His Name Was Clean. Four Entities Later, It Wasn't.
A Western logistics company was three days from signing a services contract with a Moscow-registered consultant. Standard pre-contract due diligence. His name returned no OFAC hits, no adverse media, no court records. We were asked to verify his identity and business background. What we found four corporate entities deep — all of it in public registries — stopped the contract entirely and, according to the client's legal team, would have constituted sanctions exposure under US law.
Undisclosed
Multi-year logistics consultancy agreement, EU-Russia corridor. Value not shared with us.
OFAC violation
Confirmed beneficial owner of a co-holding entity listed on the OFAC Specially Designated Nationals list since 2022.
Routine check. No red flags on the surface.
The client — a European logistics firm with US parent-company ownership — was in final negotiations with a Russian national we will call Dmitry V., a logistics consultant operating through a Moscow-registered limited liability company. The engagement concerned cargo transit advisory services across the Russia-EU land corridor.
The client's in-house compliance team had run Dmitry's name through two commercial sanctions-screening tools. Both returned clean. They had reviewed his LinkedIn profile, which listed fifteen years of logistics experience and a degree from a respected Moscow institution. They had spoken with him over video call on three occasions and found nothing to raise concern.
They hired us as a final confirmation step — what they expected to be a formality — before the contracts were executed. We were given his full name, his company name, his registration number in the Russian Federal Tax Service registry, and his stated address in Moscow.
Entity confirmed. Directorship confirmed. First ownership link found.
We began with the Russian Federal Tax Service's public registry (EGRYUL — the Unified State Register of Legal Entities), which is freely searchable and returns registration data, director names, and declared ownership structures for all Russian legal entities.
Dmitry V.'s company was confirmed: registered in Moscow, active, with him listed as sole director and 100% owner. So far, consistent with what the client had been told. But the registry also disclosed that Dmitry V. held a 34% stake in a second, separate legal entity — a transport holding company registered in St. Petersburg. This second entity had not been mentioned in any of the client's due diligence materials.
We noted it and continued.
Dormant status. Two additional co-owners. One UK registered address.
The St. Petersburg entity was listed as dormant — no active filings since 2021 — but remained registered. Its ownership structure showed three shareholders: Dmitry V. at 34%, a second individual named in full (a St. Petersburg resident with no adverse results in Russian court records), and a third listed owner that was not a natural person but a legal entity: a limited liability partnership registered in the United Kingdom.
A dormant Russian holding company with a UK LLP as a minority co-owner is not inherently suspicious. UK LLPs are a legitimate corporate structure used across legitimate businesses. But in the context of Russian corporate research, a UK LLP registered after 2021 with Russian beneficial interest warrants further examination. We searched Companies House.
LLP registered eight months after the invasion. Registered address shared with 47 other entities.
The UK LLP was registered in October 2022 — eight months after Russia's full-scale invasion of Ukraine and four months after the expanded OFAC sanctions packages of June 2022. Its registered address in London (a commercial address service in the City) was shared with 47 other active entities, most registered within the same twelve-month window. This pattern — bulk registrations at a shared address by a formation agent, clustered in the period immediately following major sanctions expansion — is a documented indicator of sanctions-evasion structuring.
The LLP's two designated members were listed. One was a named individual with a correspondence address in Cyprus. The second designated member was not a person but another legal entity — a Cyprus holding company.
Beneficial owner disclosed. Name matched on OFAC SDN list.
Cyprus's Registrar of Companies maintains a searchable public database of company registrations, including beneficial ownership declarations filed under the EU's Anti-Money Laundering Directives. These declarations are not always complete or current, but the Cyprus holding company in this chain had a filed beneficial ownership declaration on record.
The declared ultimate beneficial owner was a Russian national — not Dmitry V., and not anyone named in the preceding entities. A full name search against the OFAC Specially Designated Nationals and Blocked Persons list returned a confirmed match. The individual had been listed since April 2022, designated in connection with the Russian energy sector and related state entities.
The chain was four entities long: Dmitry V.'s Moscow company, to a St. Petersburg holding, to a UK LLP, to a Cyprus holding whose declared beneficial owner was on the OFAC SDN list. Every link in that chain was in a public registry. None of it required anything beyond a search query and a filing number.
Why four entities of distance does not create legal separation.
The client's legal team confirmed what we had suspected: under OFAC's 50 Percent Rule, any entity in which SDN-listed persons hold a 50% or greater ownership interest — directly or indirectly, in aggregate — is itself considered blocked regardless of whether it appears on the SDN list by name. The precise aggregate interest of the designated individual across this chain was not calculable from public records alone, but the existence of the connection was sufficient for the client's counsel to recommend against proceeding.
The client did not sign the contract. They reported the finding through their internal compliance process. We do not know what subsequent steps, if any, were taken.
It is worth stating clearly: nothing in this research established that Dmitry V. knew about the beneficial ownership of the Cyprus entity, or that he was a willing participant in any sanctions-evasion arrangement. Corporate chains of this type are sometimes constructed without the knowledge of individuals who hold stakes in intermediate entities. Our research established the factual corporate structure. The legal and compliance conclusions were the client's, made with the advice of their own counsel.
Name-matching is not corporate registry research.
The two commercial sanctions-screening tools the client used operate primarily as name-matching systems. They check a submitted name against consolidated watchlists — OFAC, HM Treasury, EU, UN — and return matches or near-matches. They are fast, inexpensive, and appropriate for volume screening.
What they do not do is follow ownership chains through corporate registries across multiple jurisdictions. That is not a flaw in those tools — it is a scope question. Name-screening tools are designed to find direct exposure: a counterparty who is themselves on a list. They are not designed for the research question we were answering: does this person hold any interest, however indirect, in any entity that has SDN-connected beneficial ownership?
That question requires a researcher who can read a Russian EGRYUL filing, search Companies House, pull a Cyprus beneficial ownership declaration, and cross-reference the resulting names against OFAC — across four registries, in three jurisdictions, in two languages. Commercial screening tools do not do this. That is why the client's initial checks returned clean and ours did not.
A name check is not a background check.
If your counterparty has any Russian, Ukrainian, Belarusian, or CIS business structure, a name-only sanctions screen is not adequate due diligence. Corporate registry research — through EGRYUL, Companies House, Cyprus, BVI, Malta, or any other jurisdiction in the chain — is the only method that catches indirect SDN exposure.
We conduct this research as part of our standard corporate background investigation. We deliver a written report documenting every entity found, every registry searched, and every source consulted. The research is conducted entirely from public sources and is admissible as a compliance record.
Other investigations involving identity and corporate deception
The cases below involve different fraud types but share the same investigative foundation: public-source research that surfaces what commercial tools and surface-level checks miss.
Fake Businessman — fabricated corporate history, three jurisdictions
AI-Generated Job Candidate — fabricated Kazakh identity
Public registries contain the answer. We know where to look.
If you are about to sign a contract, enter a partnership, or send money to a Russian or CIS-connected counterparty and want to know what the corporate registry trail shows — send us the details. We will tell you what is there.