By Erin E. Arvedlund The NEW YORK TIMES,Dec. 16, 2003 published: "She said that Yukos and Bank Menatep, Mr. Khodorkovsky's original vehicle for acquiring and running former Soviet state assets, used offshore companies ''to minimize taxes and spread the shares around to avoid problems with the antimonopoly committee in Russia.''
“Elena Collongues-Popova worked for years in silence, as the financial architect of parts of the early empire built by Mikhail B. Khodorkovsky, who controls Yukos, the giant Russian oil company.
But she has since turned on Mr. Khodorkovsky, Russia's richest man, after French tax police fined her roughly $15 million over actions she said she undertook on behalf of his early business dealings.
Mr. Khodorkovsky, 40, was arrested in Russia in October and is now in jail awaiting trial on charges of tax evasion, fraud and embezzlement. The case is widely viewed as a political crackdown by President Vladimir V. Putin on a billionaire whose political ambitions rankled the Kremlin. Ms. Popova says she is telling the Russian authorities what she knows to assist their investigation into the ways Mr. Khodorkovsky amassed his fortune.
Ms. Popova says that she has never met him and that her role in his business was a bit part, as a midlevel financial administrator; she never had the complete picture of Mr. Khodorkovsky's business empire. But she can speak with authority, she says, about a very relevant part of it: offshore companies that were set up to hold Yukos shares, seemingly for owners independent of Mr. Khodorkovsky and his associates. In fact, she said in an interview in November that the ''client'' was her.
She said that Yukos and Bank Menatep, Mr. Khodorkovsky's original vehicle for acquiring and running former Soviet state assets, used offshore companies ''to minimize taxes and spread the shares around to avoid problems with the antimonopoly committee in Russia.'' She added: ''They wanted it to look like these weren't owned by a single person, but really they were.''
Ms. Popova, 50, said that from 1996 to 2000, when Russia's rough-and-tumble transition to capitalism was in full swing, she worked for Alexei Golubovich, who was then finance director of Bank Menatep. Fortunes were built in those years by buying plants and factories from the state for pennies on the dollar and either stripping them or revamping them into successful businesses; Mr. Khodorkovsky assembled a cluster of former state oil properties into what is now Yukos.
Bank Menatep itself collapsed when Russia defaulted on debts in 1998 and the value of the ruble crashed, but a successor holding company, Group Menatep, now holds a variety of businesses along with Mr. Khodorkovsky's stake in Yukos, Russia's biggest oil company.
Ms. Popova acknowledges that she has a financial motive for coming forward with her story: the millions of dollars that French authorities say she personally owes in connection with the offshore companies. She says that throughout the transactions involved, she was acting on behalf of her boss, Mr. Golubovich, and that Yukos and Menatep are responsible for the French taxes. But they have refused to pay, she said.
''It's very difficult to understand why they didn't want to pay -- it's not logical,'' she said in the interview, in the modest apartment in the chic Neuilly-sur-Seine district of Paris that she shares with her boyfriend, Roger Kinsbourg, and his son. ''I told them they needed to pay'' the French taxes, she said. ''Otherwise, it was tax evasion. Why they didn't pay, I don't know. It was stupid.''
There is no easy way to corroborate Ms. Popova's account or to verify the provenance of the documents she offered to support them. But there is a public record of her role at the offshore holding companies. She was named as a defendant in a highly publicized lawsuit by an American investor, Kenneth Dart, against Mr. Khodorkovsky and Yukos. In the suit, she is listed as a director of Wilk Enterprises, which Mr. Dart contended was used to dilute shares of three smaller oil companies.
Many of the documents Ms. Popova said she had provided to Russia's Ministry of Internal Affairs appear to describe transactions in Yukos stock processed on behalf of Mr. Golubovich's brokerage firm, Russian Investors, and they bear her signature. A spokeswoman for the ministry declined to comment on Ms. Popova or say whether it had received documents from her related to Mr. Khodorkovsky's case.
A spokesman for Menatep in Moscow acknowledged that Ms. Popova worked on financial matters involving Bank Menatep, but dismissed her claims of wrongdoing by the company. ''I believe that frankly she is trying to use the situation around Yukos to solve her own problems with French tax police,'' the spokesman said. Referring to Mr. Golubovich and his firm, the spokesman said, ''I don't know what relationships she had in the past with shareholders'' of Menatep.
It is doubtful whether Ms. Popova would have surfaced or shared her account of her business dealings publicly if she had not been faced with a ruinous tax bill and the threat of a prison sentence herself. Ms. Popova said had been asked by the Russian authorities to return to the country to testify, but was afraid to go.
Ms. Popova said she had been recruited by Mr. Golubovich for his firm when they met at a party in St. Tropez. She became friendly with him and his wife, and they often vacationed together, she said. Now, she said, she is suing Mr. Golubovich in Switzerland.
Efforts to reach Mr. Golubovich through intermediaries for comment were not successful.
Ms. Popova was born in Russia and became a French citizen after marrying a French diplomat; they later divorced. Ms. Popova, who moved to Paris a decade ago, said her French citizenship made her the perfect resident executor for Russian offshore companies.
It was common, she said, for Russian business owners to arrange to sell their products to offshore shell companies at low prices and then have the shell companies resell them at market prices, keeping the profits beyond the Russian tax authorities' reach. ''Everybody did it,'' she said.” – notes The New York Times in the article “Russian Oil, French Taxes and Foreign Intrigue”
