STATEMENT TO THE TURKSIB DISTRICT POLICE DEPARTMENT OF THE ALMATY CITY POLICE DEPARTMENT REGARDING A CRIMINAL OFFENSE
TO: The Turksib District Police
Departmentof the Almaty City Police Departmentof the
Ministry of Internal Affairs of the Republic of Kazakhstan
14 Richard Sorge Street, Almaty.
From the Applicant: A.I.S.
IIN: ....
Almaty, Zhe... Street, Building 3
+7 701 ...
STATEMENT
regarding a criminal offense
I have been warned of criminal liability for knowingly making a false report under Article 419 of the Criminal Code of the Republic of Kazakhstan.
I, A.I.S., hereby submit this statement requesting that Z.B.N., born on 19 April 1985, IIN ...., be held criminally liable for fraud.
On 30 December 2024, my former colleague, Z.B.N., approached me with a request to provide him with money as a loan, referring to extremely difficult circumstances in his life. In support of his request, he stated that he had been involved in a road traffic accident as a result of which harm had been caused to a person's health, and that he urgently needed funds to compensate the injured party for material and moral damage. By using these circumstances and exerting psychological pressure on me, he persuaded me to provide him with KZT 5,000,000, which he undertook to repay by 15 February 2025.
For the purpose of misleading me and creating the appearance that his obligation was secured, on 30 December 2024 Z.B.N. personally wrote a receipt stating that, in the event of non-repayment of the debt, he would transfer to me, as collateral, two machines for the production of expanded metal mesh, allegedly owned by him.
On the same day, I made the following transfers of funds: KZT 1,300,000 at 11:17 to the account of G.B. (at the request of Z.B.N., who is his mother); KZT 2,000,000 at 11:19 to his personal account; and KZT 1,700,000 at 11:40. All of the above transfers are confirmed by the respective bank receipts, which are attached to this statement.
Subsequently, on 28 January 2025, Z.B.N. again approached me with a request for funds, once again referring to the circumstances related to the road traffic accident. I initially refused; however, he assured me that this time he would provide more reliable security, namely the apartment in which he resided. In confirmation of his statements, he provided me with the original sale and purchase agreement for an apartment located at: Apartment 4, Building 2, T.K. Street, Bayseit Village, Enbekshikazakh District, Almaty Region. The agreement identified I.M.A., born on 10 March 1961, as the owner of the apartment.
When I directly asked Z.B.N. who owned the apartment, he stated that the apartment actually belonged to him but had been registered in the name of his relative. I repeatedly warned him that deception was unacceptable, which is confirmed by an audio recording (file name: “WhatsApp_Audio_2026-04-01_at 13.54.06_(1).OGG”). Nevertheless, relying on his statements, on 28 January 2025 I provided him with KZT 3,000,000 against a written receipt, with a repayment deadline of 1 March 2025.
After the above deadlines expired, Z.B.N. failed to fulfill his obligations and did not return the funds despite repeated demands, telephone conversations, and personal meetings. At the same time, he systematically evaded repayment of the debt, referring to various reasons and excuses.
Subsequently, when I attempted to realize the pledged property, I learned that the two machines specified in the receipt did not belong to Z.B.N. but were owned by a third party named Dastan (contact number: +7 708 111 16 76). This is confirmed by an audio recording entitled “станки_принадлежат_Дастану.OGG”, which has been uploaded to a flash drive. Similarly, it was established that the apartment provided as collateral under the second receipt also did not belong to him and was in fact owned by a third party to whom Z.B.N. was also indebted.
I further inform you that I conduct entrepreneurial activities involving the sale of construction materials, including plaster mesh. Z.B.N. had previously purchased such goods from me on multiple occasions with payment to be made subsequently, i.e. on credit. As a result of his systematic receipt of goods without payment, he incurred an outstanding debt to me in the amount of KZT 2,000,000 (two million), which remains unpaid to date.
