Pay-ving Paradise
Russia's A7 paid $1.5 million to a Maldivian luxury travel company (potentially) for Ilan Shor's birthday using products that didn't yet exist and multiple double-decker buses.
On 17 March 2025, XENTRA L.L.C-FZ, one of the UAE front companies at the center of Russia’s A7 sanctions-evasion operation, wired $500,000 to Lets Go Maldives PVT.LTD., a luxury yacht charter, private aviation, & tourism company in Malé, Maldives.
The invoice described payment for 250 “Garmin Fenix 9 Pro smartwatches” at $2,000 each.
The Garmin Fenix 9 Pro does not exist yet.1
The current flagship is the Fenix 8, released mid-2024, retailing at between $999 and $1,599. Fans of the watch, who follow Garmin’s product cycle put the Fenix 9 at H2 2026 at the earliest. A Pro variant would probably come sometime after that. Whoever made up this invoice named a product that was, on the date of issue, somewhere between eighteen months and two years from existing.
This is not the most interesting invoice in the series.
From within the totality of A7’s thousands payments are three invoices and three SWIFT MT103 confirmations. Viewed together, they document $1.5 million paid in a forty-four-day window between February and March 2025.
Date Entity Amount Goods described
07 Feb 2025 FAVNIR L.L.C-FZ $500000 (USD) Double-decker tourist buses (Scania OmniCity, Wrightbus Gemini 2, Neoplan N122)
14 Feb 2025 FAVNIR L.L.C-FZ $500000 (USD) Double-decker tourist buses (Scania OmniCity, VanHool TDX27 Astromega)
17 Mar 2025 XENTRA L.L.C-FZ $500000 (USD) 250x Garmin Fenix 9 Pro smartwatchesEvery invoice totals exactly $500,000. The goods change completely between invoices. The beneficiary, the bank, and the amount do not.
I want to walk through what is wrong with the buses, because it is specific and it matters.
The Scania OmniCity is a low-floor double-decker that was designed for UK urban transit routes. Production ended in 2011. The last examples were withdrawn from London bus service in 2024.2 A Maldivian company invoiced two of them in February 2025 as “double-decker tourist buses.” You cannot buy a new one. You probably aren’t going to operate one in the Maldives: Malé has five bus routes on narrow coral-island streets, and the outer resort islands are accessible only by seaplane or speedboat. There is no infrastructure in the archipelago for multiple double-decker buses.
The VanHool TDX27 Astromega is a touring coach made by Van Hool NV, a Belgian manufacturer. Van Hool NV was declared bankrupt by the Commercial Court of Belgium on 8 April 2024, with 1,550 jobs at risk and approximately €400 million in debt. VDL subsequently acquired the coach activities and relaunched them under a new brand name. Invoice 0100/25 is dated 14 February 2025: ten months after the the manufacturer went out of business.3
The Wrightbus Gemini 2 is a double-decker body manufactured by Wrightbus. Production ended in 2014. Wrightbus itself entered administration in September 2019, with £60 million in debts and 1,300 jobs lost.4 Of note, the Gemini 2 is my personal favorite bus in London’s TFL fleet.
None of these are available as new purchases. The seller doesn’t sell buses and the buyers don’t buy buses. None of these buses should be operated in the Maldives if they were. Lets Go Maldives is a travel company. It sells yacht charters and private villa bookings. There is no mention of Lets Go Maldives quietly maintaining a fleet of large buses to rival the official transport company in the Maldives.
These goods are not the point and this blog is not a double-decker bus blog. The goods were a mechanism to move Russian money into the Maldives.5
Who is Lets Go Maldives?
Lets Go Maldives PVT.LTD. was founded in 2005 by a CEO, who spent thirteen years at the Bank of Maldives before starting the company.6 That is worth noting as the A7 payments land at account ‘7701151588002’ at the Bank of Maldives. An institution that Lets Go Maldives knows extremely well.
