Two Thousand Shells and a Mailing Address

Since 2021, five cryptocurrency exchanges have been sanctioned while operating out of Federation Tower East in Moscow — Suex, Chatex, Garantex, Grinex, and as of May 26, 2026, ABCeX — each one replaced before the last was shut down. ABCeX processed over $11 billion before the UK designated it through its El Salvador-registered parent company. Its successor, AEXBit, was not included in the designation. As of May 2026, it remained accessible on the same wallets. Six exchanges, one address, and the cycle is accelerating.

The question is not what these exchanges did. The blockchain evidence is public, the OFAC designations are on record, the DOJ indictments have been filed. The question is how the same building keeps producing them — and why nobody can seem to stop it.

The answer is underneath the building, in the offshore layer that owns it.

The Ownership Chain

Federation Tower's ownership is deliberately opaque. The East tower's developer, AEON Corporation, is controlled by Roman Trotsenko, sanctioned by the EU and UK; AEON Corporation was OFAC-designated in November 2023 under Executive Order 14024. The West tower belongs to VTB Bank, sanctioned since 2022. The Podium is held by EVINDREAM LIMITED (HE 343693), a Cyprus holding company registered in Limassol in May 2015 with a nominee director who administers at least eight other Cyprus entities from a shared office in Maximos Plaza. Its beneficial owner is not disclosed. Its management company, Invitech Management, produces zero public results.

This is not accidental. The building is wrapped in layers designed to prevent exactly this kind of tracing. But the Panama Papers opened a seam.

Bancario Corporation — The Mailing Address

In 2016, the International Consortium of Investigative Journalists published the Panama Papers, 11.5 million documents from Mossack Fonseca, the Panamanian law firm that incorporated offshore entities for clients worldwide. Among the records was a company called Legal Consulting Limited, incorporated in the Bahamas on September 13, 2011. Its agent was Mossack Fonseca. Its shareholder, recorded from September 20, 2011, was Bancario Corporation.

Bancario Corporation is not a ghost. It is something more instructive: a shell whose existence proves nothing except the sophistication of the people who built it.

The ICIJ's Offshore Leaks database contains Bancario Corporation as node 12053342 — registered as an officer in Seychelles, with a single address: 102 Aarti Chambers, Mont Fleuri, Victoria, Mahé. That address is a mass-registration point. Sixty-seven officers — companies, nominees, and individuals — are registered at the same suite. The ICIJ's own visualization gives up: "too many connections to display a useful graph."

Bancario is not the only Seychelles vehicle at this address connected to the network. Global Recruitment Consultants Limited — also registered at 102 Aarti Chambers — held shares in six Bahamas entities between 2001 and 2004, all through Mossack Fonseca. It was a serial nominee: BEYSS-Investments GmbH, Donnelly Ventures S.A., Panda Impex GmbH, Iceland Management Ltd., Follet Corporation, and one other — International Secretary Services Limited, a Bahamas entity incorporated in March 1994, linked to Russia, dissolved in 2014.

The ownership chain of International Secretary Services Limited tells the story of how offshore opacity evolves:

• From 1994 to 2001: held by THE BEARER — physical possession of share certificates, maximum anonymity.
• From 2001 to 2004: transferred to Global Recruitment Consultants Limited — a named Seychelles entity, but at a mass-registration address.
• From 2004 onward: transferred to Bancario Corporation — another Seychelles entity, at the same mass-registration address.

Bearer shares to Seychelles shell to Seychelles shell. Two handoffs, one address, three layers of opacity. And Bancario holds shares in not just International Secretary Services Limited but also Legal Consulting Limited — the Bahamas entity that connects to the intermediary at the center of this investigation.

One shareholder. One mailing address in Victoria, Mahé. Two Bahamas entities. And from there, the trail opens into something much larger.

Legal Consulting Services Limited — The Nexus

Legal Consulting Limited's intermediary — the firm that administered it on Mossack Fonseca's behalf — was Legal Consulting Services Limited, a Moscow-based operation listed in the ICIJ database as node 11010643. Its status is Active. Its address is the Mosles Building, Third Floor, on Bolshaya Polyanka Street in central Moscow.

