabanadze’s structures are clearly reliable clients of Georgia’s largest bank and have access to credit lines.
They assist in the transaction by creating an Armenian company — ostensibly for local development projects — receiving funding from Ameriabank, concluding the assignment agreement, and making the payment to VTB Armenia in local currency. In turn, repayment for services could plausibly have flowed through the U.S. side via the Trans-Caspian Enterprise Fund (Delaware) and Dynamic Frontier Limited (Texas).
It is Worth Noting #4 that both KUPRAR AR and the Trans-Caspian Enterprise Fund (Tripp+ Enterprise Fund) were registered on the very same date: January 26, 2026. Whether by design or coincidence, this parallel adds another layer to our hypothesis.
This would be an elegant and strategic arrangement.
How the Transaction Might Have Been Structured (A Thought Experiment)
Let’s be clear: we have no evidence that the following sequence actually happened. The steps below outline a hypothetical transaction structure, not a claim about what the parties actually did.
The sequence is illustrated in Illustration 1 and Illustration 2 (see below), with the key steps numbered 1 through 6.
We would incorporate two separate local SPVs: SPV A (non-public) for purchasing the debt from the restricted structure, and SPV B for acquiring the asset’s shares and handling any government approvals. Both companies would be structured so that their shareholder information remains outside the public register.
For SPV A, we would appoint a director from a non-local jurisdiction — ideally one closely associated with independent structures that have significant credit leverage and could be funded by a major international bank or fund. The funding would be non-targeted, documented as a working capital loan, and denominated in local currency.
After the debt is purchased and the asset is secured, SPV A would assign its rights to the debt to its parent company. At this point, the holding company would become both the owner of the asset and the holder of the debt claim — unifying control in a single entity.
To settle SPV A’s obligations to the local bank, the holding company would use funds provided by an affiliated fund and repay the loan through an international banking structure — preferably outside the region where the asset is located, within the holding company’s own jurisdiction. This would separate the transactions by jurisdiction and decouple the sources of funding from the repayment of obligations.
In this hypothetical scenario, SPV A would subsequently be liquidated. The holding company would emerge as the sole owner and the sole creditor of the operating asset, with the debt consolidated within the same ownership structure.
Final Note
We want to emphasize: this is a completely fictional story. We have constructed a hypothesis based on public records, open-source data, and logical assumptions. We have no evidence that any of the individuals or companies mentioned acted as described.
We apologize in advance to IG Development if our assumptions are incorrect. But we find our hypothesis too amusing not to share — we even chuckle at it ourselves, yet it fits the puzzle too well to ignore.
A well-informed and brave man — Mkrtich Karapetyan, an Armenian Service of Radio Free Europe/Radio Liberty (RFE/RL) journalist who has been investigating the flow of foreign capital into Armenia, once said, in a DW article titled “Russian-American heads Trump’s planned Caucasus trade route”:
“Sokolov wanted to avoid a direct deal with the Russian bank.”
Radio Liberty (RFE/RL) was the first to publish the milestone news about the Teghut deal:
As the deal was already settled in two phases — first phase (debt purchase) in June 2026, second phase (shares purchase) in July 2026 — the time had come to make some fantasy on this matter.
“— When and to whom will the copper mine in Armenia be sold? Will the group make a profit from the deal?
— In June 2026, the deal to sell 100% of VTB Bank’s claims against Teghut CJSC was closed. As a result of the transaction, the loan previously extended to Teghut from the balance sheet of our subsidiary bank in Armenia [VTB Bank (Armenia) CJSC] was also fully repaid. The buyer was a group of international investors. The financial result for the bank in 2026 from this transaction is positive, and the profit from exiting the asset, including income previously received in the first half of the year, will amount to approximately 4 billion rubles [∼ USD 51M].”
Thus we can be sure that the key financial settlement for the deal occurred a month before the SPA deal — in the period between June 8, 2026 (the date of Armenia’s parliamentary elections) and June 30, 2026 (before the interview was given on July 1, 2026). It was during this window that the buyer of the debt made the full cash settlement for the purchase of TEGHUT CJSC’s debt from VTB Bank.
