Who is Ali Moulaye and why does it matter?


Or, what links Deutsche Bank, the Moldovan Laundromat, Paul Manafort and three dead Russians?

It’s impossible for anyone working in the field of Anti-Financial Crime, KYC or Anti-Money Laundering not to have noticed that there have been a number of high profile money laundering cases over the past few years. High on that list would be the Deutsche Bank Mirror Trades and subsequent fine, especially if, like me, you have worked or are working at Deutsche Bank in KYC.

Although, just to be clear, every fact, reference and document in this article has been sourced from publicly available databases, websites or resources. I do not have access to, and neither have I used, any inside information or non-public sources to put this story together. What I do have is an obsessive nature and a love for investigation so that, once I started noticing some strange “coincidences” I couldn’t let it rest until I had followed them to where they wanted to lead me. This (rather long and complex) article is what came of that investigation although I could not have imagined at the start that it would cover the three alleged murders of Alexander Perepilichnyy, Sergei Magnitsky and Alexander Litvinenko, the former head of President Trump’s election campaign, the Moldovan Laundromat and the Deutsche Bank mirror trades but that is serendipity for you!

My story starts with an article that appeared in the New Yorker on 29th August 2016, written by Ed Caesar (https://www.newyorker.com/magazine/2016/08/29/deutsche-banks-10-billion-scandal). I’ve always been interested in the role of offshore companies and UK LLPs and how they might be used as part of a sophisticated money laundering scheme and the article reference some specific companies allegedly involved in the DB mirror trading, some of which were located in the UK which gave me a place to start.

The article specifically mentions the following companies:

  • Westminster Capital Management – Russia
  • Financial Bridge – Russia
  • Chadborg Trade LLP – UK
  • ErgoInvest LLP – UK
  • Cherryfield Management Ltd – British Virgin Islands

The two UK LLPs seemed like a good place to start.

Chadborg Trade was incorporated on 10 September 2012 with two corporate designated members (Kenmark Inc and Ostberg Ltd) both of which were based in Dominica at the same address (8 Copthall, Roseau Valley, Commonwealth Of Dominica, 00152).

The accounts for 2013, 2014 and 2015 (during which time they showed annual commission income of £20,683, £21,353 and £6,281 – a far cry from the millions if not billions they are supposed to have laundered) were signed off by Aly Moullaye in 2013 and Ali Moullaye in 2014 and 2015 on behalf of Kenmark Inc.

ErgoInvest LLP was also incorporated on 10 September 2012 with two designated members (Kenmark and Ostberg). Their accounts for the same three years show commission income of £20,983, £20,683 and £8,557 (spot the similarities) and were also signed off by Mr Moullaye with the same variant of spelling between 2013 and 2014/15.

Additionally, whilst researching Ergoinvest LLP I couldn’t help noticing that there was also a business registered with Companies House called Ergoinvest LP (which is a limited partnership registered in Scotland). Not being a great believer in coincidences I thought that was worth a further look and found, from their Certificate of Registration that their two general partners were called Dexberg Inc and Montbridge Inc. Intrigued I delved a bit deeper.

Both Montbridge and Dexberg are registered at the same address in the Marshall Islands (Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Mh96960) which also just happens to be the same address as two further companies we are soon to meet. Both Montbridge and Dexberg serve as designated members for a number of UK LLPs, one of which (Baltex Centre LLP) is still active (although their latest accounts are overdue). Their filing history makes for interesting reading. Their original designated members were Milltown Corporate Services Ltd and Ireland and Overseas Acquisitions Ltd (both based in Belize – remember those names) who were in place from the formation of the company in 2007 until 2011 when they were replaced by Monohold AG and Intrahold AG who are based in the Seychelles. They in turn resigned in 2014 to be replaced by Tallberg Ltd and Uniwell Ltd (they are on the Caribbean island of Nevis) who in turn resigned in June of this year to be replaced by the aforementioned Montbridge and Dexberg in the Marshall Islands. Are you still with me? It’s been quite a tour of the Caribbean.

Since 2007 they’ve filed annual accounts, but sadly the early ones have indecipherable signatures. It gets more interesting when the first set of accounts are filed by Monohold AG in 2012 (they’re the ones in Seychelles) which were signed by? Yes, you guessed it, Ali Moulaye! He signed for Monohold in 2012/13/14 but by 2015 they had resigned and the new accounts were signed on behalf of Tallberg Ltd by Ali Moulaye! Who repeated the act in 2016.

