Experts from Transparency International — Russia (in exile) have analysed the cases of illegal transfer of funds by trade operations from Russia to the UK over the last ten years.
The research focuses on Russian court decisions under articles 193 and 193.1 of the Russian Criminal Code for illegal currency transactions, including those involving forged documents. Several hundred analysed judgements were identified between 2013 and 2022 and about 10% of them mention UK-registered firms. The authors estimate that at least 20 billion roubles (or £150 million) were withdrawn from Russia over ten years with the help of UK firms. This is approximately 10% of the total funds illegally withdrawn through trade from the Russian Federation.
This method of illegally withdrawing funds is called trade-based money laundering (or TBML). It is an actively used illegal method of withdrawing funds; in 2022, we showed how 41 billion roubles was withdrawn from Russia through this scheme on the supply of machines to manufacture plastic products. In the new research, we report on two dozen cases of money withdrawal from Russia that have yet to be covered in detail or compiled in one place.
In some cases, the withdrawal schemes consist of actual deliveries of goods but at false values in customs declarations or deliveries of one product under the guise of another. For example, in the case of copper powder or cleaning agents for industrial equipment, it is relatively easy to pass them off as other goods.
In other cases, the goods are not delivered at all, and false documents containing information about some export/import trade activity are attached: deliveries of electronic equipment, construction materials or even clothing. Moreover, it often concerns not only goods but also services, such as transport and forwarding services (the provision of services for which takes more work to prove).
Transactions are conducted through firms registered under English common law, such as Scottish Limited Partnerships (SLPs). SLPs appear as intermediaries in a large number of cases of international laundromats. Representatives of these firms are shell companies registered in Seychelles, Marshall Islands, British Virgin Islands or Belize. This allows them to conceal information about the ultimate beneficiaries successfully.
The research describes cases of illegal trade transactions from Russia until 2022. However, we see how, after Russia’s full-scale invasion of Ukraine, similar British intermediary firms and shell companies can be used to supply Russian military contractors with dual-use commodities.