Let us draw attention to the phrasing of First Deputy Chairman of VTB Bank: “profit from exiting the asset, including income previously received in the first half of the year.” This means that the $51 million includes, apparently, certain current income that VTB received from the mine in the first half of 2026. In 2024, Teghut’s revenue was $144 million (at an average annual exchange rate of ~390 AMD/USD). For half a year, this amounts to roughly $72 million — of course, salaries, taxes, and other operating expenses were paid out of this sum, so the bank’s actual “income” would have been lower. Nevertheless, the very fact of this inclusion does not allow us to treat the $51 million as purely profit from the sale of the debt — part of this sum had already been generated by the enterprise itself while it was under VTB’s control. Therefore, the exact price of the transaction remains unknown, and our preliminary estimate of $100–150 million still appears realistic.
This brings us to the central question that remains unanswered: which international bank was brave — or reckless — enough to facilitate a cash settlement of hundreds of millions of dollars with a sanctioned Russian bank, fully aware of the risks of secondary sanctions?
Media reports, led by Azatutyun (RFE/RL), have named Konstantin Sokolov — a US-based investor and head of TRIPP+ — as the architect and public face of the transaction. But as a US citizen or US-connected investor, Sokolov would have been acutely aware of the legal exposure involved in any transaction with a sanctioned entity like VTB. The question is not just who bought the debt — but which financial institution was willing to process the payment, knowing the consequences.
Did Sokolov personally take that risk? Or did he rely on a local intermediary — a “KUPRAR RA-2” with its own nominee beneficial owner, a “Virabyan-2” — to carry the operational burden while he remained the strategic frontman?
What we can say with confidence is that the debt was purchased by a separate entity, not KUPRAR RA. KUPRAR RA was a later construct, used to obtain legal title to the asset after the debt had already been cleared. That much is clear. But how the transaction was structured, who financed it, and who ultimately bore the financial and legal risk — these questions remain open, and are the subject of our ongoing thoughts.
Tigran Markosyan — signatory of the Decision, Temporary Acting Chairman, Member of the Competition and Consumer Protection Commission of the Republic of Armenia.
To complete the share purchase, the transaction required approval from the Commission for the Protection of Competition and Consumer Interests of the Republic of Armenia, which issued its decision on July 7, 2026. During the approval process, the beneficial owner of Kuprar RA was entrepreneur Sergey Virabyan, who — according to media reports — sold the company to Sokolov’s U.S. company immediately after the commission’s decision. As we previously noted, based on KPMG’s 2024 audit, Teghut CJSC has negative equity (with a charter capital of just 3.1 million AMD ≈ $3,221), rendering its shares essentially valueless, which suggests the share purchase agreement was largely nominal in nature.
Note: All companies involved in the transaction are closed joint-stock companies. This means that information about their shareholders is not available in the public register — the Electronic System of the State Register of Legal Entities of the Ministry of Justice (https://e-register.moj.am/) — but is maintained by the Central Depository of Armenia (https://cda.am/en), and is not publicly accessible. It is important to note that while the current public registry profile for mining operatorTeghout CJSC still shows the pre-transaction beneficial owners (such as VTB Bank and its partners), this is a matter of legal timing. Under Armenian law, companies have a 40-day window to update their Real Owners Declaration following a change of control. Check TEGHUT BO Declaration here: https://e-register.moj.am/en/companies/39193721/declarations/7c9191c2-1273-451e-bc28-b0545abc029c.
We have reviewed the official document of the Commission for the Protection of Competition and Consumer Interests of the Republic of Armenia — Decision No. 269-A of July 7, 2026, obtained via the portal ef.competition.am.
What the document reveals.The content is striking in its opacity. Nearly all significant sections — from the size of the acquired stake to the ownership structure and financial indicators of the parties — are fully redacted, replaced with █[REDACTED]█. The only certainty we can extract from the document is the fact of concentration: Kuprar RA CJSC acquired some stake in the charter capital of Teghut CJSC. Everything else remains outside the public domain, making any substantive analysis of the transaction impossible based on this document alone.
This is a classic example of a formal public approval that provides minimal information, leaving researchers with little more than speculation.
Notably, according to our information, both Sergey Virabyan and Tigran Markosyan previously worked at Ardshinbank (formerly Ardshininvestbank) at different times, as well as within the Armenian government.
Below, we publish our English translation of Decision.
