RE: Bear with me on some of this10 Mar 2019 16:06
to come clean.
“The requested list of information and documents seems excessive,” read one email from a Meridian staffer.
In another case, Meridian agreed to provide Appleby with some information to satisfy Bermuda’s “Know Your Customer” (KYC) rule, which requires a certain level of disclosure about the identity of one’s business partners. But before providing the information, Meridian demanded that Appleby staff first sign a non-disclosure agreement.
Appleby seemed surprised by the request. “I don’t believe we have ever been required to sign a non-disclosure agreement in respect of KYC, nor do I believe it advisable,” wrote an Appleby employee in an internal email. “Has Appleby or one of its service provider entities ever agreed to or signed something like the document in question?”
In at least one case, Meridian preferred to move one of its related companies to another agent rather than going through what an employee called a “time-consuming and expensive KYC again with Appleby.”
The information Appleby had requested in this case was nothing unusual: a report of the company’s activities over the past 12 months, the status of its bank account, and the names of its ultimate beneficial owners. Evidently, this information was not something Meridian wanted its Bermuda law firm to have.
Catch Me If You Can
The profits from Meridian’s global holdings may end up in Bermuda, but that’s not where its operations are run from.
The next level in the pyramid consists of two investment funds – Meridian Capital CIS Fund and Meridian Capital International Fund – which are registered in the Cayman Islands, another secretive offshore jurisdiction.
From there, it gets complicated.
In some cases, the Cayman funds form the top of a chain of holding companies that – for those who have the patience to follow the trail – eventually lead to the actual businesses. For example, Meridian Petroleum, its domestic oil and gas consultancy in Kazakhstan, is owned by a Dutch company that is owned by a Cyprus company which, in turn, is owned by one of the Cayman funds.
In other cases, the name “Meridian” doesn’t show up anywhere in the publicly available chain of ownership of a given business. Instead, its role as “beneficial owner” can only be discovered in obscure reports, sometimes years after it takes control. For example, TengizTransGaz, a major Kazakhstani transportation service provider, has no mention of “Meridian” in any of its four layers of ownership.
In the most complicated cases, Meridian’s businesses are run by nominee owners or by completely parallel structures which lead to separate, seemingly unrelated, offshore holdings. The mechanisms through which the profits from these companies end up in Meridian’s hands are unknown. In such cases, only a leak of private correspondence, like the Appleby leak, allows the connection to Meridian to be established.
In one leaked email, for example, a Meridian employee asks Appleby to prepare