The Russian TUI major shareholder Alexei Mordashov reorganized his shares in the travel group shortly before the EU sanctions were imposed.
From his previous 34 percent stake, which he had held through Unifirm in the EU country of Cyprus, he transferred a 4.1 percent stake to his Russian holding company Severgroup, as TUI announced late Friday evening in Hanover.
He sold his shares in Unifirm, which he had held through two subsidiaries, to a company called Ondero Limited in the British Virgin Islands.
Both happened accordingly on February 28th.
According to the information, Ondero Limited now holds a 29.9 percent stake in TUI via Unifirm, making it the largest shareholder in the world's largest travel group.
"We do not know who Ondero's shareholders are," said a TUI spokesman on Saturday.
This leaves open the question of whether Mordashov is one of them.
The Virgin Islands are considered a tax haven where many shell companies are based.
By transferring less than 30 percent of TUI shares, Mordashov avoided Ondero having to submit a takeover bid for the German travel group.
On the evening of February 28, the EU imposed sanctions on several Russian oligarchs, including Mordashov.
Since then, their assets in the EU have been frozen and their freedom to travel restricted.
The Russian apparently acted at the last minute with the reorganization of his TUI shares.
Mordashov is the main owner of the Russian steel group Severstal and was also TUI's largest shareholder at least until the end of February.
After the EU sanctions were imposed, he resigned from the travel group's supervisory board on Wednesday.
"The aim of the EU sanctions is that Mr. Mordashov can no longer dispose of his shares in TUI AG," the group said.
This is to prevent Mordashov from being able to generate revenue or profits from his stake in TUI.