PAGE 1
REPUBLIC OF ARMENIA COMMISSION FOR THE PROTECTION OF COMPETITION AND CONSUMER INTERESTS
DECISION 7 July 2026, No. 269-A Yerevan
ON PERMITTING THE CONCENTRATION OF “KUPRAR RA” CLOSED JOINT-STOCK COMPANY AND “TEGHUT” CLOSED JOINT-STOCK COMPANY
The Commission for the Protection of Competition and Consumer Interests (hereinafter also referred to as the Commission), at its session on July 7, 2026, discussing the issue of permitting the concentration of “Kuprar RA” Closed Joint-Stock Company (hereinafter also referred to as the “Kuprar RA” Company) and “Teghut” Closed Joint-Stock Company (hereinafter also referred to as the “Teghut” Company),
HAS ESTABLISHED:
1. Brief description of the proceeding: The “Kuprar RA” Company submitted an application to the Commission on June 11, 2026, and the “Teghut” Company submitted an application on June 12, 2026, requesting permission for the notifiable concentration. According to the submitted applications, the “Kuprar RA” Company plans to acquire █[REDACTED]█ of the charter capital of the “Teghut” Company.
Based on the applications of the “Kuprar RA” and “Teghut” companies, a proceeding to assess the concentration was initiated in accordance with the procedure established by law (hereinafter also referred to as the Proceeding).
PAGE 2
2. Documents and other information requested and obtained by the Commission:
1) Regarding “Kuprar RA” Closed Joint-Stock Company: According to the information submitted to the Commission, “Kuprar RA” Company was founded on February 6, 2026, and is █[REDACTED]█.
The █[REDACTED]█ percentage share of the charter capital of “Kuprar RA” Company belongs to “█[REDACTED]█” Limited Liability Company (hereinafter also referred to as “█[REDACTED]█” Company).
According to the information submitted to the Commission, █[REDACTED]█.
The █[REDACTED]█ percentage share of the charter capital of “█[REDACTED]█” Company belongs to a physical person: █[REDACTED]█.
The value of the assets of “█[REDACTED]█” Company for the financial year 2025 amounted to █[REDACTED]█.
PAGE 3
The value of the assets of “Kuprar RA” Company as of the date of submitting the declaration amounted to █[REDACTED]█ AMD, and the amount of revenue was █[REDACTED]█ AMD.
According to the information submitted to the Commission, █[REDACTED]█.
PAGE 4
2) Regarding “Teghut” Closed Joint-Stock Company: The “Teghut” Company was registered on May 22, 2006, and carries out the production and sale of copper ore and concentrates, and molybdenum concentrate. The █[REDACTED]█ percentage share of the charter capital of “Teghut” Company belongs to █[REDACTED]█.
PAGE 5
The ownership chain of “Teghut” Company: █[REDACTED]█.
The value of the assets of “Teghut” Company as of the end of 2025 amounted to 97,366,219,000 AMD, and the amount of revenue was 63,355,054,000 AMD.
The value of the assets of “Teghut” Company as of May 31, 2026, amounted to █[REDACTED]█ AMD, equity capital was █[REDACTED]█ AMD, and liabilities amounted to █[REDACTED]█ AMD.
The volume of copper ores and concentrates produced by “Teghut” Company during 2025 amounted to █[REDACTED]█ net metric tons (չմտ), and the volume of molybdenum concentrate was █[REDACTED]█ net metric tons (չմտ).
PAGE 6
3) Regarding the proposed transaction: According to the applications submitted by “Kuprar RA” and “Teghut” companies, “Kuprar RA” Company plans to acquire █[REDACTED]█ percentage share of the charter capital of “Teghut” Company.
The ownership chain of “Teghut” Company after the Transaction: █[REDACTED]█.
According to information submitted by “Kuprar RA” Company on July 2, 2026, as soon as “Kuprar RA” Company becomes a shareholder of “Teghut” Company, it intends to ensure stable and socially responsible management of “Teghut” Company, in particular: █[REDACTED]█.
PAGE 7
4) Regarding the study conducted by the Commission: According to the results of the study of the mining sector conducted by the Commission, regarding the activities of “Teghut” Company, it should be noted that the company was registered on 22.05.2006, but the actual operation of the mine started in 2015, carrying out the production and sale of copper ore and concentrates, and molybdenum concentrate.
The study of the mining sector showed that the dynamics of the change in gross added value in the mining industry and open-pit mining was mainly conditioned by the operation of the Teghut deposit, and with the suspension of its operations, the sector’s share in GDP decreased.
According to information available in the EITI (Extractive Industries Transparency Initiative) publications (eiti.am):
In 2022, copper ores and concentrates were produced in the Republic of Armenia by:
In the domestic market, “Teghut” Company sold 9,901 net metric tons (չմտ) of copper ores and concentrates and 392 net metric tons (չմտ) of molybdenum concentrate, while “Zangezur Copper-Molybdenum Combine” Closed Joint-Stock Company sold 280 net metric tons (թմտ) of molybdenum concentrate.
