Or Hiding in plain sight – the continued abuse of UK LLPs
GEEK ALERT – this is a long and, to those who are not really into complex investigations, rather nerdy look at what is hidden in plain sight amongst the filings for UK LLPs. I make no apology for this as I am a self-confessed Geeky Nerd (or should that be Nerdy Geek?)
What would I like to happen next as a result of this article?
A couple of things really.
1. To maintain pressure on the UK government to significantly improve due diligence on these registrations and filings. I believe the way forward is to make it mandatory to have a UK registered DM or Director, preferably tied to a Government Gateway account number which are well verified and link to HMRC.
2. I would love it if any of my readers working in banks across the world recognised any of the LLPs mentioned below as customers and knew that the account filings were completely out of whack with the actual account activity. If anyone wants to get in touch, please message me and I will forward my Signal credentials for a more secure conversation.
This is too important to let go!
So…
As a consequence of the sequence of articles I’ve written about the role of UK LLPs in money laundering, a few people have been in touch to ask whether I am being highly selective in what I present in these articles.
So I thought I’d do a little experiment which anyone else can copy from the comfort of their own homes with just a computer and an internet connection.
There are a whole host of offshore companies that are used to play the role of designated members of UK LLPs but, given that our good friend Ali Moulaye has been something of a constant companion throughout this journey, I thought I’d select one with which he has been associated, so our experiment will be looking at LLPs which have Formond Inc as one of its designated members.
If you put “Formond” into the search field at the https://beta.companieshouse.gov.uk/address, and then select the “officers” option, you will be given a list of 615 matches, the first 400 of which (20 pages) will be available for viewing.
I’m going to work through the matches on the first page (20), in order, one at a time, and see what I can find out about them. If you want, you can play along at home as you should be able to replicate my results exactly.
But there’s one thing I’d like to point out right away. Since publishing my previous article (https://www.linkedin.com/pulse/who-ali-moulaye-why-does-matter-graham-barrow/) it is very interesting to note that Mr Moulaye has stopped signing accounts on behalf of all these strange LLPs and appears to have handed on the baton to someone variously named as Kang Dong-Hee, Dong-Hee Kang or Dong-Lee Khan. Hence the title of this article.
So, apart from the selection of Formond, the rest of this investigation is in the lap of the gods.
The first link is for a company called:
1. MEGAWEST IMPEX LLP
It was incorporated on 24/06/2010 and dissolved on 28/11/2017.
It’s designated members (DM) at the time of dissolution were Formond Inc and Primecross Inc, both of the Marshall Islands.
There was no Person with Significant Control (PSC) recorded.
They had filed accounts for the years 2011 through to 2016, all but one of which were signed by Ali Moulaye.
Commission income for each year was as follows:
2011: £2,933
2012: £3,827
2013: £4,579
2014: £4,017
2015: £5,176
2016: £3,671
Let’s do a search on Google (using quotation marks to limit the results hence “Megawest Impex”.
The first page is all corporate registry returns but, on page 2 we get:
1. Megawest Impex Llp – Buyer | Russia | Import Genius
Followed by:
2. Megawest Impex Llp – Buyer | Ukraine | Import Genius
Let’s follow both these links and see where they take us.
They are both Bill of Lading details. The first, in Russian (you’re going to need Google translate for this) dated 18/5/2015 says that the origin country was Russia, the destination was Cape Town, the net weight of the cargo (which appears to be colouring for animal foodstuffs) was 22050 kg and the value of the consignment was $US6007.38.
The second link is also a Bill of Lading dated 18/2/13. The originator is a company called “In-baby LLC” from Kiev, Ukraine and the cargo appears to be 20438kg of coriander valued at 119723.15 although no currency is specified.
And that’s about it.
Next up is:
2. POLYGRAFSPECTR AZIA LLP (OC313863)
Not your average LLP name!
It was incorporated on 25/06/2005 and dissolved on 28/11/2017 (same day as Megawest Impex LLP).
DM – Formond and Primecross.
No PSC
Accounts filed for 2006 to 2016. From 2011 (signed by Ali Moulaye) they were:
2011: £10,018
2012: £9,959
2013: £10,234
2014: £10,756
2015: £4,925
2016: £5,528
Google search for “Polygrafspectr Azia” yields:
Page 1 – all corporate registry entries
Page 2:
1. Ywds Korea Co. Ltd On Behalf Of Polygrafspectr Azia Llp
Which appears to be the delivery of a 3 phase motor from Korea to Moscow.