The ICIJ's web interface describes its network as having "too many connections to display." When CrimsonVector downloaded the complete ICIJ bulk dataset and filtered for all entities where Legal Consulting Services Limited served as intermediary, the number was not fifty-seven — the approximate count visible on the web page. It was 2,014.

Two thousand and fourteen offshore shell companies — 1,050 in the British Virgin Islands, 924 in the Bahamas, 21 in Panama, 19 in Niue — all administered through one Moscow office. Of these, 203 remain active. Five hundred and nineteen were held through bearer shares, the most opaque form of corporate ownership available. We found no prior published identification or profiling of this network.

Legal Consulting Services Limited is not a law firm with a website and a client list. It is an infrastructure provider that left its fingerprints on two thousand shells — and the fingerprints belong to two men.

Sergey Sobolev appears as the contact name on 1,996 of the 2,014 entity records, always through the same vehicle: Graff International Partners K/S, a Danish-registered limited partnership. Danish Business Authority records (CVR 33258291) show it was registered in Copenhagen on November 3, 2010, initially classified under construction project management, then reclassified to non-specialized wholesale trade, then to business consultancy — a progression that mirrors the shift from tangible commerce to intermediary services. Its general partner changed twice: from Graff Nordic Management ApS at a registered-agent office on Ny Adelgade, to Park Management ApS in the outer Copenhagen suburb of Frederikssund, then to a foreign entity called Mentor Capital Partners Ltd with no Danish registration. It was struck from the Danish register in August 2013 for failure to file, revived in August 2014 with two years of back-filed annual reports, and finally dissolved on August 28, 2017 — sixteen months after the Panama Papers were published. Its beneficial owners are classified as hidden under Danish law. Its operational address was on Dobrolyubova Street in Moscow.

Sobolev is not just a Panama Papers figure. He reappears in the Pandora Papers — the 2021 leak from a separate set of offshore service providers — as the beneficial owner of Xeolanta Corporation, administered by Alpha Consulting. The Pandora Papers data is current through 2019, which means Sobolev was still actively using offshore structures two years after Graff International Partners was dissolved. The Danish vehicle was closed. The operation continued. His residential address in the Pandora Papers filing is on Vilnyusskaya Street in southwest Moscow.

Sergey Logachev is the formal officer — shareholder and beneficiary of Cheviot International Inc., a defaulted BVI entity incorporated in 1996 whose address is listed as "Legal Consulting Services Limited, Mosles Building, Third Floor." He used the intermediary's own address as his own. His son, Nikita Sergeevich Logachev — the patronymic confirms the relationship — appears in the Paradise Papers as director and shareholder of J2P Ltd, a Malta company incorporated in 2016. Other family members appear across the Paradise Papers and Panama Papers, connected to entities in the UAE, Malta, and the British Virgin Islands. The family's offshore activity spans three separate leak investigations.

Based on the ICIJ data, Sobolev was the operational contact; Logachev was the formal officer. Together, through Graff International Partners, they administered an offshore network whose clients included a BIS-listed energy oligarch, a representative of sanctioned Putin associates, and the family whose Panama Papers address is the Federation Tower complex itself.

Who Was in the Network

The 2,014 entities are largely anonymous. Five hundred and nineteen — more than a quarter — were held through bearer shares, meaning no owner was recorded by name. The remaining entities used nominee directors drawn from a small pool of Seychelles-based professionals: Dorothy Tina Chung-Loye appears across 21 entities, Fabian Bonnelame across 15, Roland Francois Felicie across 9. These are not real decision-makers. They are names rented by the hour, providing a fig leaf of corporate governance for shells designed to hold assets without revealing who holds them.

But among the 2,267 unique officers and shareholders in the network, some names stand out. One of them is the building's owner.