In 2022, “Zangezur Copper-Molybdenum Combine” Closed Joint-Stock Company exported 243,367 net metric tons (թմտ) of copper ores and concentrates and 8,041 net metric tons (թմտ) of molybdenum concentrate; “Agarak Copper-Molybdenum Combine” Closed Joint-Stock Company exported 52,189.2 tons of copper ores and concentrates and 894.6 tons of molybdenum concentrate; “Teghut” Company exported 11,744 net metric tons (չմտ) of copper ores and concentrates; and “Akhtala Mining and Processing Combine” Closed Joint-Stock Company exported 8,325 net metric tons (թմտ) of copper ores and concentrates.
In 2023, copper ores and concentrates were produced by:
In the domestic market, “Teghut” Company sold 15,779 net metric tons (չմտ) of copper ores and concentrates and 146 net metric tons (չմտ) of molybdenum concentrate; “Zangezur Copper-Molybdenum Combine” Closed Joint-Stock Company sold 1,380 net metric tons (թմտ) of molybdenum concentrate; and “Agarak Copper-Molybdenum Combine” Closed Joint-Stock Company sold 711.1 tons of molybdenum concentrate.
In 2023, “Zangezur Copper-Molybdenum Combine” Closed Joint-Stock Company exported 203,367 net metric tons (թմտ) of copper ores and concentrates and 8,042 net metric tons (թմտ) of molybdenum concentrate; “Agarak Copper-Molybdenum Combine” Closed Joint-Stock Company exported 50,968.1 tons of copper ores and concentrates; “Teghut” Company exported 38,617 net metric tons (չմտ) of copper ores and concentrates; and “Akhtala Mining and Processing Combine” Closed Joint-Stock Company exported 9,150 net metric tons (թմտ) of copper ores and concentrates.
PAGE 9
According to the information submitted to the Commission by “Teghut” Company, during 2025, the volume of copper ores and concentrates produced by “Teghut” Company amounted to █[REDACTED]█ net metric tons (չմտ), and the volume of molybdenum concentrate was █[REDACTED]█ net metric tons (չմտ).
3. As a result of a comprehensive, complete, and objective discussion of the case, the Commission considers the following factual circumstances established:
“Kuprar RA” Company was founded on February 6, 2026, and is █[REDACTED]█.
The █[REDACTED]█ percentage share of the charter capital of “Kuprar RA” Company belongs to “█[REDACTED]█” Company.
The “█[REDACTED]█” Company (█[REDACTED]█) was founded on August 14, 2025, and carries out █[REDACTED]█.
The █[REDACTED]█ percentage share of the charter capital of “█[REDACTED]█” Company belongs to a physical person: █[REDACTED]█.
The value of the assets of “█[REDACTED]█” Company for the financial year 2025 amounted to █[REDACTED]█.
█[REDACTED]█.
PAGE 10
█[REDACTED]█.
The value of the assets of “Kuprar RA” Company as of the date of submitting the declaration amounted to █[REDACTED]█ AMD, and the amount of revenue was █[REDACTED]█ AMD.
█[REDACTED]█.
█[REDACTED]█.
PAGE 11
“Teghut” Company was registered on May 22, 2006, and carries out the production and sale of copper ore and concentrates, and molybdenum concentrate.
The █[REDACTED]█ percentage share of the charter capital of “Teghut” Company belongs to █[REDACTED]█.
The assets of “Teghut” Company as of the end of 2025 amounted to 97,366,219,000 AMD, and the amount of revenue was 63,355,054,000 AMD.
The volume of copper ores and concentrates produced by “Teghut” Company during 2025 amounted to █[REDACTED]█ net metric tons (չմտ), and the volume of molybdenum concentrate was █[REDACTED]█ net metric tons (չմտ).
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█[REDACTED]█.
█[REDACTED]█.
█[REDACTED]█.
4. As a result of the study and analysis of the factual circumstances of the proceeding and the relevant legal norms, the Commission concludes the following:
According to Part 1, Point 4 of Article 13 of the Law “On the Protection of Economic Competition” (hereinafter also referred to as the Law), the concentration of economic entities is considered to be the acquisition by an economic entity of a share in another economic entity registered in the Republic of Armenia, if this in itself constitutes at least 20 percent of the charter (pooled) capital of that economic entity, or if together with the share already owned by the acquirer, it constitutes at least 20 percent of the charter (pooled) capital of that economic entity.
