Bayrock Group LLC

Bayrock still contracting sales agents at Trump SoHo in 2013 despite being supposedly dormant since 2008-2011

Despite multiple sources stating Bayrock ended US operations between 2008-2011 (Tevfik Arif shifted focus away from US real estate post-financial crisis), the Domus Arbiter lawsuit reveals Bayrock/Sapir Organization and Bayrock/Zar Spring LLC were still actively contracting sales agents (Zampolli, Elliman) and managing unit sales at Trump SoHo in January 2013. This contradicts the narrative that Bayrock was dormant. The 6% commission offer (vs standard 4%) suggests desperation to move units before the 2014 foreclosure, and willingness to pay above-market rates for well-connected brokers who could bring foreign cash buyers. CIM Group acquired Trump SoHo through foreclosure auction in late 2014 after Bayrock/Sapir defaulted on junior loan.

EDGAR shows 'Bayrock Ventures, Inc.' (CIK 0001432272, also filed as 'Innovative Wireless Technologies, Inc.') with 27 filings including 10-K and 10-Q forms. SIC 6770 (Blank Checks). Business location: New York, NY. Incorporated in Delaware. This appears to be a blank check/shell company vehicle distinct from Bayrock Group LLC (the real estate firm). Filed annual and quarterly reports 2008-2009 period. The dual naming (Bayrock Ventures / Innovative Wireless) and SIC 6770 classification suggests reverse merger or shell company structure. Bayrock Group LLC itself (the real estate development firm at 725 Fifth Avenue/Trump Tower and later 160 Varick St) was a private LLC with no direct SEC filing obligations.

Bayrock Group LLC is the #2 betweenness centrality node (0.303) and #3 by degree (13) in the non-subject graph. It bridges the Trump Organization/real estate cluster to the Kazakh money laundering network (Khrapunov-Sater-KazBay) and Zampolli's real estate operations.

Bayrock connects three otherwise disconnected subnetworks: (1) Trump Organization / Daniel Ridloff / George Sorial, (2) Ilyas Khrapunov / Viktor Khrapunov / Martin Jajan / KazBay B.V., and (3) Zampolli Domus Arbiter Realty / Paramount entities. Its neighbor density is only 0.103, confirming classic broker position. Bayrock has only 3 findings against 13 connections (gap ratio 4.3), making it significantly under-investigated relative to its structural importance.

Bayrock Group LLC (NY DOS #2661460) still Active as of 2026; Bayrock/Sapir entities also Active — corporate capacity existed to contract with Zampolli in 2013

NY DOS search confirms Bayrock Group L.L.C. (DOS ID 2661460, filed 2001-07-17) is still Active status. The Trump SoHo sponsor entities — Bayrock/Sapir Organization Holdings LLC and Bayrock/Sapir Organization Realty LLC (both Delaware LLCs authorized in NY, DOS IDs 3229588 and 3231994) — are also Active. Bayrock Spring Street LLC (DOS 3229491, Delaware) is Active. This means Bayrock had full legal capacity to contract with Zampolli/Paramount Realty in 2013 as alleged in the Domus Arbiter case. The question of WHO at Bayrock authorized that contract remains unresolved — Tevfik Arif is the founder but Sater allegedly continued to control operations per Kriss RICO allegations.

CourtListener indexes 20+ cases with Bayrock as party. Key litigation: (1) Kriss v. Bayrock Group LLC (SDNY 10-cv-03959) - RICO suit by ex-finance director alleging tax fraud, money laundering; 3 Second Circuit appeals (15-4077, 16-703, 18-914); settled May 2018 after 8 years on confidential terms. (2) City of Almaty v. Sater (SDNY 19-cv-02645) - $52M judgment against Sater for laundering Khrapunov money through Bayrock-connected transactions. (3) Numerous consumer complaints: Bayrock Mortgage Corporation was separate entity (multiple consumer credit, foreclosure, fair debt collection cases across SDNY, NDGA, CDCA, DNV, SDCA). Bayrock Mortgage cases are NOT related to Bayrock Group LLC real estate development.

NYSCEF business search 'Bayrock' (page-limited at 50) reveals extensive NY state court footprint NOT fully captured in prior CourtListener-based analysis. Notable new/related dockets beyond known federal Kriss RICO case: (a) Bayrock/Sapir Organization LLC v Tax Commission of City of NY (tax certiorari cases 2006-2010, Bronx County, repeat annual) — 256862/2006, 256863/2006, 257022/2007, 257023/2007, 260393/2008, 260421/2009, 262941/2010, 803738/2007; (b) People of NY ex rel Qui Tam v Bayrock Qui Tam Litigation Partners (101478/2015 and 2018-3507) — state qui-tam actions tied to the Oberlander/Kriss whistleblower thread; (c) Bayrock Group v Frederick Oberlander (158246/2016) — Bayrock's retaliatory suit against the whistleblower attorney; (d) Bayrock Spring Street LLC v 246 Spring Street (Soho NY) Mezz LLC (650921/2015 and appellate 2019-2091) — Trump SoHo mortgage/mezz workout; (e) Bayrock/Sapir Organization v Affiliated FM Insurance (652014/2013); Bayrock Group v National Union Fire Insurance Pittsburgh (653853/2018) — insurance coverage litigation; (f) Bayrock Group LLC v Rockwell Architecture (mirror suits 651347/2011, 651370/2011); (g) multiple Trump SoHo personal injury cases (Astashova, Bajmel, Gordon, Garcia, Rivas, Martin, Lang — 2013-2022); (h) Bayrock Insurance Agency LLC + Bayrock Realty Co. Inc. + Bayrock Natural Stone LLC + Bayrock Capital LLC + Bayrock Spring Street LLC — multiple Bayrock-branded subsidiaries still active/being sued through 2025.

ACRIS deeds and FL registry confirm Bayrock Group LLC operated from two key addresses: (1) 725 Fifth Avenue, 24th Floor, New York, NY 10022 (Trump Tower) -- used as principal address for Bayrock Midtown LLC (FL L05000001303, formed 2005-01-04, inactive, EIN 061784665). (2) 160 Varick Street, 2nd Floor, New York, NY 10013 -- used on all 3 Khrapunov purchase deeds (April 2013) as the C/O address for Bayrock/Sapir Organization LLC and Bayrock/Zar Spring LLC. The Varick Street address matches the SoHo neighborhood and is blocks from Trump SoHo at 246 Spring Street. The address change from Trump Tower to Varick Street occurred between Bayrock's active development period (2001-2010) and the 2013 sales period.

Bayrock Sponsor-Defendants' sales/admin staff in 2013 Trump SoHo transactions: Ivan Pelaez (sales office), Amy Williamson (Prudential Douglas Elliman, alleged straw broker), Ken Nadkumar (staff accountant)

Trump SoHo (246 Spring St) was Bayrock-Sapir-Trump joint venture; buyers sued for fraud, settled with 90% refunds; DA investigated

Trump SoHo at 246 Spring Street was a $450M, 46-story condo-hotel developed as joint venture between Bayrock Group (Tevfik Arif), Sapir Organization (Tamir Sapir), and Trump Organization (18% equity, licensing deal). Felix Sater was managing director of Bayrock 2003-2008 and key decision-maker on the project. In 2010, buyers filed federal suit alleging sales fraud — told 60% of units sold when actual figure was 16%. Settled in 2011 with buyers receiving 90% of $3.16M in deposits. Settlement required buyers to cease cooperating with government investigators. Manhattan DA conducted secret criminal investigation into the fraud. Building later renamed 'The Dominick' in Dec 2017 after CIM Group (owner since 2014) severed ties with Trump.