So far so good. We will come back to Mr Moulaye in a minute.

What can we discover about Financial Bridge and Cherryfield?

One of the only official references I could find was an order by the Arbitration Court of the City of Moscow (http://sudact.ru/arbitral/doc/7foh0bFyYIs/ – I used Google translate for the information in this article) which appears to be an appeal by Financial Bridge against an order by the Russian Financial Markets Regulator against some form of indiscretion. Part of the judgment lists several firms on whose behalf Financial Bridge appears to have conducted trades that contravened some Russian regulations (I’m neither a Russian expert nor a lawyer so I cannot confirm the fine detail).

I did spot a couple of interesting companies in the list though. One of them was Cherryfield Management Ltd and another is called Lantana Trade LLP. Most times when you see the LLP suffix you can bet it is a UK registered limited liability partnership and, sure enough, Lantana was. Cherryfield, on the other hand, appears to be registered in BVI.

Lantana Trade LLP was initially incorporated on 6 May 2011 with two corporate designated members – Marteza Alliance Ltd and Dorado Group Ltd, both based in the Seychelles. They resigned on 26 July 2012 and were replaced by Formond Inc and Primecross Inc, both of whom are based at the same address in the Marshall Islands (Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Mh96960). They filed accounts for 2012/13/14, all of which were signed off by one Ali Moulaye. They show annual commissions for the three years of £15,689, £14,083 and £14,682 – remarkably similar to Chadborg and ErgoInvest, except Mr Moullaye (or Moulaye) appears to have nipped over to the Marshall Islands to sign them off.

But back to Financial Bridge. What else can we discover?

In a follow up to the article in the New Yorker quoted above, Ed Caesar revisits the DB Mirror Trades story and, right at the end of the article, throws in a huge curve ball (see: https://www.newyorker.com/business/currency/deutsche-bank-mirror-trades-and-more-russian-threads).

“It should interest both Congresswoman Waters and investigators at the Department of Justice, then, that, the name Alexander Perepilichnyy appears as a major shareholder on the official Russian documentation of Financial Bridge, a brokerage that was one of Deutsche Bank’s key Russian counterparties in the mirror-trades affair.”

Anyone interested in modern politics, particularly where it concerns Russia, would sit up and take notice of that little gem. The man allegedly murdered with a rare Chinese plant poison (gelsemium – see, for example this report in the Independent – http://www.independent.co.uk/news/uk/home-news/russian-whistleblower-poisoning-alexander-perepilichnyy-surrey-gelsemium-elegans-sorrel-soup-flushed-a7628736.html) turns out to be a beneficial owner of one of the firms allegedly involved in the DB Mirror Trades.

But it doesn’t end there. Perepilichnyy is also alleged to have been the owner of another company called Quartell Trading, based in the British Virgin Islands. According to a report carried by CNN (http://edition.cnn.com/2017/06/16/politics/russian-mob-syria-chemical-weapons/index.html) this Perepilichnyy owned company was part of a scheme to launder the proceeds of the Hermitage Fund scam conducted against Bill Browder which resulted in the death in a Russian prison of Sergei Magnitsky. This shouldn’t be too much of a surprise as Perepilicnyy admitted to being involved in the laundering of this money prior to turning whistle-blower and working with Browder to expose the plot.

Quartell allegedly transferred at least $900,000 to a company named Balec Ventures Ltd whose address is given in a number of different articles as PO Box 3321, Drake Chambers, Road Town, Tortola. Coincidentally, this is the same address as the two designated members of Countform LLP – Formway Project Corp and Countline Company Inc. The original designated members for Countform were Milltown Corporate Services Ltd and Ireland and Overseas Acquisitions Ltd (remember them) who were replaced after just four months by the firms mentioned above. Countform was dissolved in May 2016. Their last four year’s annual accounts were signed off by Ali Moulae (hooray – yet another different version).

The same article on the Cyprus Business Mail (http://cyprusbusinessmail.com/?p=47034) that gives Balec’s address also cites two more firms which operate from the same location – Maribo and Tredwell Marketing. Intriguingly, there is a Scottish Limited Partnership registered with Companies House called Maribo Inter LP who have two corporate general partners – Hokkaido Invest SA and Okinawa Holdings SA who are based at 7 New Road, Belize City, just a few metres from Milltown and Ireland & Overseas who are at 35 New Road.