According to Part 5 of Article 13 of the Law, in the case of the acquisition of a share, the participants in the concentration are the economic entity acquiring the share and the economic entity in whose charter (pooled) capital the share is being acquired.
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According to Part 8 of Article 13 of the Law, a concentration within the meaning of the Law is deemed to occur in:
the same product market (horizontal concentration),
different product markets with a certain interrelationship (vertical concentration), and
different product markets (mixed concentration).
According to Point 2 of Part 1 of Article 15 of the Law, the concentration of economic entities is subject to notification prior to being put into effect if the total amount of revenue of the participants in the concentration, or the amount of revenue of at least one of the participants, in the last financial year preceding the submission of the concentration notification, exceeds the amount of revenue established by the decision of the Commission.
According to the Commission’s Decision No. 553-N of August 15, 2025 “On defining the sizes of assets and revenues of participants of concentrations subject to declaration, the procedure for declaration of concentration, and the form of declaration, and declaring void the Decision No. 322-N of November 9, 2021 of the Commission for the Protection of Competition” (hereinafter also referred to as Decision No. 553-N), Appendix 1 sets out the thresholds for assets and revenues of participants in concentrations subject to declaration. Specifically, according to Point 1, Sub-point 1 of Appendix 1 of Decision No. 553-N, the concentration of economic entities is subject to declaration prior to being put into effect if the total value of the assets of the participants in the concentration at the time of submitting the concentration declaration or in the preceding financial year exceeded four billion drams, or the value of the assets of at least one of the participants at the time of submitting the concentration declaration or in the preceding financial year exceeded three billion drams.
According to Part 1 of Article 70 of the Law, the Commission prohibits a concentration subject to declaration if:
according to the results of the Commission’s studies, as a result of the concentration, economic competition in the relevant product market will be prevented, restricted, prohibited, or otherwise worsened, or
according to the results of the Commission’s studies, the concentration will lead to the emergence or strengthening of a dominant position, or
according to the results of the Commission’s studies, consumer interests will be harmed as a result of the concentration, or
the participant in the concentration does not submit information considered essential by the Commission to assess the impact of the concentration in the relevant product market, and
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it is impossible to obtain such information from other sources, or 5) the participant in the concentration has submitted false information considered essential by the Commission for assessing the impact of the concentration in the relevant product market, which negatively affected the course and results of the study conducted by the Commission.
According to Part 1 of Article 71 of the Law, a mixed concentration and a concentration of economic entities included in a group of persons is permitted under a simplified procedure if there is an apparent absence of grounds for prohibiting the concentration.
According to Part 1 of Article 72 of the Law, in the absence of grounds for prohibiting the concentration, the Commission permits the concentration subject to declaration.
From the facts of this case, it follows that “Kuprar RA” Company was founded on February 6, 2026, and is █[REDACTED]█. The █[REDACTED]█ percentage share in the charter capital of “Kuprar RA” Company belongs to “█[REDACTED]█” Company. “█[REDACTED]█” Company (█[REDACTED]█) was founded on August 14, 2025, and carries out █[REDACTED]█. The █[REDACTED]█ percentage share of the charter capital of “█[REDACTED]█” Company belongs to a physical person: █[REDACTED]█. The companies interconnected with the physical person █[REDACTED]█ operate in █[REDACTED]█.
The “Teghut” Company carries out the production and sale of copper ore and concentrates, and molybdenum concentrate, and the █[REDACTED]█ percentage share of the charter capital belongs to “█[REDACTED]█” Company (█[REDACTED]█). The copper ore and concentrates during 2025 were exported to █[REDACTED]█.
█[REDACTED]█.
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Taking into account the above, the transaction of acquiring a █[REDACTED]█ percentage share of the charter capital of the “Teghut” Company by the “Kuprar RA” Company constitutes, within the meaning of the Law, a mixed concentration, which will not lead to the prevention, restriction, prohibition, or other deterioration of economic competition, nor to the harm of consumer interests, under which conditions the grounds for prohibiting the concentration are absent.
Taking into account the above, the Commission concludes that the concentration through the acquisition of a █[REDACTED]█ percentage share of the charter capital of the “Teghut” Company by the “Kuprar RA” Company is subject to permission.
