Details, dealings and discoveries – further adventures in LLP Land

What are we up to now then?

We! It’s me that does all the hard work. You just come along at the end and ask lots of questions.

But that’s the most important bit.

How do you work that out?

Because it’s my questions that help all the people reading understand what you’re trying to say. You know you have a tendency to get all technical, and I force you to write things simply and logically.

Are you saying that all my readers are simple?

Not at all. I’m saying they don’t have time to delve into the ins and outs of all the deeply technical stuff so we need, between us, to make all this accessible.

Fair point.

So what is this one all about?

It’s the results of a recent investigation I did which is intriguing, even if I can’t quite say what exactly is going on.

What prompted it?

I’m not entirely sure you’d believe me if I told you.

Try me.

Ok. Every now and then I like to see what new legal entities have been registered at Companies House to see if any interesting trends or developments are emerging.

That seems eminently sensible to me.



Thanks for that. I thought I was being a tad eccentric.

Given you’re creating a bit of an audience for this stuff, it makes sense to try and stay one step ahead. Now, what was it you found?

Well, on 27April 2018, a new Limited Liability Partnership was registered at Companies House. It was called Allia Systems LLP at Suite 6, 5 Percy Street, London, W1T 1DG. An address I know quite well.

Is it one of “those” addresses?

It is.

What was it, other than the address, that aroused your interest?

The LLP has two designated members, Cezara Limited and Iveda Business Inc, both at a well known offshore address in Belize (Blake Building, Corner Eyre & Hutson Streets, Belize). Their registration numbers in Belize were consecutive (161383 and 161384) indicating that they had both been formed at the same time.

It had declared a Person with Significant Control, Sergii Varyvoda, a resident of Ukraine but with a correspondence address as above.

I googled Mr. Varyvoda and the only information I could find was the fact that he was the Person with Significant Control of three other U.K. entities.

·        Regato Ltd – Director: Alfred Victor Brewster, PSC: Sergii Varyvoda

·        Kulberg Trading Ltd – Director: King Howard Cordero Enriques, former director: Ian Taylor, PSC: Sergii Varyvoda

·        Kulberg Int. Trading LLP – Designated Members: Cezaro Ltd/Iveda Business Ltd – PSC: Sergii Varyvoda

Plus the related:

·        Kulberg Investors Ltd: Director: Hema Noronha, PSC: Convex Credit Ltd (about which I have since written – Are they taking the PSC?)

Of the four, Kulberg Int. Trading LLP looked most interesting as its officers are also identical to Allia Systems LLP, so I decided to Google it.

Here is the first of the hits I found.

Matios appears to be a high ranking military prosecutor in Ukraine who has connections to a firm called “Polyexpo” which apparently is a grain exporter

Ukraine. We always end up somewhere in Eastern Europe. It’ll be “that man” again in a minute.

I know what you mean but this was quite an interesting story. For example, see:

Then there’s this:


Isn’t Petro Poroshenko the current president of Ukraine?

Yes, so Kullberg Int. Trading LLP links the Matios story with Petro Poroshenko which makes it even more interesting. He also has a chocolate company called “Roshen” which makes very nice chocolate and provided the inspiration for the cover picture.

More seriously, I don’t think either story has been picked up by the U.K. press even though, as it explains in the article, a number of U.K. entities are involved. Unbelievably, one of them (Brightmill Solutions LLP) is registered at 175 Darkes Lane, Potters Bar. Here is a copy of their accounts:



No, no, no, no, no. It can’t be that every single story you write ends up connecting with this man. Are you sure you’re not starting with his signature and back engineering the story.

Nope. There’s just always a connection. Here’s another interesting link: (Bill of lading record)

This suggests that Kulberg Int. is being used as a “shell” company to bill shipments into and out of Ukraine. It also used to be registered to the same address as Allia Systems but moved, in 2016 to a new address, 26 York Street, W1U 6PZ.

Where did you go from here?

I was interested to understand if there were any further connections (other than sharing a PSC and Designated Members) between Allia Systems LLP and Kulberg Int. Trading LLP so I looked up Allia Systems on Open Corporates. I quickly found one other company called “Allia Systems Ltd SA” registered in Panama.

Well that’s quite a coincidence!

Hmm. A google search of Allia Systems Ltd SA” throws up an Import Genius page showing a shipment of “granulated sugar wheat” from the “State Food and Grain Corporation of Ukraine” to ALLIA SYSTEMS LTD., S.A, Av. Ricardo J. Alfaro The Century Tower , Office 713, Panama City, Panama.

Other link:

Ok. Well that all looks very like they’re connected in some way. And the others?

There is very little online about Regato Ltd.

Kullberg Trading Ltd (according to Open Corporates) maintains a branch in Cyprus.

Here’s a link toa deal in Latvia:

There are details of a charge for a trade finance deal on Companies House which was satisfied by Oleg Khaladzhy, Donetsk, Ukraine. He is also associated with Kulberg Finances Inc, which is a Delaware registered US LLC.

Kulberg Investors Ltd used to have a branch in Kazakhstan:

However it now appears to have closed.

UK Companies quoted in Matios story (translated from Ukrainian) taken from the link above:











What do we know about them?

Without boring you with the details, the main connections I can find are either with Eastern Europe or Turkey (of which there are quite a few) which makes sense as, again according to the article quoting all the LLPs, Turkey was one of the main recipients of the grain exports.

Anything else?

There are some real oddities. According the article (and there’s no way that I can check this) between 2013 and 2017 Brightmill Solutions LLP (which was dissolved in 2015) received UAH26,622,000 from Ukrainian company “Polyexpo” and, in the same period, they received UAH 12,273,000 from Ukrainian company Ampir Ltd. In total that’s almost UAH 39,000,000 which equates to about £1.12m. Brightmill only filed accounts for 2012 and 2013 (both signed by our old friend Ali Moulaye) which show commission income for 2012 of £2,312 and for 2013, £13,156 so there’s quite a discrepancy there.

And then it was dissolved?

Yes. Same for Lyndale Consulting LLP. Filed accounts for 2014/15/16 of £3,112, £2,820 and £3,020 although I suspect they were not entirely reflective of the true situation.

Why do you say that?

Have a look:


 That’s actually quite funny in a depressing sort of way.

 At least the allegation is that they only invoiced £172,000 through Lyndale.

Oh, that’s all right then.

 Hmm. And then there’s Feedsen Commodities LLP. Absolutely nothing suspicious about their accounts.

Are you being sarcastic?

Take a look for yourself.


Oh dear, Oh dear, you were being sarcastic!

It’s the only way I know to deal with all this.

How would yo summarise all this?

 I’m not really sure. There are unproven allegations of financial machinations in Ukraine that may or may not be illegal. They involve the country’s president so it’s a pretty serious allegation (although it hasn’t been picked up on by the press here in the west as far as I can see). And there are clearly links and issues with the filings of some of these LLPs and the strange commonalities between UK entities and those registered elsewhere.

It would be fascinating to see where some of these UK LLPs banked and what the actual throughput of money was, wouldn’t it?

 Oh yes.