Another firm involved in the scheme is given as Nomirex Trading Ltd – a UK company. It was wound up many years ago but a bit of digging unearthed the fact that its original directors were two more corporates – Voilent Trade Limited and Administrative Office Ltd. Voilent is based at Zenon Court, 55 Ptolemeon Street, Office 1, Limassol, 3041, Cyprus (coincidentally, also the address of Scotmax Import Ltd, the designated member for the still active Green Trace LLP based at the same address as Chadborg and Ergoinvest and whose accounts are still being signed off by Ali Moulaye) . According to the Organized Crime and Corruption Reporting Project (OCCRP – https://www.reportingproject.net/proxy/en/russian-laundering-machine) Voilent was itself owned by a firm called Trade Invest Systems Ltd, who (surprise, surprise) are (or were) the designated members for a whole bunch of UK LLPs. They tend to have accounts signed off by… no, not Ali Moulaye but Sabine Boze (or Vickers) another name you will get to hear again later.

So let’s just summarise where we’ve got to so far. Two of the UK firms allegedly used in the DB Mirror Trading scheme had designated corporate members based in Dominica. The person signing off on their accounts appears on a large number of other corporate designated members accounts in a number of different Caribbean islands as well as Cyprus.

One of the beneficial owners of another firm alleged to have been used as part of the Hermitage/Magnitsky/Browder Russian money laundering scheme was also a beneficial owner of one of the DB schemes. He has subsequently died in highly suspicious circumstances (along with Sergei Magnitsky). Oh, and another curious coincidence to throw in here is that there is an allegation that Perepilichnyy was at one point being sued by a company of which Dimitri Kovtun was a director (http://www.telegraph.co.uk/news/uknews/crime/11626368/Russian-supergrass-poisoned-after-being-tricked-into-visiting-Paris.html). Kovtun is alleged to be one of the killers of Alexander Litvinenko.

Let’s take this a stage further. Many national newspapers have carried a story that Perepilichnyy was murdered by a Russian called Andrei Pavlov (https://www.theguardian.com/uk-news/2016/may/10/russian-alexander-perepilichnyy-whistleblower-death-left-uk). Pavlov was subsequently pictured with Natalia Veselnitskaya and Rinat Akhmetshin shortly before the latter two met with Donald Trump Jr and others during the US election at the now infamous, Clinton kompromat meeting (http://www.dailymail.co.uk/news/article-4712384/Two-Russians-met-Don-Jr-pictured-accused-killer.html). Wow!

So that’s the DB Mirror Trade story.

Let’s turn to the Moldovan Laundromat. The Guardian newspaper has been prominent in the UK in carrying details of this story detailing 100s of millions of dollars that were laundered through the global banking system – much of it utilising UK companies. Their story of 20 March 2017 for instance (https://www.theguardian.com/world/2017/mar/20/british-banks-handled-vast-sums-of-laundered-russian-money) carries the names of a couple of UK enterprises allegedly involved. One of them, Ronida Investments LLP is worth a closer look. Its registered office was in Cornwall Buildings, Birmingham (an address you see a lot in these investigations) and the original designated members were Advance Developments Limited and Corporate Solutions Limited, both of Barrack Road, Belize. The accounts for Ronida Invest LLP from 2009 through to 2014 were signed off by Sabine Boze (I did say we’d be coming back to her). Incidentally, the address for both these members is the same as for another firm called Ecoport Express Inc who were the designated member for a UK LLP called IGW Worldwide LLP (their correspondence address is the same as for Chadborg and Ergoinvest, the DB mirror trading companies) and their accounts for 2014 to 2016 were signed off by none other than Ali Moulaye (although in 2013 he was Moulae).

If we head over to Scotland, a whole host of Scottish Limited Partnerships were also allegedly involved in the Moldovan Laundromat, some of which were named in an article in the Scottish Sunday Herald in June 2015 (http://www.heraldscotland.com/business_hq/13414235.The_Moldova_Connection/). The bulk of the companies identified were formed by two corporates called Eurointer AG and Bridgepoint AG whose address is given as Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Mh96960 (which we have already come across and which is home to several companies related to our Mr. Moulaye).

