Alexei Mordashov, a Russian billionaire, may have avoided a freeze on a £1 billion shareholding in Tui, the world’s largest tourism company, after selling the majority of his 34 percent stake to a British Virgin Islands company.

After stepping in to keep Tui afloat during the pandemic, Russia’s richest man had become the single largest shareholder in the company, which has dual stock market listings in Frankfurt and London. On March 2, two days after being blacklisted by the EU, he resigned from the Tui board. On Tuesday, the UK government sanctioned him. Mordashov was among the first oligarchs targeted, with the EU citing his investments in Rossiya bank, dubbed the “personal bank” of Russia’s top officials, as well as his stakes in television stations that helped destabilize Ukraine through pro-Russia broadcasts.

Mordashov sold 29.9 percent of his Tui shareholding to Ondero Ltd, based in the British Virgin Islands, according to a regulatory filing and press release issued by Tui last Friday. At today’s prices, the shares are worth £1.1 billion. The remaining 4.1 percent, according to Tui, was sold to the businessman’s Russian investment vehicle, Severgroup. Tui stated that the transfers took place four days earlier, on February 28th, the day Modashov was named to the EU sanctions list.

Mordashov’s entire stake in Tui would have been frozen under sanctions rules, which would have prevented him from selling his shares, receiving dividends, voting at board meetings, or profiting from the stake in any other way.

Tui, on the other hand, has confirmed that only the small portion held by Severgroup, worth £155 million, has been frozen. The company claimed it had no idea who owned Ondero or whether its 29.9 percent stake had been frozen as part of the sanctions regime.

“We cannot judge whether and how the sanctions apply here,” a Tui spokesperson said. Tui would only need to be notified if Ondero has a controlling shareholder. Reporting obligations under German capital market law apply to all shareholders of a company, regardless of location. Because Tui and Germany’s financial regulator BaFin did not receive any additional voting rights notification, the company is unable to pursue this or identify Ondero’s shareholders.”

According to Bloomberg, the Ondero stake is still “affiliated” with Mordashov. British Virgin Islands secrecy laws keep the true owner’s identity hidden. The UK’s overseas territory and former colony has resisted calls to make its company register public, so information about shareholders can only be obtained in exceptional circumstances, such as a law enforcement request.

Mordashov transferred another valuable asset to his wife, Marina Mordashova, on February 28: a $1.1 billion shareholding in the Russian mining group Nordgold. The businessman, who is the CEO of Severstal, Russia’s largest steel and mining group, also chairs Severgroup, a private investment firm with interests ranging from telecommunications to gold mining, media, and engineering.

According to a Severstal spokesperson, the company is unable to comment on the Ondero transaction. “I just want to remind you that Mr. Mordashov was previously included in the EU sanctions list [on 28 February],” she added. So, with the imposition of UK sanctions on Mr. Mordashov, nothing really changes for Tui. I can also confirm that he has no assets in the United Kingdom.”

Mordashov reacted angrily to the EU’s decision to blacklist him, saying a day later, “For a very long time, I have been engaged in the development of economic, cultural, and humanitarian cooperation with many European countries, and I fail to understand how these sanctions against me will contribute to the resolution of Ukraine’s dreadful conflict.”