LLC Titul is a company based in Russia and owned by Dimitry Beloglazov. Its subsidiary Joint Stock Company (JSC) Iliadis (based in Russia) acquired Oleg Deripaska’s share in the International LLC Rasperia Trading Limited (“Rasperia”, based in Russia). Rasperia owns 28,5 million shares in the European company STRABAG SE. Those shares were frozen because Rasperia was controlled by Oleg Vladimirovich Deripaska, an individual subject to Union restrictive measures. The establishment of a subsidiary of LLC Titul was coordinated between Dimitry Beloglazov and Oleg Deripaska to sell the frozen shares of STRABAG. To that end, Beloglazov’s company LLC Titul established a subsidiary, JSC Iliadis, which acquired Deripaska’s share of Rasperia, and thereby also the frozen STRABAG shares. Deripaska received an equivalent economic benefit for the sale of Rasperia. Dimitry Beloglazov and the involved companies LLC Titul, JSC Iliadis and Rasperia used this complex scheme to sell, outside the Union, a non-Union company controlled by a listed person and owning frozen shares of a Union company with the sole purpose to lift the freezing of those shares in the Union, thereby circumventing Union restrictive measures. Therefore, LLC Titul is facilitating infringements of the prohibition against circumvention of Regulation (EU) No 269/2014.