5. Final part.
Based on the above and governed by Part 2 of Article 67, Part 1 of Article 69, Part 2 of Article 72, Part 1 of Article 101 of the Law, Articles 70 and 71 of the Law “On the Fundamentals of Administration and Administrative Proceedings,” as well as Point 1 of Part 1 of Article 72 of the Administrative Procedure Code of the Republic of Armenia, the Commission
DECIDED:
To permit the concentration of “Kuprar RA” Closed Joint-Stock Company and “Teghut” Closed Joint-Stock Company through the acquisition by “Kuprar RA” Closed Joint-Stock Company of a █[REDACTED]█ percentage share of the charter capital of “Teghut” Closed Joint-Stock Company.
This decision enters into force for each addressee in its respective part from the day following the delivery of its copy to “Kuprar RA” Closed Joint-Stock Company and “Teghut” Closed Joint-Stock Company, respectively.
Point 1 of this decision is valid for a period of one year.
This decision may be appealed through administrative or judicial channels within a two-month period from the moment of its entry into force.
An appeal against this decision does not suspend its operation (execution).
TEMPORARY ACTING CHAIRMAN T. MARKOSYAN
7 July 2026 Yerevan
__________________________________________
Today we reviewed the competition authority’s decision. Next week, we will focus on the financial settlement — and when it actually happened. Almost no one noticed.
Tripp+ Enterprise Fund was awarded Project Grant SEUACE26GR0002 worth $402,000,000 from the Bureau of European and Eurasian Affairs in January 2026 with work to be completed primarily in Armenia. The grant has a duration of 11 years and was awarded through assistance program 19.878 EUR-Other. According to the US government spending database HigherGov (14 days free subscription).
According to the transaction history description as of January 30, 2026: “THE AWARD IS BEING MODIFIED TO SWAP OUT FUNDS. SPECIFICALLY, F HAS INSTRUCTED EUR/ACE TO SWAP THE CURRENT $201 MILLION AEECA FUNDS WITH NSIP FUNDS. THE GO WILL THEREFORE MAKE TWO AMENDMENTS TO THE GRANT. THE FIRST ONE WILL OBLIGATE $201 MILLION NSIP FUNDS. THE SECOND AMENDMENT WILL DE-OBLIGATED $201 MILLION AEECA FUNDS”.
In our view, this substitution appears to be a technical but potentially significant manoeuvre. The original $201 million from the AEECA (Assistance for Europe, Eurasia and Central Asia) programme is being replaced by funds from the new State Department programme — the National Security Investment Programs (NSIP). However, based on the available data, we cannot be certain that the AEECA funds have been fully de-obligated. It is possible that the $402 million currently shown in the system represents the total sum of all transactions processed so far, and that the de-obligation of the original AEECA funds has not yet been reflected in the public database. Until that happens, the true nature of this operation — whether a genuine swap or a real increase — remains technically unclear.
According to the Congressional Research Service (CRS) report R48956, NSIP was established in FY2026 specifically to consolidate the authorities of the Development Assistance, Economic Support Fund, and AEECA accounts into a single, more flexible funding stream. Unlike AEECA, NSIP provides the fund’s management with significantly greater discretion, allowing funds to be directed toward a broader range of objectives — from infrastructure to commercial and political goals. Its FY2026 budget stands at $6.77 billion.
We do not have conclusive evidence that the TRIPP+ money will be directly used for the Teghut purchase. If the administration intends to finance the Teghut acquisition — reportedly controlled by entities linked to Sokolov — through the NSIP mechanism, it would be a logical, albeit opaque, way to do so. We are not asserting this as fact.
July 20, 2026 (brilliant article from HETQ.AM, author Vahe Sarukhanyan, published as of 17/07/2026)
Konstantin Sokolov, who donated $11 million last year to the MAGA committee supporting U.S. President Donald Trump, has been appointed head of the U.S. government-backed TRIPP+ Enterprise Fund, which plans to invest $201 million in the South Caucasus and Central Asia. What does this appointment mean for Armenia, and who is really behind Armenia’s largest mobile telecommunications asset?
Konstantin Sokolov is a U.S. citizen of Jewish descent and a businessman originally from St. Petersburg. His name has once again become the subject of widespread media attention—not because of his business activities this time, but because of politics.
$201 Million for the Private Sector in the South Caucasus and Central Asia
According to The Guardian, citing a spokesperson for the U.S. Department of State, the TRIPP+ Enterprise Fund—named after the TRIPP (Trump Route for International Peace and Prosperity) initiative—has been authorized to invest $201 million in the private sectors of the South Caucasus and Central Asia. The fund will operate in Armenia, Azerbaijan, Georgia, Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan, and Uzbekistan.