In addition, I recorded video footage (file names: “WhatsApp_Video_2026-04-01_at_14.01.51.mp4” and “WhatsApp_Video_2026-04-01_at_13.58.47.mp4”) in which Z.B.N. acknowledges the existence of the debt and requests a deferment of payment: the recording dated 18 November 2025 contains his promise to repay the debt by 21 November 2025, while the recording dated 3 December 2025 contains his promise to repay it by 10 December 2025. Neither of these promises was fulfilled.
The above actions of Z.B.N. indicate the existence of an initial intent for personal financial gain aimed at the unlawful and gratuitous conversion of my funds to his own benefit. By providing knowingly false information that the machines and apartment belonged to him, as well as by abusing the trust that had arisen from our personal and business relationships, he misled me, as a result of which I voluntarily transferred the funds to him. Pursuant to the explanations contained in Regulatory Resolution No. 6 of the Supreme Court of the Republic of Kazakhstan dated 29 June 2017, “On Judicial Practice in Cases of Fraud,” such actions constitute fraud, since property is transferred voluntarily by the victim under the influence of deception or abuse of trust, where the perpetrator acts with an intent to obtain unlawful financial gain.
I additionally inform you that on 23 February 2026 I had already filed a statement with the police concerning these circumstances and was questioned by J.B.B., an investigator of the Investigation Department of the Turksib District Police Department of the Almaty City Police Department. However, to date, I have not received any information regarding the results of the pre-trial investigation. I am also aware that on 24 February 2026 Z.B.N. submitted a written explanation addressed to the Head of the Turksib District Police Department, in which he acknowledged that he owed me KZT 10,000,000 and undertook to repay the amount within two months. This undertaking was also not fulfilled.
Pursuant to paragraph 1 of Regulatory Resolution No. 6 of the Supreme Court of the Republic of Kazakhstan dated 29 June 2017, as amended on 22 December 2022, an essential element of fraud is the existence of an intent for personal financial gain, as well as the fact that property was transferred under the influence of deception or abuse of trust.
In view of the foregoing, I believe that the actions of Z.B.N. contain elements of the criminal offense provided for by subparagraph 1) of part 3 of Article 190 of the Criminal Code of the Republic of Kazakhstan, namely fraud committed on a large scale. The total amount of funds misappropriated by him through deception and abuse of trust amounts to KZT 10,000,000 (ten million), which is confirmed by the written receipts, bank transfers, and other evidence. The said amount constitutes significant damage and qualifies as a large amount of damage caused to me as the victim.
Pursuant to Article 167 of the Criminal Procedure Code of the Republic of Kazakhstan (hereinafter referred to as the “CPC”), a civil claim may be filed from the commencement of the pre-trial investigation until the end of the judicial investigation by a person who has suffered direct property or moral damage as a result of a criminal offense or a criminally punishable act committed by an insane person, or by his or her representative.
Pursuant to Article 179 of the CPC, the commencement of a pre-trial investigation shall be the registration of a statement or report concerning a criminal offense in the Unified Register of Pre-Trial Investigations or the performance of the first urgent investigative action.
Subparagraph 1) of paragraph 1 of Article 180 provides that grounds for commencing a pre-trial investigation include sufficient data indicating the elements of a criminal offense, in the absence of circumstances precluding proceedings in the case, namely: a statement by an individual or a report by an official of a state body or a person performing managerial functions in an organization concerning a criminal offense or the disappearance of a person whose whereabouts are unknown.
Based on the foregoing and pursuant to Articles 71, 73, 167, 179 and 181 of the Criminal Procedure Code of the Republic of Kazakhstan,
I HEREBY REQUEST:
- To register in the Unified Register of Pre-Trial Investigations a criminal case against Z.B.N. on the grounds of the criminal offense provided for by subparagraph 1) of part 3 of Article 190 of the Criminal Code of the Republic of Kazakhstan (fraud).
- To recognize me, A.I.S., as the victim in this criminal case.
- To recognize me, A.I.S., as a civil plaintiff.
- To conduct a comprehensive, complete and objective pre-trial investigation and take all measures provided for by law.
Respectfully,
A.I.S.
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