Are they taking the PSC?

You’re back for more are you?

Well that chat about RLEs was so interesting I’m ready to tackle PSCs!

Was that sarcasm?

Might have been…

Then you can Bogof!

I beg your pardon?

Bogof. Buy one get one free. I’ve found a great example to explain some of the idiosyncrasies of PSCs as well as some anomalies relating to directors.

You like anomalies, don’t you?

I think you learn more from things that aren’t quite right than things that are perfect, yes.

So, what’s this example then?

It’s a company called Kulberg Investors Ltd.

Why is it so interesting?

It’s quite a long story.

That’s ok, I’ve got plenty of time and you’re a good storyteller.

I see. We’ve gone from sarcasm to flattery, have we?

Might have…

OK. Let’s start with some basic facts.

Kulberg Investors Ltd was formed on 28 April 2006 and is still active.

It’s been around a while then?

It has, and it’s been through quite a number of changes in that time.

For a start, it’s had ten different directors.



Here they are:


Wow! There’s a lot of countries represented there.

There are. And no obvious reason why. I’d call that a red flag, wouldn’t you?

I think so. Are they making a huge amount of money?

Let’s have a look at their account filings. Here’s 2007

2007 accounts

That’s not a lot. And do you really pay corporation tax on a profit of £645?

I’m not an accountant so I can’t say for sure. Possibly.

Should we look at 2008?


2008 accounts

OK. Well they’ve gone up. Here’s the rest.

2009-10 accounts
2011-12 accounts
2013-14 accounts
2015-16 accounts

So they’re not exactly setting the world on fire., are they?

That’s one way of putting it.

Before we look at their Person with Significant Control, let’s have a look at their current sole active director shall we?

Is that the Indian lady in the last line of your table?

It is. How well do you know India?

Not that well. Where’s Chikmagalur district?

In Karnataka, which is probably best known as the home state of Bangalore (or, more properly, Bengaluru).

And Koppa region?

According to the latest Indian Census ( ) Koppa is a sub-district of Chikmagalur with 84,882 inhabitants – 41,746 males and 43,136 females.

That’s not a lot. And Yelemadlu?

This is where things start getting a bit more confusing. There’s a village in Chikmagalur called Yelamadalu which has to be the one referred to here. According to the latest census has the population of Yelamadalu at 2117.

That’s a strange place to find a director of a UK limited company?

Even stranger when you discover she’s the director of 126 UK companies.

I didn’t see that coming!

No, me neither. And the latest appointments relate to 23 May 2018 so some of them are very recent.

Does she really exist?

You’re getting as cynical as I am. Yes, I think so. At the very least I’ve found a Facebook page (although I think it would be unfair to publish it in this article) which looks entirely genuine and which carries birthday congratulations at exactly the same point in the year that her Companies House details suggest is correct, so… yes, I think she’s genuine. I’m less sure about the address though.


Because the pincode (577118) is not for Yelamadalu, it’s for either Durgadabetta or Herura. The pincode for Yelemadalu is 577123.

You know a lot about Indian Pincodes.

I didn’t, but I know how to use the internet! Sadly, Google Street View hasn’t made it here and the satellite imagery shows a very rural setting so I can’t add much more than that.

I still can’t work out how she came to be the director of over 100 UK companies.

Me neither. Especially as she followed hard on the heels of a Latvian and a Korean along with legal entities from Northern Ireland, Ireland, USA, Hong Kong, Dominica and Nevis.

Can we look at the PSC now?


And it is… (drum roll)…


But that’s not a person, it’s a Relevant Legal Entity.

Very good. But the point here is that because it is a RLE we can follow the trail to the PSCs of Convex Credit Ltd.


So the first thing we find is that Convex Credit Ltd is a Designated Member to 56 LLPs. That means there’s a good chance it is also their PSC but sadly we can’t yet search Companies House specifically for PSCs so I can’t tell you for sure or if it is PSC to other Limited companies.

56 LLPs.. It must be very important.

Hmmm. It was incorporate on 28 February 2014.

Convex Credit

Up until 2016 it filed dormant accounts but then in 2017 (after being appoint PSC to all those entities) it returned:

CC Accounts

That doesn’t actually tell you much, does it?

No, not really. Let’s see who their Directors and PSCs are.

OK. Current director is Gracieili Marian Morales from Panama.

And their PSC is:


Oh dear.

That must mean that it has shareholders who own 25% or less of the company. Let’s see who they are.

CC Shareholders

It’s just another bunch of legal entities. Wait a minute! How do we know that the same person doesn’t own 100% of each one of those entities?