So, to recap, we find the same type of company, signed off by the same few names in both the mirror trades and Moldovan Laundromat. Some of the key players are Russians allegedly murdered, other Russians allegedly responsible for their murders, more Russians who allegedly tried to disrupt the US elections and there is alleged Russian money laundering.

Let’s throw one more interesting tidbit into the mix.

We’ll start with the Independent’s story about Viktor Yanukovych, ousted Ukrainian premier and his alleged laundering of hundreds of millions of dollars (http://www.independent.co.uk/news/uk/crime/exclusive-ukrainian-assets-owned-or-used-by-ousted-president-viktor-yanukovych-hidden-behind-trail-9161504.html). The story names a number of UK LLPs which are alleged to have been involved in the scheme.

First up is Highway Investment Processing LLP. Formed by Milltown and Ireland & Overseas (who we have already met) they were replaced in 2011 by new designated members called Astarta Inc and Pilon Inc who both give their address as 35 New Road, Belize (wouldn’t you know). At least their accounts weren’t signed off by either Mr Moulaye or Ms Boze but a new kid on the block called Manuel Carrera.

Next up is Darton Management LLP, again formed by Milltown and Ireland & Overseas but this time they resigned in favour of Intrahold AG and Monohold AG – remember them? And, of course, their accounts were signed off by Ali Moulaye.

Then we have Bincroft LLP, also formed by Milltown and Irish & Overseas who were subsequently replaced by Oledo Corporation and Oledo Associated who were then, in turn, replaced by Rosario Inter SA (based in Anguilla) and Leinston Holdings Inc (based in Panama). It’s worth having a look at their filings. The accounts for 2012 were filed by Ireland & Overseas Acquisitions Ltd and the person who signed them off was, yes, Ali Moulaye. In 2013 the designated member had changed to Rosario Inter SA but the signature was still Mr Moulaye’s.

The last LLP mentioned in the article is Fineroad Business LLP, who gave the same registered address as Chadborg and Ergoinvest at the very beginning of this article (for the record it is 175 Darkes Lane, Suite B, 2nd Floor, Potters Bar, Hertfordshire, EN6 1BW). They have had a number of designated members over the years, Milltown, Ireland & Overseas, Monohold, Intrahold, Uniwell and Tallberg – all of whom we’ve seen before. And, of course, they have filed accounts signed off by Mr. Moulaye on behalf of Monohold and Tallberg (for the record, Mr Moulaye has also signed off on behalf of Intrahold and Uniwell for other LLPs).

One high profile American linked with Yanukovych and Ukraine is Paul Manafort, currently under investigation by Robert Mueller, Special Prosecutor, for his part in the alleged Russian interference during the US elections. Our only interest here is in a company he set up called Pericles Emerging Partners LP in 2007. According to an article by Luke Harding in the Guardian (https://www.theguardian.com/us-news/2016/aug/16/donald-trump-campaign-paul-manafort-ukraine-yanukovich) the only investment ever made by Pericles was to a Ukrainian telecoms company called Black Sea Cable. From there the money was allegedly funnelled through various shell companies in various offshore locations including one called Cascado AG. Now Cascado AG just happens to be the designated member for a number of UK LLPs, one of which is called Inwestway Star LLP. Set up by Milltown and then transferred to Cascado, its accounts for 2012 to 2014 were signed off by Ali Moulaye. Which brings us right back to where we started.

There are some weird connections throughout this story. Russia, money laundering, Deutsche Bank, and US connections to Donald Trump who, famously, sued DB a few years ago only for them to become pretty much the only firm who would lend to him (and his family) and to who he still owes several hundred million dollars. Three murdered Russians – all connected. Most of the major money laundering schemes of the last few years – all connected. I’m sure some of this is coincidence, but all of it? It doesn’t seem likely. Of course, it doesn’t help that the former CEO of Deutsche Bank (Josef Ackermann is now non-executive chairman of the Bank of Cyprus – a role he was proposed for by Wilbur Ross who is now Donald Trump’s Commerce Secretary.

And here’s a weird thing. Not a single LLP that I have researched has had its own website – or even a web presence. Isn’t that weird in this day and age? Occasionally, during web research, I’ve found a reference to a bill of lading (always from Eastern Europe) but that’s it.

And overwhelmingly, the accounts of these LLPs show that they are either dormant or making little or no profit. How strange.

Many of them are still active and filing current accounts so there is a treasure trove of research out there for identifying potential future money laundering.