And then there’s
2. http://mozdocs.kiev.ua – registrar for the Ministry of Health in Ukraine
Register of Polygrafspectr Azia as a supplier of printing colours
Next:
3. CRUISE NAVIGATOR LLP
Incorporated on 02/09/2005 and dissolved 21/11/2017 (seven days before Megawest and Polygrafspectr).
DM – Formond and Primecross
No PSC
Accounts filed from 2006 to 2016. From 2011 (signed by Juri Vitman or Ali Moulaye) they were as follows:
2011: £10,224
2012: £14,357
2013: £20,879
2014: £23,041
2015: £14,546
2016: £17,106
Google search:
Nothing until page 3 and then it is mentioned as a debtor in the accounts of JSC MoscowTourist Fleet (http://otc-new.rbc.ru/documents/37818.doc)
Next:
4. LEXINGTON UNITED LLP
Incorporated on 23/07/2005 and dissolved on 21/11/2017 (you get the picture!).
DM – Formond and Primecross
No PSC
Accounts filed from 2007 until 2016. From 2011 (signed by Juri Vitman or Ali Moulaye) they were:
2011: £8,128
2012: £3,784
2013: £2,946
2014: £6,359
2015: £13,128
2016: £7,237
Google search yields nothing.
5. INVESTBOARD LLP
Incorporated on 15/08/2007 and dissolved on 23/01/2018.
DM – Formond and Primecross
PSC – Oleg Lifanov, 21/3, Timoshenko Street, Apt. 65, Kiev, Ukraine, 04205
Accounts filed from 2008 until 2016. From 2011 (signed by Juri Vitman or Ali Moulaye) they were:
2011: £7,364
2012: £0
2013: £0
2014: £0
2015: £5,190
2016: £2,984
Google search yields:
On page 1 a link to a Facebook page (https://www.facebook.com/Investboard-LLP-456790497839976/) from December 2015. Which in turn links to a website (www.investboardonline.com) which is no longer available. And that’s it.
6. DINHOLD SALES LLP
Incorporated on 07/06/2006 and still active!
DM – Formond and Primecross
PSCs – Georgii Terzilev, Lvovskaya Str.68, Odessa, Ukraine
Rima Gochiashvili, Vazha Pshavela Avenue 3, Apt. 19, Tbilisi, Georgia
Accounts filed from 2008 up to date. Accounts (for consistency) from 2011 until 2016 signed by Juri Vitman or Ali Moulaye)
2011: £17,333
2012: £24,741
2013: £4,641
2014: £4,530
2015: £5,180
2016: £5,740
Accounts for 2017 (dated 11/2/2018) were signed by our newcomer – Kang DONG HEE
Google search yields nothing other than that there is a similarly named Scottish Partnership called Dinhold Transit LP, registered at an address known to be associated with “problem” SLPs – 1/2 35 Taits Lane, Dundee as well as another LLP called Dinhold Ventures LLP which never got further than incorporating before being struck off.
N. B. There is another article that needs to be written (and I will) about duplicative naming of LLPs and LPs as a way of obfuscating the investigative trail.
7. GOLDPRIME MANAGEMENT LLP
Incorporated on 24/07/2008 and dissolved on 06/03/2018(!!)
DM – Formond and Primecross
PSC – Mykola Bogdanov, 8 Shumskogo Street, Apt. 284, Kiev, Ukraine
Accounts filed from 2010 until 2016. Accounts from 2011 until 2016 (signed by Juri Vitman or Ali Moulaye)
2011: £6,657
2012: £6,005
2013: £4,935
2014: £4,276
2015: £11,108
2016: £6,831
Google search yields nothing.
8. UNOMARK UNIVERSAL LLP
Incorporated on 24/06/2010 and dissolved on 28/11/2017.
DM – Formond and Primecross
PSC – None
Accounts filed from 2011 until 2016. They were signed by Juri Vitman or Ali Moulaye and were as follows:
2011: £2,637
2012: £3,400
2013: £4,748
2014: £5,527
2015: £6,563
2016: £7,028
Noticing any patterns yet?
Google search yields at least one bill of lading in respect of a Lithuanian company.
9. WESTFOLK IMPEX LLP
Incorporated on 21/06/2010 and dissolved on 28/11/2017.
DM – Formond and Primecross
PSC – No
Accounts filed from 2011 until 2016. They were signed by Juri Vitman or Ali Moulaye and were as follows:
2011: £14,091
2012: £10,948
2013: £12,570
2014: £8,917
2015: £6,846
2016: £6,290
Google search yields nothing.
10. NORDLOGIC LLP
Incorporated on 06/07/2010 and dissolved on 21/11/2017.
