In 2011, Probusinessbank started placing its funds with the London-headquartered Dinosaur Merchant Bank Ltd. (DMBL), a small financial firm regulated by the U.K.’s Financial Conduct Authority (FCA).

Probusinessbank opened a checking account and a deposit account with DMBL. In September 2011, Probusinessbank deposited $20 million. The bank would go on to transfer a total of over $243 million to its DMBL brokerage account.

So far, so good. Both companies were within their rights to do what they were doing. A Russian bank may deposit its funds with a foreign brokerage account for extra revenues. That was a common practice.