The investments are intended to promote the strategic development of the private sector in these countries and may take the form of loans, equity investments, and grants.
TRIPP+ Is Not the Manager of the TRIPP Project
To avoid confusion, it is important to note that the TRIPP+ Enterprise Fund is not responsible for managing the TRIPP project itself.
A joint document published on January 13, 2026, by the foreign ministries of Armenia and the United States, revealed that the two countries will establish the TRIPP Development Company, which will oversee the implementation and infrastructure development of the TRIPP project.
Under the agreement, 26% of the company will be owned by Armenia, while 74% will belong to the United States, specifically to TRIPP Development Company US, which will be incorporated in Delaware as a subsidiary of the U.S. International Development Finance Corporation (DFC).
Armenia and the United States initiated the strategic cooperation agreement on the implementation of TRIPP on May 26, 2026, in Yerevan, and formally signed it remotely in June.
During the Armenian government’s meeting on July 16, Foreign Minister Ararat Mirzoyan explained that:
“An American investment company called TRIPP+ is being established to attract investments for the implementation of the project. Legally, it has an indirect relationship with our TRIPP Development Company. The head of the American investment company TRIPP+ has already been appointed.”
Mirzoyan was referring to Konstantin Sokolov.
Why Was Konstantin Sokolov Chosen?
According to The Guardian, which cited four U.S. foreign assistance experts, appointing politically connected individuals to the boards of Enterprise Funds is common practice for the White House.
Former Enterprise Fund official Don Niss noted that while such appointments are understandable, problems arise when politically connected appointees lack experience in investment banking, private equity, or the sectors in which the funds will invest.
In Sokolov’s case, however, his professional background appears to support his appointment.
According to his official biography, the 51-year-old businessman has led restructuring projects for sovereign wealth funds and central banks, steered the listing of firms on all major stock exchanges and provided strategic counsel to governments and major companies.
One notable detail, though, is absent from his official biography.
According to records from the U.S. Federal Election Commission, Sokolov has become an active political donor.
While he contributed only $3,600 to Barack Obama’s presidential campaign in October 2008, in 2025 he donated $11 million to the MAGA (Make America Great Again) Committee supporting President Donald Trump. In March 2026, he contributed another $443,000 to the Republican National Committee.
Notably, according to FEC records, Sokolov made political donations only twice: once in 2008, and then again beginning in 2025.
Beyond his support for President Trump and the Republican Party, Sokolov is also among the 36 donors who contributed to the construction of the new White House Ballroom. Although the amount of his personal donation has not been disclosed, President Trump has stated that donors collectively contributed more than $350 million to the project.
Sokolov’s Footprint in the Armenian Economy
Hetq first wrote about Konstantin Sokolov in early 2024, when it was officially announced that he had become one of the beneficial owners of Viva Armenia, the country’s largest mobile telecommunications operator.
However, Hetq had obtained information about both Sokolov and the company’s other ultimate beneficial owner, Chinese national Zhe Zhang, several months earlier, in 2023.
In April 2023, Armenia’s Public Services Regulatory Commission (PSRC) refused to approve the transfer of control over MTS Armenia (now Viva Armenia).
The company’s Russian parent, MTS, sought to sell its Armenian subsidiary, but the PSRC referred the proposed transaction to the Ministry of High-Tech Industry, which in turn consulted the National Security Service (NSS). The state bodies ultimately objected to the deal, concluding that approving it would harm—or could potentially harm—Armenia’s national security or state interests.
According to a Hetq source, the authorities rejected the transaction because they were unable to identify the ultimate beneficial owner of the acquiring entity. The lack of transparency regarding who would ultimately control Armenia’s largest mobile operator was considered a security risk.
Later, Sokolov and Zhang emerged through their Cyprus-registered companies.
According to Hetq’s source, they stated that the funds intended for the acquisition of MTS Armenia would come from their family trusts. However, the origin of those assets, the nature of the trusts, their activities, and other essential information were never adequately disclosed.
Eventually, Armenian authorities approved the transaction in November 2023. Ownership of MTS Armenia officially changed in January 2024, with Zhe Zhang becoming the ultimate beneficial owner of 75% of the company and Konstantin Sokolov acquiring the remaining 25%.
In February 2024, the new owners donated a 20% stake in Viva Armenia to the Armenian government. As a result, Zhang’s ownership was reduced to 60%, and Sokolov’s share became 20%.