DM – Formond and Primecross
PSC – No
Accounts filed from 2011 until 2016. They were signed by Juri Vitman or Ali Moulaye and were as follows:
2011: £2,116
2012: £2,137
2013: £12,554
2014: £14,228
2015: £17,096
2016: £17,582
Google search yields:
A recommendation on the website of KazMunayGas-Aero (https://glavportal.com/materials/kazmunajgaz-aero-dat-energiyu-krylyam/).
A mention in the accounts of a Russian Airline Company.
11. LUXHOLM INDUSTRIES LLP
Incorporated on 29/08/2008 and dissolved on 06/02/2018.
DM – Formond and Primecross
PSC – Alexander Domrachev, 47 Novocherkassky Boulevard, Apt. 169, Moscow, Russia
Accounts filed from 2009 until 2016. For 2011 until 2016 they were signed by Juri Vitman or Ali Moulaye and were as follows:
2011: £4,423
2012: £4,392
2013: £4,610
2014: £4,411
2015: £5,190
2016: £5,840
Google search yields:
A Danish company (Westholm K/S) is between 90% and 100% owned by Luxholm Industries LLP.
12. INVESTBIO LLP
Incorporated on 29/08/2008 and dissolved on 06/02/2018
DM – Formond and Primecross
PSC – Irina Shlyam, 47 Via Brattas, St. Moritz, 7500, Switzerland
Accounts filed from 2010 to 2016. For 2011 until 2016 they were signed by Juri Vitman or Ali Moulaye and were as follows:
2011: £5,311
2012: £6,865
2013: £5,457
2014: £5,451
2015: £2,825
2016: £2,325
Google search yields:
A Bill of Lading for a sale of pharmaceuticals valued at $US81,316 originating from Moscow.
13. ELECTRA LOGIC LLP
Incorporated on 28/07/2007 and dissolved on 05/12/2017.
DM – Formond and Primecross
PSC – No
Accounts filed from 2008 to 2016. From 2011 until 2016 they were signed by Juri Vitman or Ali Moulaye and were as follows:
2011: £1,553
2012: £1,734
2013: £1,667
2014: £1,538
2015: £1,064
2016: £1,448
Google search yields no useful results.
14. FONDTRANS LLP
Incorporated on 13/07/2007 and dissolved on 21/11/2017.
DM – Formond and Primecross
PSC – No
Accounts filed from 2008 until 2016. From 2011 until 2016 they were signed by Juri Vitman, Ian Virel or Ali Moulaye and were as follows:
2011: £14,858
2012: £24,088
2013: £11,240
2014: £7,598
2015: £8,036
2016: £9,134
Google search yields:
A Russian court judgement between Fondtrans LLP and a Russian company called SwarMetiz.
15. PRESTONEX LLP
Incorporated on 26/07/2007 and dissolved on 21/11/2017.
DM – Formond and Primecross
PSC – No
Accounts filed from 2008 until 2016. From 2011 until 2016 they were signed by Juri Vitman, Ian Virel and Ali Moulaye and were as follows:
2011: £10,000
2012: £5,096
2013: £5,264
2014: £5,000
2015: £5,000
2016: £5,000
Google search yields no useful results.
16. PRIMELINE UNIVERSAL LLP
Incorporated on 25/08/2010 and dissolved on 28/11/2017.
DM – Formond and Primecross
PSC – No
Google search yields no useful results.
17. TARGETA MERCHANTS LLP
Incorporated on 10/05/2011 and still active.
