Cardvox LLP – A history of incongruous connections

The following article (and underpinning investigation ) was prompted by the output from Caspian’s “Entity Investigator”. It was just one of a large number of entities which were identified as part of a focused piece of work which involved the analysis of multiple publicly available data sources. The reality is that there are thousands more in Companies House waiting to be identified. The scary thing is that the vast majority of these will be banking somewhere in the world and, in all likelihood, a significant number of banks here in the UK and elsewhere, will be providing correspondent services to those banks with which these companies conduct business.

On 6 December 2006, Stan Gorin and Erik Vanagels, two anonymous Latvians, incorporated a new Limited Liability Partnership at Companies House. It was called Cardvox LLP and its history encapsulates many of the elements common to UK entities alleged to have been involved in a number of global laundromats.

Messrs Gorin and Vanagels filed the requisite paperwork on behalf of two legal entities called Ireland & Overseas Acquisitions Ltd (I&OA) and Milltown Corporate Services (MCS), both based in the Yamraj Building, on Market Square, Road Town, Tortola, British Virgin Islands and they recorded the company’s registered address in the UK as 39 Wetherby Mansions, Earls Court Square, London, SW5 9BH.

It’s almost impossible to find a picture of the Yamraj Building in Tortola, but it’s much more straightforward to find one of the London registered office.

UPDATE: Courtesy of Oliver Bullough (of Moneyland fame) I can now also show you the Yamraj Building. Thank you Oliver!

The Yamraj Building – Tortola, BVI
39 Wetherby Mansions

39 Wetherby Mansions is, or has been, home to at least 581 UK companies (438 Limited Liability Partnerships and 143 Limited Companies). Intriguingly, most of the limited companies were formed first and the bulk of them were dissolved just as the Limited Liability Partnerships were being formed – around 2009/2010.

Messrs Gorin and Vanagels, along with I&OA, MCS and this address were subsequently to become infamous as the names and location behind hundreds, if not thousands, of entities which were caught up in stories of money laundering, sanctions breaking, fraud and other financial crimes. For instance the International Consortium of Investigative Journalists (ICIJ) wrote about them here, and the Organised Crime and Corruption Reporting project (OCCRP) wrote about them here.

Cardvox LLP filed its first set of accounts for the year ending December 2007 in early 2008. Signed by Mr Vanagels, they showed commission income of £29,000. By the time they filed them, they had also moved office, to an address in the leafy outer London suburb of Elstree, home to another 2,450 companies, nearly a thousand of which were LLPs like Cardvox.

Over the next few years, Cardvox continued to file accounts signed by either Gorin or Vanagels for sums ranging between £10,000 and £30,000. I&OA and MCS both relocated from BVI to Belize and occupied an office in New Road, Belize City.

In 2011, I&OS and MCS resigned as designated members, making way for Monohold AG and Unihold AG. Don’t be fooled by the AG suffix though, these are not Germanic Joint Stock companies but private companies registered in Mahe, Seychelles. Several hundred other UK LLPs also changed designated members from I&OS/MCS to Monohold/Unihold over the course of 2011. The change also brought about a change of account signatory, first (for the 2011 accounts) fellow Latvian Juri Vitman, followed in 2013 (for the next five years) by Ali Moulaye who, while not being Latvian himself, is married to one and, at the time, lived in Riga.

The changes of location, members and signatories did not significantly change the company’s activity with annual commission income still showing as being between a maximum (in 2015) of £13,599 down to a mere £6,849 in 2018. And this was accompanied by a further change of designated members (along with 100s of other LLPs – again) to Uniwell Inc and Tallberg Ltd both registered to the island of Nevis in the Caribbean.

It would be a fair observation at this stage to consider this to be quite a lot of expensive looking administrative effort for a company which doesn’t appear to be making much money. After all, it has now had three separate sets of designated members based in Belize, Seychelles and now Nevis. It’s also had many different account signatories who are either Latvian (Vitman, Vanagels, Gorin) or married to a Latvian (Moulaye).

Of course, the other thing this company is required to do is register a Person with Significant Control (PSC). His name is Alexander Burmistrov, a 63-year old Russian who gives his address as 11 Fabrichnaya Ulitsa, Pushkino, Russia. 11 Fabrichnaya Ulitsa turns out to be the end house on a small unmade road in the Pushkino district in the northern suburbs of Moscow.

11 Fabrichnaya Ulitsa, Pushkino, Moscow

Let’s do a quick recap. Cardvox LLP began life in 2006, registered to an address in a mansion block in Earl’s Court, London. It had members based first in the British Virgin Islands but who subsequently moved to Belize. They resigned in favour of two more in Seychelles, who also resigned in favour of a third set in Nevis. Their accounts are signed mainly by Latvians or persons associated with Latvia and the person who they say controls the company lives in Russia although I’ve been unable to find any connection between him and the company he controls.

And their accounts suggest that they don’t make much money.

What else do we know about them?