And it’s worth noting that, despite the banks always getting the blame for money laundering, there’s a role to play for those who own the central registry, or maybe the National Crime Agency, to mine the data in much the way I have done to try and identify future potential money laundering schemes.

And while I’m at it, does anyone know how much the new transparency regime under 4MLD is going to help if LLPs just use designated corporate members in offshore locations where it is hard, if not impossible, to get a proper understanding of the underlying beneficial owners?

So who is Ali Moulaye (and Ms Boze and others)? Are they international money launderers?

No, I don’t think so.

I suspect they are just poorly paid patsies who have been conned into fronting a whole bunch of shell companies for a fairly meagre reward because, after all, if you were an international money launderer, you wouldn’t stick your name out there for all to see.

Would you?

Ghost Story 2 – Grafting for coal in the Donbas

In our recent Buzzfeed news article tracking down Ali Moulaye and exposing a network of similarly constructed UK Limited Liability Partnerships, we highlighted a few of the more egregious uses of LLPs and I promised to write in more detail about some of them.

In my first article (My name is Bond, Prof Bond) I wrote about a UK LLP which was returning annual commission income of a few thousand pounds whilst having made a number of multi-million pound loans to various Ukrainian energy companies.

Staying with both Ukraine and energy, I want to turn my attention in this article to the rather dirtier and more dangerous world of coal in the Donbas.

It’s dirty and dangerous for two reasons.

One: the Donbas (which is an abbreviation for “Donets Basin” the area of Eastern Ukraine under discussion) has been gripped by internal strife since the March 2014 uprising and large parts of which are now the self-proclaimed “People’s Republics” of Donetsk and Luhansk. Sadly, this has been followed by a litany of allegations of bribery, corruption and mob-style behaviour.

Two: due to a long term lack of investment and modernisation (for reasons we will discuss later) the work is also primitive and very dangerous.

I’m not intending on delving in to the politics of this situation by I am interested in why UK LLPs appear to be integral to some of the entities involved in coal mining there.

But first, let’s take a step back.

A question I am often asked is “Why are UK entities so often at the heart of these money-laundering schemes. And, of course, that’s an excellent question. The answer is a little more complicated and comes in a number of parts.

  1. UK entities are easy to create. You can create one online in minutes and, providing you have a UK registered address (which can be a PO Box or virtual office address) it doesn’t matter where in the world you are
  2. You can designate legal entities as your “designated members” and they can also be registered anywhere in the world – handy if they are in “secrecy locations” which means you can hide the people behind the legal entities
  3. Although you are required to designate a “Person with Significant Control” (i.e. name someone who is in charge) there is no real due diligence around this process and a large number of ways of circumventing the rules – more on that later)
  4. UK entities are viewed with high regard elsewhere. They add credibility to a legal structure
  5. Given all the above, if you were, say, a corrupt politician, who wanted to invest a pile of your corruptly gained money into a large industry so you could cream off the profits but you don’t want anyone to know about it, you can create a UK LLP, make it look like valuable foreign inward investment, hide behind all the elements detailed above and then, because it is a UK entity, open a bank account somewhere else in the world and make it look like you are legally removing the “profits” from your investment when, in fact, you are offshoring your countries hard earned money into a personal account somewhere prior to investing it in, say, high end property in London.

So, with that in mind, back to our story.

Let me say right away that I’m not aligning the story I’m about to relate to all of those factors I’ve just explained, but it’s worth bearing them in mind when trying to understand the specifics of what you are about to read.

In our story, we specifically mentioned a firm called “Renton Resources LLP”. You’ll be pleased to know it’s still going strong having filed its most recent update on 9 September this year. It still has our old friends Tallberg Ltd and Uniwell Inc from Nevis as its Designated Members (both if which are entities that have years of Ali Moulaye accounts behind them, although they have now moved on to Kang Dong-Hee). Unusually, it has actually named a PSC who is identifiably associated with the area in which it operates. Less helpfully, due to the vagaries of transliteration (the process of turning non-western scripts into letters you and I would recognise) the spelling of his name is not consistent.

In Companies House he is recorded as “Oleksandr Melnychuk” although, as can be seen from this article he is more often referred to as “Aleksandr Melnychuk” but also Alexander Melnychuk (see: https://uawire.org/polish-firm-sells-coal-from-donbas-to-italy-and-austria) and Alexander Melnichuk (and the list goes on).