DM – Formond and Primecross
PSC – Wallingford Projects Ltd. Notified on 01/07/2016. Current shareholders are:
· 230 LNX Capital LP
· 170 Lordhouse Developments LP
· 190 Cliffmount Properties LP
· 200 Vectorex Inc
· 210 ETG Federation
Wallingford Projects is the PSC for 19 LLPs. They are:
1. Fineburg Sales LLP (DMs – Tallberg and Uniwell – Nevis, A/Cs signed by Ali Moulaye)
2. Goldhill Commerce LLP (Bondwest AG and Entervox AG – Marshall Islands, Kang Dong-Hee and Ali Moulaye)
3. Targeta Merchants LLP (Formond and Primecross – Marshall Islands, Ali Moulaye and Dong-Lee KHAN)
4. Meranom LLP (Hillmont and Logoform – St Kitts and Nevis, A/Cs electronically filed)
5. Agrocomplex LLP (Tallberg and Uniwelll – Nevis, Kang Dong-Hee and Ali Moulaye)
6. Texmond Sales LLP (Astrocom and Exponet – Seychelles, Ali Moulaye)
7. Aliove Systems LLP (Dexberg and Montbridge – Marshall Islands, Ali Moulaye and Sabine Boze-Vickers)
8. Kronex Premium LLP (Dexberg and Montbridge – Marshall Islands, Dong-Hee Kang and Sabine Boze-Vickers)
9. Eurasia Gazexport LLP (Kenmark and Ostberg, Dominica, Kang Dong-Hee and Ali Moulaye)
10. Astromark Systems LLP (Formond and Primecross – Marshall Islands, Dong-Hee Kang and Ali Moulaye)
11. Woodbridge Sales LLP (Astrocom and Exponet – Seychelles, Kang Dong-Hee and Ali Moulaye)
12. Figas Steel LLP (Tallberg and Uniwell – Nevis, Dong-Hee Kang and Ali Moulaye)
13. Entercraft LLP (Formond and Primecross – Marshall Islands, Ali Moulaye)
14. Steelcore Alliance LLP (Paco and Synteco Inter – Marshall Islands, Aybek Buribekov)
15. Telecon Projects LLP (Formond and Primecross – Marshall Islands, Kang Dong-Hee and Ali Moulaye)
16. Glenport Merchants LLP (Formond and Primecross – Marshall Islands, Ali Moulaye)
17. Incomstar Industries LLP (Kenmark and Ostberg – Dominica, Ali Moulaye)
18. Meyerstone LLP (Altimex and Crestberg – Dominica, Kang Dong-Hee and Ali Moulaye)
19. Experto Ventures LLP (Formond and Primecross – Marshall Islands, Ian Virel and Ali Moulaye)
The shareholders:
LNX Capital LP – Partners are Logoform and Hillmont – Nevis
Lordhouse Developments LP – Partners are Tallberg and Uniwell – Nevis
Cliffmount Properties Limited Partnership, Suite 260, 2323-32 Avenue NE, Calgary, Alberta – no further information
Vectorex Inc – registered in Dominica, no further information
ETG Federation, 1 Oak Court, Caledon Road, Somerset West, Western Cape, South Africa – no further information
18. Voxplan Transit LLP
Incorporated on 09/08/2010 and dissolved on 21/11/2017.
DM – Formond and Primecross
PSC – No
Accounts filed from 2011 until 2016. They were signed by Ali Moulaye and were as follows:
2011: £7,187
2012: £7,371
2013: £7,480
2014: £14,786
2015: £18,319
2016: £19,960
Google search yields no useful results.
19. WDC Projects LLP
Incorporated on 06/07/2010 and still active.
DM – Formond and Primecross resigned as DM on 01/01/2018 to be replaced initially by Logoform and Hillmont (01/01/2018 to 02/02/2018 when they were replaced by Entervox AG and Bondwest AG alongside Sergii Parshutkin, Oleksandr Parshutkin and Maksym Kirieiev all from Kiev, Ukraine who were appointed in May 2017.
PSC – No
Accounts filed from 2011 until 2016. They were signed by Ian Virel (on those accounts where it was noted) and were as follows:
2011: £14,482
2012: £605,783
2013: £1,182,069
2014: £969,216
2015: £5,135
2016: £0
Google search yields no useful results. However the accounts for 2012 note that the company bankers are Citadele Bank, Latvia.
20. Campley United LLP
Incorporated on 07/03/2014 and still active.
DM – Formond and Primecross along with Tallberg were appointed on 05/01/2017 and all resigned on 01/01/2018. Two other DMs (Assetmark, Belize and Altimex, Dominica, who were appointed on 07/03/2014 remain. Crestberg was briefly a DM from 07/03/2014 until 10/04/2014.
Accounts filed from 2015 until 2017. They were signed by Ali Moulaye and were as follows:
2015: £5,420
2016: £495
2017: £0
Google search yields no useful results.
So that’s it! The first 20 of the 615 available. As I said at the beginning, you can only retrieve the first 400 (and, for the record, the 400th is Magnum Global LLP, incorporated on 30/03/2006 and dissolved on 10/11/2015., no PSC and Ali Moulaye signed the accounts).
What have we learned from all this?
Clearly, a huge number of these LLPs are being run by the same shadowy people in the background. The consistency of the formation dates, dissolve dates, annual commissions (and of course, signatories to the accounts) makes it so.
The accounts are rubbish!
Every time you find a mention about one of them on the internet it references Eastern Europe. Almost every named PSC is Eastern European. None of them is anyone (as far as I can tell) who has any business background (I haven’t bothered to include those fruitless searches here).
Hiding in plain sight - my search for money launderers 