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.”
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.