All of which makes the research for someone like me a tad problematic.

By the by, Renton Resources LLP filed accounts on 13 February 2018 as follows:


So what else do we know about this particular LLP?

It has been referenced in a number of articles (see: http://okkupatsiya.net/4641-i-o-glavyi-mintopenergo-lnr-narushaet-zakon/). Intriguingly, one particular article, which has been carried by a number of Ukrainian newaspapers including “epravda” –  https://www.epravda.com.ua/rus/news/2017/08/12/628001/ – have also identified a number of other UK LLPs associated with Mr Melnychuk.

For example (this is from a translated version of the epravda report):


As well as:


So we have a couple more to look at (as well as a hitherto unknown Hong Kong company called “Grecol Ltd”).

We’ll start with the extraordinarily named “British Coal Trade Antrahcit LLP”. It is actually called “Coal Trade Antrahcit LLP” and it was dissolved in December 2017. At the time it was dissolved it had two legal entity Designated Members based (almost unbelievably) in Belize (Trusco Management Ltd and Trusco Secretary Ltd). It’s PSC was Grecol Limited! It did actually return reasonable annual accounts, as per the last set before it was dissolved:


Muskwell Import LLP was dissolved on 18 January 2018. It also had legal entity Designated Members based in Belize (Livorno Holding SA and Verona Inter SA) and a PSC named Ms Liubov Melnicyuk (different spelling of the surname but pronounced the same way as Oleksandr).

Their last set of accounts wasn’t quite so impressive:


There is a bill of lading relating to Muskwell Import LLP available on ImportGenius as the screen grab below shows:


Sadly, we don’t know the currency utilised in this transaction but if we assume it was either roubles or hryvnia (Russian or Ukrainian) 20,475,689.67 equates to £238,404 (RUB to GBP) or £559,881.61 (UAH to GBP) at today’s rates.

Either way, even though this is turnover and not fee income, this one deal makes it look  like Muskwell Import was doing rather more business than its accounts tend to suggest. Particularly as the article above alleges that all the exports from a mine owned by Rinat Akhmetov (who, coincidentally was a friend of the recently jailed Paul Manafort) went through Muskwell Import LLP. Although it should also be noted that Mr Akhmetov has always stoutly maintained the propriety of everything we does and, to date, none of these allegations has been proven.

Let’s see what we can find about Grecol Ltd. It was incorporated in Hong Kong on 22 April 2014 and is listed as “live” on the current registry (source: https://opencorporates.com/companies/hk/2088980). And, other than the mentions in the previously linked articles relating to Coal Trade Antrahcit LLP that’s about it other than the fact that it turns out that Grecol Limited was also the PSC for a Scottish Limited Partnership (I know, unbelievable!!) called Montgowell LP, which was registered on 11 July 2016.

It resigned from the role on 23 October 2017 to be replaced by Mansolution Inc which was registered in Nevis (of all places).

Now, there’s a couple of issues here. Firstly, there is absolutely no sign of Montgowell LP anywhere on the internet. Nor is there for Mansolution Inc.

Nevertheless, the point needs to be made that neither Grecol Limited nor Mansolution Inc are likely to be eligible to be PSCs of a Limited Partnership or a Limited Liability Partnership. The rules state that in order to be a registrable relevant legal entity (RLE) the company must:

  • holds its own PSC register; or
  • is subject to DTRs (disclosure and transparency rules); or
  • has voting shares admitted to trading on a regulated market in the UK or EEA (other than the UK) or on specified markets in Switzerland, the USA, Japan and Israel

Given that neither meet criteria 2 or 3 and there is no suggestion that they have an accessible PSC, it does not qualify as a PSC as it is not possible to ascertain the natural person or persons who own or control the company.

So where does this leave us?

It appears that we have a number of UK LLPs which are involved in the ownership and supply chain for one (or more likely a number) of coal mines located in one of the more politically unstable and problematic parts of central and eastern Europe, their accounts do not tend to match other empirical evidence in relation to their economic activity, the ownership chain is, at least in part, highly obscure and without any apparent economic purpose (why have a Hong Kong company as the PSC of a UK LLP which is operating in some way as part of a Ukrainian Coal Mining concern which has designated members located in Nevis?)

Other than that, it’s all quite straightforward.