The company is a legitimate, award-winning luxury Maldivian operator. Multiple Seven Stars Luxury Hospitality awards (2022, 2023, 2024, 2025), World Travel Award recognition, and current CEO is founder and president of MAYA, the Maldives Association of Yacht Agents, one of the most connected figure in Maldivian private charter space. Their client base explicitly notes UAE and Russian customers.
The relevant product is the CIP (Commercially Important Person) Fast-Track: VIP arrival handling for customs and immigration. A sanctioned principal arriving on a private jet in a non-extradition jurisdiction needs someone who can move him through an airport quietly. Lets Go Maldives sells that as a named service and appears by stamp on all three invoices.7
The route is the point.
All three SWIFT MT103s follow the an identical payment corridor: First Abu Dhabi Bank (UAE) through Citibank in New York (CITIUS33) to the Bank of Maldives, account 7701151588002.8
Citibank New York is listed as the USD correspondent for all three payments. Every one of these transfers is a US-dollar transaction cleared through a US financial institution. That establishes US jurisdiction over these transactions. All three SWIFT reference numbers (FT25042GDJ25, FT25057JB61T, FT2508623VH2) are (or should be) traceable.
Between the second and third payments, the sending entity changed. FAVNIR LLC was designated and swapped for XENTRA L.L.C-FZ, opened at the same Meydan Grandstand address in Dubai, with the same First Abu Dhabi Bank correspondent relationship and a brand new account number. The beneficiary did not change. The routing did not change. The amount did not change. Only the named buyer on the invoice changed.
I have documented this rotation pattern in detail elsewhere and will continue to. The short version: the front-company entity is a burner. The banking relationship is the real asset and by the time you designate FAVNIR, XENTRA is already open.
Ilan Shor (Șor/אילן שור) was born on 06 March 1987. He turned 38 on 06 March 2025.9
He was likely in the Maldives for his birthday.
Romanian investigative outlet rise.md, investigating the fleet of aircraft Shor acquired through intermediaries and registered under a Turkish trust (Zafer Air, controlled by Turkish businessman Zafer Halidi), tracked one of those aircraft, a Gulfstream G650ER registered as TC-MZK, to the Maldives from 2 to 7 March 2025.10 The aircraft arrived four days before Shor’s birthday and left the day after. His wife Jasmin (Sara Lvovna Shor, Russian singer) has a documented pattern of family Maldives holidays going back years, including one trip with their daughter during which Sara described waking Shor during a storm.11 The Maldives is a non-sanctioning jurisdiction. Shor cannot enter Western countries but he can enter the Maldives.
The payment chronology now reads as a receipt for Shor’s birthday trip.
Two advance payments in February, consistent with staged deposits for a booked charter. A settlement invoice dated 17 March 2025, eleven days after the birthday, potentially a final billing that follows a completed booking. SWIFT execution on 28 March 2025 confirms the money cleared. The advance invoices describe buses. The settlement invoice describes watches. None of the goods exist, were available, or would make sense to be used in the Maldives. What was purchased was the trip.
The A7 invoice generator did not need to pick plausible goods. The SWIFT-matching document just needs to exist: a piece of paper explaining why money moved, for the brief moment a compliance officer might look at it. Nobody at First Abu Dhabi Bank was going to call anyone in Malé to confirm the watch shipment.
While Shor was in the Maldives, something else was happening.
In May 2025, two months after TC-MZK touched down in Malé, OFAC designated A7A5, Shor’s stablecoin. It generated significant coverage.12 Russia building a crypto evasion network, a new frontier of sanctions circumvention, legislative discussions about how to respond, et cetera. By A7’s own internal accounting, A7A5 represented approximately 0.3% of the network’s claimed flows.13
While the stablecoin was being debated, $1.5 million in fabricated invoices for discontinued buses and non-existent watches had already cleared through Citibank in New York. Shor had been on a Gulfstream G650ER for his birthday. The money was long gone.
This is not a crypto story. It has never been a crypto story. It is a correspondent banking story, and the evidence is sitting across 1,091 banks that processed payments for A7.