Roman Trotsenko — the sanctioned developer of Federation Tower East — appears in the ICIJ data as shareholder of Dothy Investments Limited, a BVI entity incorporated on February 23, 2004 and still listed as active. The entity's intermediary is Legal Consulting Services Limited. Its contact on the Mossack Fonseca paperwork is Sergey Sobolev of Graff International Partners. Trotsenko held his shares as bearer from March 2004 to February 2007, then as a named shareholder for six months, before the entity passed to Anatoliy Matveenko — a Russian associate whose residential address is on Yasenevaya Street in southwest Moscow. Matveenko also appears as the beneficiary of a second active LCS entity, Flamank Resources S.A. (BVI, incorporated February 2004). By the time of the Pandora Papers — data current through 2017, from a separate law firm (Alcogal) — both Dothy and Flamank list a new ultimate beneficial owner: Rustem Rinatovich Khalilov, whose address appears at the same Moscow apartment building (Sokolnicheskiy Val, House 50) across both the Panama Papers and Pandora Papers datasets. A third LCS entity, Sempyo Trading Corporation (BVI, incorporated September 2007, dissolved April 2013), lists Sofia Trotsenko — a family member — as its beneficiary, with the same Sobolev/Graff contact.

The man who developed Federation Tower and whose company collects rent from its tenants was a direct client of the same offshore intermediary that administered 2,014 shells. Sobolev was his contact. Graff was the vehicle. The building and the offshore network are not parallel structures. They share an architect.

Andrey Komarov — the billionaire owner of ChelPipe, Russia's third-largest steel pipe manufacturer and a major supplier to the oil and gas industry — held bearer shares in four LCS entities: Kenn Management S.A. (which later changed agent), Eunice Pacific Limited, Prentice Capital Management Corporation, and Girvan Impex Limited, all BVI-incorporated and all administered through Sobolev and Graff. Komarov, a former member of the Federation Council (Russia's upper legislative chamber), was sanctioned by Ukraine in October 2022 and by the United States under Executive Order 14024 in February 2024. His sons Klim and Artem were designated by OFAC in January 2025. His entities are all defaulted, but his presence in the LCS client list confirms a pattern: the intermediary serviced not just the building's owner but a broader tier of sanctioned Russian industrialists.

Anatolie Stati — the Moldovan energy oligarch whose family has juggled more than 50 offshore companies in the international oil industry — appears across 15 entities in the LCS network, 10 of which remain active. His Ascom Sudd Operating Company Limited, a BVI entity incorporated in 2006, is listed on the U.S. Bureau of Industry and Security Entity List for operations in South Sudan. His Tristan-branded entities (Tristan Energy Capital, Tristan Energy Global, Tristan Gas Energy, and others) form a constellation of energy holding vehicles, all intermediated through the same Moscow office. Casco Petroleum Overseas, 80 percent owned by Stati through East-West International, ran oil and freight transport operations across Kenya, Congo, Uganda, and South Sudan.

Vadim Gurinov, a Belize-Cyprus citizen based in the UAE, appears in three entities — Hercules Impex Ltd (Bahamas), Punch Investments Ltd (BVI, active), and through his brother Artem in the critical node Gano Services Inc. (BVI, active), which connects to the Petroruss DMCC oil sanctions-evasion network. Petroruss ships oil from Rosneft, Lukoil, Surgutneftegaz, and Gazprom Export using a shadow fleet of 20-plus vessels; it was sanctioned by the United Kingdom in December 2024. Vadim Gurinov represents the interests of Gennadiy Timchenko — the sanctioned Putin associate who controls Volga Group — and Andrey Dyukov, CEO of Gazprom Neft. The same intermediary that structured Federation Tower's offshore ownership also serviced the infrastructure of sanctioned Russian oil exports.

The Tskhovrebov family — Dzhambulat and Yury — appear in 4 entities, most importantly Atlantico Investments Inc. (BVI, active since 2000). The ownership history of Atlantico traces the evolution of Russian offshore practice: bearer shares from 2000 to 2006, then Yuri Tskhovrebov as named shareholder through 2014, with Dzhambulat as beneficiary throughout. The entity passed through six recorded ownership changes in fourteen years.