Now that is an excellent question which is why we need to carry on looking behind these entities to see who does own them. Let’s see where they are all registered.

According to Companies House, Wiltron Nordic LP and Sidney Transit LP are both Limited Partnerships. Sadly they are not subject to the PSC regime but let’s have a look anyway.

Here’s Wiltron Nordic LP

Wiltron Nordic PSC

So they don’t need to file a PSC statement?

No, they just need to register a general partner and limited partner. As it’s doesn’t have legal personality, it is not obliged to do anything else. Although there is one interesting thing there.

What’s that?

Hillmont Inc. Logoform Inc. I know them. See:


Ali Moulaye! There’s always a connection to Ali Moulaye or Moulae.

There is. We should play “degrees of separation” one of these days. As in “Name a laundromat scheme and then see how many degrees of separation there is between the laundromat and Ali.”

I already know that the Moldovan and Azerbaijani schemes score 1.

Shall we move on?

Yes. So Wiltron Nordic has two partners who, incidentally, are both based in Nevis so we won’t find out anything more about them.

And Sidney Transit LP?

Well that’s a Northern Irish Limited Partnership so still no PSC requirements.

Sidney Transit

So, do you recognise Sidney Transit’s partners as well?

I sure do!


Oh yes.


That’s ridiculous. And a Moyllae to add to the list.

That’s one way of putting it. Now, we’ve got three more entities to track down. Luxhold Ltd, Webholm Merchants, Limited Partnership and ETG Federation.

I can help with one, straight away.

Ali Moullaye

Now you’re taking the…

PSC? Exactly. Although five Ali Moulaye’s, or Moulae’s or Moullaye’s or Moyllae’s in one article is some sort of record.

Now for the other two. The only thing I can find for ETG Federation is this:

ETG Federation

Nothing else?

Absolutely nothing.

And Webholm Merchants Limited Partnership?

Only from another Companies House filing. They are general partner for Fortshield Inter LP. Here’s a copy of the filing.


And nothing relating to that address in Calgary?

Only that it appears to be a correspondence address. And I’ve seen it before in relation to other investigations that I can’t (yet) publish.

Do we know anything about what Kulberg Investors Ltd actually does.

We can have a look.


Right. I’ve had a look. They appear to be a construction company based in Kazakhstan.

Of course they are. And anyway, there’s always a link to somewhere near Russia. What makes you think this?



So if I’ve got this rightKulberg Investors Ltd has a branch in Kazakhstan although their accounts show minimal financial activity, a director who lives in rural India, a Person with Significant Control which is an entity with five shareholders who are themselves entities based in Canada, South Africa, Northern Ireland, Seychelles and London and they’ve had previous directors from Latvia, South Korea, Northern Ireland, Ireland, USA, Hong Kong, Dominica and Nevis, and Ali Moulaye is linked to five of them. And Companies House somehow considers this unexceptional?.

Er… yes..

And this PSC regime was going to open up our corporate world to proper inspection and stop criminals in their tracks – not that I’m suggesting for a minute that this particular case is criminal.

That was the expectation. Although, to be fair, we can now dive into the detail and write these reports.

Maybe. But wouldn’t it be better to have a system that stopped it happening in the first place.

I don’t think I’m the right person to answer that question.

How much worse could this be?

You wait until you see the next two articles.


Yes. Kulberg Investors Ltd is not the only UK entity to have the word Kulberg in its name. So I thought I’d write about the others.

Others! Plural?


Really? And the other article?

It’s about companies who are declaring real human beings as their shareholders under the PSC regime.

That’s better!

You’d like to think it was, wouldn’t you.

You said that in a way that makes me think it isn’t.



As I was about to publish this article I noticed that there was another limited company called Hillson Division Ltd that had some uncanny resemblances to Kulberg Investors, such as:

1.      Formed on the same day (28 Aprll 2006)

2.      Company number almost identical (05799480 vs 05799483)

3.      Exactly the same 10 directors appointed/retired on exactly the same days

4.      Exactly the same PSC (Convex Credit Ltd)

5.      Almost identical account

We’ve been here before haven’t we?

Yes, my article “Spot the difference” was about this point. I didn’t expect to come across another example quite so soon though. And it gets worse.


Yes, it’s one thing to have almost identical UK legal entity filings (and not a good thing) but what do you make of this?

Toplink Hillson
Toplink Kulberg

Where did they come from?

They’re screen shots from a website called (see: and

So these two companies were formed the same day, have had the same directors, the same PSC, filed the same accounts, have the same branch address in Kazakhstan and even have the same head?

It would appear so.


I have no idea…