The Dark Money Files

In this special episode we review and comment on the recent Global Witness update to its reports from last year on the effectiveness of the Companies House PSC regime.

For more see:Global Witness blog and link

Oh, and we also include an amusing update to our previous report on UK Limited Liability Partnerships.

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In an extended episode, we delve into the intricacies of UK LLPs and, using real examples, explain how the rules allow them to be constructed in a such a way as to hide ultimate ownership behind a series of entirely plausible, but geographically diverse entities.

And our old friend Ali Moulaye gets a mention (or two...).

Due to the complexities of the subject, there are supporting graphics on our website.

DISCLAIMER: There is no suggestion by us, explicit or implied, that any of the people or entities discussed in this or any other episode of "The Dark Money Files" is in any way connected to laundromat or other criminal activity. They are simply used as examples of how other actors might circumvent the rules.

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We begin our analysis of how legal entities, in locations which have transparent corporate registers can still be used to mask ultimate ownership and control while still providing a veneer of respectability.

In this first part we look at Limited Companies and their Directors, Shareholders and Persons with Significant Control, to see how each of these can look plausible but still need further investigation.

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In this first episode of season 2 we discuss Ali Moulaye, the man whose signature is at the base of Companies House account filings for a multiplicity of LLPs identified as being involved in a wide variety of laundromats. And it's quite a story!

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In a sensational final look at the Danske Bank affair, we analyse the whistleblower report and definitively link it to a UK LLP (along with a few others) a small Russian Bank with Igor Putin (cousin of Vladimir) on the board, the Deutsche Bank mirror trades, Alexander Perepilichnyy, Alexander Litvinenko, Ali Moulaye and a whole lot more.

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In 2013 Danske Bank executives started to examine,rather more critically, the lucrative bond sale business in Estonia. We look at the reporting and decision making process at the start of that journey and wonder whether, in hindsight, they might have chosen to have done things differently. We also discus the risks of doing business with unregulated intermediaries (HINT: They are very high!).

The ultimate outcome of those initial investigations is really rather surprising.

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Following the release of Phase 1 of the Forensic Risk Alliance report prepared for Swedbank, we take a detailed look at that it has uncovered and where we'd like Phase 2 to go.

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We begin to look at all the different occasions, highlighted in the Bruune and Hjejle report, where the management of Danske Bank could (and arguably should) have become aware that they had a significant problem in the Estonia Branch and taken much more assertive action to do something about it. 

In this episode we look at the years from 2008 to 2010.

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The second of our special episodes looking this time at the OCCRPs newly released data dubbed "The Troika Laundromat". 

Rather than spend 20 minutes criticising everyone involved we thought we'd spend some time contextualising what it means and then look at how data releases like this can be put to good effect by helping the banks to improve their detection of financial crime in the future.

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In this jaw-dropping episode we look under the bonnet at the situation in Estonia just after Danske had bought Sampo.

It highlights conflicting stories between what the Estonian regulator was saying to Danske (and in fact, ordering them to do) and what the bank was saying to the Danish regulator.

It also looks in detail at the apparent discrepancies between what they had been ordered to do and what they carried on doing.

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