They appear in the Russian Laundromat report by the Organised Crime & Corruption Reporting Project (OCCRP). According to information obtainable from the OCCRP website, Cardvox LLP received four payments across a period of eight days at the end of March/beginning of April 2013 totalling just over a million dollars. This is something of a contrast to the accounts for the year ending 31 December 2013 (signed by Ali Moulaye) which simply declare a commission income of £10,817. The commission income was paid to the company for their role as a trade agent for cars, automotive spare parts and equipment which is in contrast to the payments that were variously labelled for “Building Equipment (Pumps)” or “technological equipment” (no mention of cars or automotive parts).

That Russian Laundromat story first appeared in the press in 2014 but was more fully reported in March 2017 after a detailed database of transactions was made available to journalists (and a slightly less comprehensive one made available to members of the public) which contained information about Cardvox LLP and the money it received. Which, incidentally, was paid into their account with ABLV Latvia from the payees account with Trasta Komercbanka of Latvia.

The fact that the company was named as a participant in the Russian Laundromat and received payments substantially in excess of what had been reported in their company accounts didn’t halt the company’s activity.

On 26 September 2017 Cardvox LLP invested €1,422 into a Latvian company called TRI-3M SIA plus a further €123,789 into a company called TILIA-A SIA. On 7 December they received a refund of the €1,422 invested into TRI-3M but, slightly oddly, invested a further €111,422 into the same company. On 7 December 2017 they invested a further €382,511 into TILIA-A SIA. On 15 November 2018, they received back their €111,422 investment into TRI-3M SA but, so far as is ascertainable, the total investment of €506,300 into TILIA-A SA remains. There is no mention of any of this investment activity in the Cardvox annual accounts for either the year ended 31 December 2017 or 31 December 2018, nor does the outstanding investment of over €500,000 into TILIA-A SIA appear in their balance sheet as a current asset.

The oddities don’t just end there though. TRI-3M SIA gives it’s address in Latvia as Ezera Iela 22, Riga (in the Riga Free Port zone). This is the same address as a company called Vega Stividors SIA which appears, briefly, on the S&P Panjiva market intelligence website (see below).

For information, “po porucheniyu” means “on behalf of” so these trades were being done on behalf of these two UK LLPs.

Import Genius also reveals one more entry mentioning Cardvox.

Using Google translate reveals that the Russian Company is called Delfin Distribution LLC, the consignor was SIA AAMG on behalf of Cardvox LLP, the consignment was, apparently Glycerine and the producer is, allegedly, a long-established Argentinian company. Intriguingly, an early investor in TRI-3M SIA was a company called Delfin Investment which, according to Lursoft, operates from the same address as TRI-3M.

Returning to the Panjiva information, Centrosource LLP has very similar characteristics to Cardvox. It was formed slightly earlier (February 2005) by I&OA and MCS and registered to 39 Wetherby Mansions with paperwork signed by Gorin & Vanagels. It changed to Intrahold and Monohold in December 2011 and then to Tallberg and Uniwell in December 2014.  Its annual accounts are very similar to those of Cardvox and they are signed by the same people (Vanagels, Vitman, Gorin, Moulaye).

The only appreciable difference is that their PSC is a 51-year-old Russian called Ruslan Dobrovolskiy who lives at 16 Akademika Arcimovicha Street, Apt. 291, Moscow. I believe this is also known as Ulitsa Akademika Artsimoviha, a street in the Konkovo district of Moscow.

And what of Vega Stividors who claim to do business on behalf of Cardvox and who share their address with TRI-3M SIA into which Cardvox has invested? They have a website at which explains that they specialise in stevedoring services as well as shipping and producing car oils and technical liquids. But there’s no mention of Cardvox, Centrosource, TRI-3M or TILIA-A.

However, Lursoft also provides telephone numbers for both TRI-3M and TILIA-A (+371 29485672 and +371 67345801 respectively).

A Google search reveals that +371 67345801 (TILIA-A) also comes up as the phone number for Euro Delfin Industry SIA of Ezera iela 22, Riga, Latvia (the same as TRI-3M even though TILIA-A gives its address as Bitenu iela 10A, Aizkraukle, Aizkraukles novads, Latvia). It also comes up as the number for VIVVA M, SIA also at Ezera iela 22.

VIVVA M SIA was named in a lawsuit in the US in May 2016 alongside Delfin Group USA LLC in an action against a former officer of Delfin called Markos Baghdasarian who was found guilty in 2012 of violating international sanctions by making illegal imports to Iran. Delfin Group is a speciality motor oils and lubrication company, much like Vega.

+371 29485672 (TRI-3M) comes up as the number for LB Omega of Salaspils county, Salaspils par., Saulkalne, Daugavmalas street 38 as well as for Euro Delfin Industries (again).

And there we have it. A story full of connections to allegations of money laundering, laundromats and other illicit activity.

A story full of connections both here in the UK and over in Latvia.

Without access to the bank records, it is difficult to know exactly what is going on. But these companies bank somewhere in the world, so someone, somewhere does know.