Dzhambulat Tskhovrebov's registered address in the ICIJ database is Mezhdunarodnaya Street 50/51, Apartment 41, Moscow — the street address of the Moscow City International Business Center where Federation Tower is located. He is not merely associated with the area. His Panama Papers filings place him at the complex itself.

The family's European footprint is documented in German corporate records. REII Holding GmbH (HRB 72105, Düsseldorf), founded in March 2014 with Dzhambulat as managing director, lists its purpose as "acquisition, holding and sale of real estate" with 25,000 euros in registered capital. Dzhambulat was replaced as director by Elvira Tskhovrebova in September 2019, and then by Will Fischkin in September 2022. REII Multiplexkino GmbH (HRB 81261), registered in July 2017 with Dzhambulat as managing director, operates film theaters. His address in the German filing is Bierges, Belgium. Yury Tskhovrebov's address in a later ICIJ filing is in Monaco — 6ET Deuplex 02, 8 Rainier III, 98000.

The Tskhovrebov entities are the physical anchor: they place the LCS offshore network not just in Moscow, but at the Federation Tower complex itself. A family that lives between Moscow City, Belgium, and Monaco, holding active BVI shells through a Moscow intermediary while operating German real estate companies — structured through the same Mossack Fonseca agent that services two thousand other entities.

The Convergence

The same Mossack Fonseca intermediary — Legal Consulting Services Limited, Mosles Building, Third Floor, Bolshaya Polyanka Street — structured shells for all of them:

• The building's owner himself (Trotsenko → Dothy Investments, Flamank Resources, Sempyo Trading, all through Sobolev/Graff)
• A sanctioned industrialist (Komarov → four entities, OFAC-designated February 2024)
• The oil sanctions-evasion network (Gurinov → Spiridonov/Petroruss → Timchenko/Dyukov/Gazprom Neft, UK-sanctioned)
• A BIS-listed energy empire (Stati / Ascom / Tristan, South Sudan operations)
• The building's physical address (Tskhovrebov at Mezhdunarodnaya / Moscow City)
• The crypto exchange pipeline (the building that houses Suex through ABCeX, enabled by the same opacity layer)

This is not a claim that these actors coordinated. It is a structural finding: the same offshore plumbing connected the building's owner to its tenants' enabling infrastructure, to sanctioned commodity networks, and to the crypto exchanges that are its most visible output. Roman Spiridonov's Petroruss DMCC operates a shadow fleet shipping crude from Russia's largest producers to buyers in China, India, and Turkey — nearly 100,000 metric tons from Gazprom Export to China in a single month. Sergey Mendeleev's Garantex processed $96 billion in lifetime volume, routing DPRK Lazarus Group funds and ransomware proceeds through nested wallets. Different products — oil and crypto — manufactured in the same factory, using shells from the same intermediary, connected through the same family of nominees.

The convergence is not coincidental. Mossack Fonseca's business model was to provide standardized offshore infrastructure to clients who needed opacity. Legal Consulting Services Limited was the Moscow distribution point. Whether the client needed to hide oil shipments or crypto flows, the product was the same: a BVI or Bahamas entity with bearer shares, administered from Polyanka Street. The building is where the outputs converge. The intermediary is how they were built.

A Second Offshore Thread

Legal Consulting Services Limited is not the only offshore network connected to this investigation. A parallel chain — administered through a different intermediary in a different country — leads back to the same ecosystem through a single person. Alexander Vasil'evich Kunitsa — a Moscow investor whose ICIJ Offshore Leaks record (node 20361) lists him at Leninski Prospekt 68, apartment 434 — was shareholder of Kuna Group Ltd, a BVI entity incorporated in December 2003 that went dead in May 2009. "Kuna" is derived from "Kunitsa" — both mean "marten" in Slavic languages.