Ilan Shor described A7 as “pretty much invulnerable” at the St Petersburg International Economic Forum. He may well be right, but not for any reason that features in the current policy debate. The stablecoin is the thing you were supposed to find. The birthday trip cleared through Citibank while we were discussing it.
Nobody called to check on the 250 watches or six double-decker buses.
About Evidence of Absence & a note on this piece.14 15If this was useful, forward it and would love to hear from you!
Garmin Fenix 9 Pro did not exist on 17 March 2025; earliest expected H2 2026, Pro variant 2027: The5kRunner, “Garmin Fenix 9 Release Date, Features and Whether to Wait” (March 2026); HMMüller.com, “Garmin Fenix 9: everything we know about the 2026 launch”; Notebookcheck, “Garmin Fenix 9: CEO hints at major new high-end smartwatch release timeline”. The current model at the invoice date was the Fenix 8, released mid-2024, retail $999--$1,599.
Scania OmniCity production ended 2011; last London examples withdrawn 2024: Wikipedia -- Scania OmniCity; Keybuses, "Scania OmniCitys Bow Out"; London Bus Museum -- 2006 Scania OmniCity SP1. Maldives road infrastructure: Wikipedia -- Transport in the Maldives.
Van Hool NV declared bankrupt 8 April 2024; VDL acquisition: Sustainable Bus, “Van Hool: crisis, bankruptcy, VDL new ownership”; Power Progress, “Van Hool declared bankrupt by Belgian court”; Route One, “Van Hool declared bankrupt; VDL to take coach and bus activities”.
Wrightbus Gemini 2 production ended 2014; Wrightbus administration September 2019, £60M debt: Wikipedia -- Wrightbus; Wikipedia -- Wright Gemini 2.
Falsified trade invoices are a long-standing method that Russia uses to move liquidity pools around the world.
Lets Go Maldives company profile: Lets Go Maldives official site; Visit Maldives directory; World Travel Market London -- Lets Go Maldives exhibitor profile. Seven Stars Luxury Hospitality awards 2022--2025; Mohamed Riyaz previously employed at Bank of Maldives for thirteen years.
Registration C-271/2005
The payment will have highly likely originated in Kyrgyzstan by way of Russia.
Ilan Shor born 06 March 1987: Wikipedia -- Ilan Shor; Wikidata Q4526147.
Aircraft TC-MZK (Gulfstream G650ER, 2016) tracked in Maldives 2--7 March 2025, coinciding with Shor’s birthday: RISE Moldova, “Flota lui Șor din Turcia” (Shor’s Turkish Fleet). The aircraft was acquired through intermediaries and registered under Zafer Halidi’s Zafer Air trust in Turkey; four aircraft in the fleet were identified totalling approximately $91.5 million, funded through a network of associated individuals. Shor’s last confirmed border crossing before this trip: Israel, 25 February 2024.
Jasmin and Ilan Shor's Maldives holidays, including a family trip during which Jasmin described waking Shor during a storm: NOI.md, "Жасмин и Илан Шор пережили на Мальдивах УЖАСНЫЕ МГНОВЕНИЯ" (22 May 2024). Jasmin (Sara Lvovna Shor, born 12 October 1977) is a Russian singer and Shor's wife since 2011.
& continues to, to the detriment of my own sanity.
A7A5 stablecoin volume versus total A7 claimed flows: A7 internal PSB presentation, April 2025. $110M A7A5 against approximately $37.8B total. Documented in OSC “The Big Shor,” / TRM Labs “The A7 Leaks” 2026. OFAC designated A7A5 in May 2025.
This piece draws on an inadvertently published codebase that has not been independently authenticated. All statements of fact, opinion, and analysis are strictly the author’s own and do not constitute a legal or regulatory finding. References to official sanctions designations reflect publicly available government records; all other characterizations reflect the author’s analysis of available evidence. All effort has been made to ensure accuracy. Named entities are welcome to get in touch if I’ve gotten it wrong.
Whilst a reference to Joni Mitchell’s timeless hit, it could also be a reference to Have Heart’s 2008 favorite of mine.