The Armbusinessbank Deal
Hetq also reported on the sale of Armbusinessbank (now AMIO Bank), 75% of which was acquired by a Swiss investment fund owned by a fund registered in Liechtenstein. The management of latter had been delegated to a Hong Kong company owned by Zhe Zhang.
According to Hetq’s source, Sokolov acted as a representative and adviser to the foreign funds that owned the bank.
The source further explained that Zhang and Sokolov essentially specialize in arranging corporate acquisitions. Their role includes organizing negotiations, coordinating transaction terms, representing the actual beneficial owners—rather than serving as the beneficial owners themselves—executing transactions, and submitting documentation to the relevant government authorities.
Hetq subsequently reported on several earlier transactions involving Sokolov. One of them concerned a Canadian investor who filed a lawsuit in a Cypriot court against his Russian business partners, seeking to recover $2.5 million in investments.
Although the Canadian investor ultimately lost the case, the story attracted attention because an article about it was later removed from a Cypriot news website, though an archived version remained available.
Following Hetq’s publication, there was also an unsuccessful attempt to have the newspaper’s article removed from Google Search.
It is perhaps no coincidence that shortly after becoming a beneficial owner of Viva Armenia, Sokolov launched his personal website on February 5, 2024. The site presents his biography, personal story, philantropy, and other information.
The move creates the impression that a businessman about whom very little had previously been known—and whose online presence largely consisted of reports about investment disputes and an unsuccessful investment project in Russia—sought to establish a more positive public profile after acquiring a stake in Armenia’s largest mobile operator and to dispel some of the mystery surrounding his background.
According to Hetq’s sources, Sokolov is highly sensitive to public reporting about him, particularly criticism related to his business activities.
What Is an Enterprise Fund?
An Enterprise Fund is a financial mechanism established by the U.S. government, with origins dating back to 1989, when the U.S. Congress passed the Support for East European Democracy (SEED) Act.
The initiative was designed to promote private-sector development in former socialist countries as they transitioned to market economies.
The first Enterprise Funds were created for Poland (1990), Hungary (1990), Czechoslovakia (1991), Bulgaria (1992), Romania (1994), the Baltic states (1995), and Albania (1995). Since 1989, the U.S. government has established 13 Enterprise Funds.
Financial Status of U.S. Government-backed CEE Funds as of September 30, 2003
Each fund operates as an independent, autonomous organization governed by its own board of directors, while the U.S. government oversees its activities.
According to the U.S. Department of State, this model was specifically designed so that the Funds could deliver assistance as rapidly as possible, with enough flexibility to develop programs and use a variety of investment approaches to address specific conditions in each country.
VTB Bank wanted to dump the toxic Teghut copper-molybdenum mine. Sanctions had made the asset radioactive. The official line: “bankers shouldn’t dig for copper.”
So VTB structured a deal that would make a Hollywood screenwriter blush. Enter Sergey Virabyan — a former mid-level government official, a banker who never worked in mining, and a man with no visible assets and no apparent reason to own a $22 billion deposit.
Here’s how it worked:
The Phantom Frontman. In February 2026, Virabyan registers “Kuprar RA”. He is the sole shareholder and director. The company has no website, no track record, no history.
The Blind Regulator. On July 7, the Competition Protection Commission approves the concentration. It publishes no information about the buyer’s revenue, assets or beneficial owners.
The Houdini Exit. Virabyan had already left the company by June 5 — before the deal was even approved.
When investigators from Azatutyun asked him who now owns Teghut, the conversation turned into a masterclass of nominee deflection:
— Are you the new owner of Teghut? — No.
— But you owned Kuprar RA? — I used to. Not anymore.
— To whom did you transfer your share? — That is a commercial secret.
— Is Konstantin Sokolov the buyer? — I cannot say. You are asking commercial things.
Virabyan’s clumsy interview sounds exactly like this legendary clash of identities in The Big Lebowski. While the public looks at the Teghut registry expecting to see a real, deep-pocketed tycoon (Sokolov), they are instead forced to listen to a shell proxy desperately repeating that he is just a random guy who has nothing to do with the heavy corporate lifting.
“Let me explain something to you. I am not Mr. Lebowski. You’re Mr. Lebowski. I’m the Dude.”
Officially, the new owner of Teghut is unknown. Unofficially, everyone in Yerevan’s financial and political circles knows exactly who stands behind the deal.
Let’s be clear: Sokolov is a man holding at least Russian, American and Maltese passports. He is an international wallet for opaque transactions, a high-tier proxy who sanitises assets that other banks won’t touch. Teghut is not his first Armenian project, and it won’t be his last.