Kuna Group Ltd was replaced in September 2011 by Kuna Group Holdings S.A., a Seychelles entity intermediated not by LCS but by Capital Strategy SA of Geneva. Its shares were held by bearer until June 13, 2014, when they transferred to RP Kapital Ltd, a Dominica company at 3rd Floor, C&H Towers, Roseau. On the same date, five other Seychelles entities — ERNID Property Holdings, Overland Trading Company, Selbourne Associates Real Estates, Cargus Properties Limited, and Caddigan Global Company — were simultaneously transferred from Russian-held bearer shares to four Dominica nominees at the same address.

On January 22, 2018, RP Kapital Ltd and its companion entity Target Management Inc were dissolved by shareholder resolution. The Dominica Official Gazette published the winding-up notices on March 1, 2018, naming OID Limited as liquidator. RP Kapital was also registered in Cyprus as RP Management Ltd (HE 331692), which was terminated around 2022.

The dissolution created an orphan problem: six active Seychelles entities whose shareholder no longer exists. Either the shares were transferred to a successor entity before dissolution — and no record of such a transfer has been found — or these are zombie shells, active on paper, controlled by no identifiable person. The only surviving institutional thread is Capital Strategy SA in Geneva, the intermediary. Who currently directs these entities, if anyone, cannot be determined from public records.

And there is one person who connects the two networks. Georgios Kyrou, a Cypriot who appears in the RP Management Ltd network on NorthData, is also listed in the Panama Papers as shareholder of Dunfey Systems Limited — a BVI entity whose intermediary is Legal Consulting Services Limited, with Sergey Sobolev of Graff International Partners as the contact. Kyrou sits in both the Geneva chain and the Moscow chain. The networks are not parallel. They share a node.

The Alexander Kunitsa who appears in this offshore chain has not been connected to the Sergey Kunitsa who runs Paysol. The analytical link between the two networks is Kyrou, not the surname.

What the Infrastructure Produces

Federation Tower's crypto operations have survived five rounds of OFAC sanctions, a domain seizure, an international arrest, a prison death, and FSB raids. The building endures because the building was designed to endure — not as architecture, but as corporate structure. Its owner used the same intermediary that services the oil sanctions network, the BIS-listed energy companies, and the sanctioned industrialists. The Danish limited partnership that served as the vehicle was dissolved after the Panama Papers were published, but its operator continued working from a different law firm. The opacity is not a bug. It is the product — manufactured across four jurisdictions, cycled through serial nominees at the same Aarti Chambers suite, designed so that tracing ownership leads not to a person but to another shell.

When OFAC designates the next exchange, another one will open. The address will be the same. The offshore layer beneath it will remain untouched — because nobody has designated the layer, and because the layer's most prominent client owns the building.

This investigation, drawn entirely from public records, identifies 2,014 entities, names the operators, maps the network, and traces the convergence to the building's sanctioned owner. The data has been in the ICIJ's database since 2016. The Danish corporate records are available from the CVR for any journalist who searches for them. No subpoenas, no informants, no leaked files beyond what was already published. It required only the question: what is underneath the building?

Methodology: The 2,014-entity count was produced by downloading the ICIJ Offshore Leaks bulk CSV dataset, filtering for all records where Legal Consulting Services Limited (ICIJ node 11010643) appears as intermediary, and deduplicating by entity ID. The jurisdiction breakdown (1,050 BVI / 924 Bahamas / 21 Panama / 19 Niue), bearer-share count (519), and active-entity count (203) were derived from the same dataset. The ICIJ notes that inclusion in the database does not imply wrongdoing.

All claims in this article are sourced to the ICIJ Offshore Leaks Database (Panama Papers, Paradise Papers, Pandora Papers, Offshore Leaks, Bahamas Leaks), Russian corporate registries (Rusprofile, Checko.ru), the Dominica Official Gazette, NorthData (European corporate data), OpenSanctions, the U.S. Bureau of Industry and Security Entity List, OFAC SDN designations, and CrimsonVector's original analysis of the ICIJ bulk CSV dataset. Attribution: International Consortium of Investigative Journalists.

"Two Thousand Shells and a Mailing Address" is a CrimsonVector investigation. Read the series: "The Address" | "The ABCeX File" | "The Kunitsa Dossier"