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The Jack of All Trades: Abramoff, Andrade, AML Bitcoin.

Author: 
Nigel Morris-Cotterill

You'd have thought that you'd heard the last of US lobbyist Jack Abramoff, the self-styled lobbyist, film producer, writer and businessman when he was awarded the coveted additional position, without which no American businessman's career is, seemingly, complete: that of convicted felon. After all, when you've been jailed for fraud, conspiracy to commit bribery and tax evasion you'd keep your head down, wouldn't you.

But then again, when your entire career has been working with dodgy businesses and doing dodgy political deals, perhaps there's nothing left to do but be dodgy over cryptoassets. A crypto-coin especially designed to be resistant to money laundering: AML Bitcoin was tailor-made for Abramoff. Now he's awaiting sentence and the company behind it is in disarray - and spending investors' money on litigation.

But what lies behind it is even more fascinating and takes us on a global trek from Las Vegas via Texas to London, Singapore and Melbourne - then across the Pacific to Northern California.

In the company's records at Companies House, the director NASH is shown as Joseph Leslie Nash born February 1965. The correspondence address is shown as 78 High Street, Newport Pagnell, Buckinghamshire, MK16 8AQ. But there is another record for Joseph Leslie Nash, born February 1965, Australian, Living in Singapore with a record of nine appointments.

Indigo (London) Holdings Limited - appointed November 2011, resigned August 2016. Correspondence address Melbourne, Australia. The Company remains active.

Indigo (London) Limited, appointed November 2011, no resignation recorded. Correspondence address Melbourne Australia.
The company is dissolved. It was listed as the sole sharholder of Investmaster Holdings Limited.

Adminsource (UK) Limited, appointed November 2011, no resignation recorded. Correspondence address Melbourne Australia.
The company is dissolved.

Investmaster Holdings Limited, appointed November 2011, no resignation recorded. Correspondence address Leicester, England
The company is dissolved upon voluntary striking off under an application dated 31 December 2015.. In addition to Nash, the director and company secretary is shown as Ralph James Horne, born September 1960 and usually resident in Australia when a return was filed in 2014. There are several records for Horne, most of which show zero registrations. However, there is one that lists an almost identical list to this for Nash. Importantly, tin relation to the companies in this list, they all show his country as residence as "England" or "United Kingdom."

Contemi Solutions (London) Limited. Appointed November 2011, resigned August 2016. Correspondence address: Leicester, England.
The company remains active.

Dion Global Solutions (UK) Limited. Appointed December 2003, resigned August 2016. Correspondence address: Singapore.
The company is in liquidation.

Risklogix Solutions Holdings Limited. Appointed August 2010, resigned October 2016. Correspondence address: Finsbury Sq. London EC2.
The company remains active

Risklogix Solutions Limited, appointed August 2010, resigned October 2016. Correspondence address:Finsbury Sq. London EC2.
The company remains active as a provider of risk, governance and compliance training which recently announced that its customers include UK Finance. Ralph Horne was a director from August 2010 to February 2018 with a correspondence address of Melbourne but country of residence as United Kingdom and British nationality.

DBS Financial Systems Limited, appointed August 2010, resigned October 2016. Correspondence address, Hewett St. London EC2
The company remains active. However, its domain name, www.dbsfinsys.co.uk, diverts to http://risklogix-solutions.com/ DBS Bank is a major government-linked bank in Singapore. At least one of the directors of DBS Financial Systems Limited is said to reside in Singapore. There is no evidence that the UK company is in any way associated with DBS Bank.

Randy Lynn Wooten - appointed 7 December 2016, resigned 26 March 2018. One appointment - Checkpal Limited. Described as American, living in America and a lawyer. His UK address was that of the US law firm in Tower 42. There is a lawyer by that name at 5625 FM, 1960 W, Suite 214, Houston, Texas 77069, an address of which more later. In April 2019 he is the attorney of record in United States v Hooper in the southern district of Texas, a criminal case involving "theft of public money greater than USD1,000. Wooten's LinkedIn profile shows that he was with Riddle and WIlliams in the 1980s and early 1990s but since 1991 has practised as Randy L. Wooten P.C. of Houston Texas, that he attended the University of Texas at Arlington and the University of Houston. No link is claimed with Pillsbury. Although listed, and having more than 250 connections, he is not active on LinkedIn having made no comments or posts in the past 90 days. That period appears to include activity in the Hooper case. The Hooper case was settled by plea agreement and will be featured in our Financial Crime Case Studies e-learning module.

Andrew Kevin Francombe - appointed 27 September 2016, resigned 31 October 2017
Carl Andrew Robert Weir - appointed 27 September 2016, resigned 30 June 2017
Darren Victor Winczura - appointed 7 June 2017 In February 2018, his details were changed to the Tower 42 address. No notice of termination as director appears in the company's records. His personal information at Companies House shows his appointment and describes him as Canadian, resident in Canada and holding no office in any other British company.

The "cessation" of Andrade as a "person with significant control" was filed electronically in April 2018 (by which time the company was CROSSVERIFY Limited. However, the notice says that the effective date was 14 November 2016 and that the "register entry date" is 4 September 2017. That same day a person with significant control notice was filed with reference to Fintech Fund Family Limited Partnership. The address of that LLP was given as 5625 FM 1960 West, Suite 214, Houston, Texas, USA, 77069, registered in Texas with no registration number. It held, directly or indirectly, 75% or more of the then CROSSVERIFY Limited. In April 2018, the LLP changed the address registered at the UK's Companies House to 4610 Sweetwater Blvd, STE. 200, Sugar Land, Texas, USA, 77479.

Fintech Fund Family Limited Partnership is (or was) registered in Texas as a Limited Partnership under registration number 0802459338. It was incorporated on 16 May 2016 with a mailing address of 9414 PLAZA POINT DR, MISSOURI CITY, TX, 77459. It was dissolved on 25 January 2019 but its current status is, apparently, shown as "reinstated). As of today, it is shown as "FRANCHISE TAX INVOLUNTARILY ENDED" Note that the US Postal (ZIP) code for both the addresses is the same. Looking more deeply into the tax office's records, we find that the Missouri City address postal code is expanded to 77459-7400. The tax office also shows the only relevant officer for the LLP is Solamor, LLC of 5625 FM 1960 WEST, STE. 214 HOUSTON, TX 77069.

The only contact for that company shown in the tax office records is its "manager" - ROWLAND MARCUS ANDRADE
4610 SWEETWATER BLVD, STE 200 SUGAR LAND, TX 77479.

So, just to help you follow this here is is in one (albeit convoluted) sentence: Andrade filed a notice that he was surrendering significant control of the UK company, ATEN GROUP Limited, the Texas LLP filed a notice that it had become a person with significant control and the Texas LLP was under the control of Solamor LLC which was "managed" by Andrade who gave his personal address to the Texas tax authorities as the same address that was given to the UK's Companies House for the LLP and just before the various changes listed above.

We could continue with page after page after page of the circular involvement of many of the same people in one company after another - and with more people that become part of the picture, much of which is unclear, often because minor inconsistencies in filed information result in misleading search results in Companies House.

And Company's House knows it: at the top of every search result is the message "Companies House does not verify the accuracy of the information filed." In short, don't use this data as conclusive evidence for Know Your Customer research.

If we leave that particular rabbit hole and return to Rowland Marcus Andrade, and recall that we ended up in London due to Aten Group Limited, we can try to find information on "National AtenCoin Foundation". Here we come up against two problems - the first is that it is, apparently, registered in the USA and the second is that it is, not actually its name. But there is something else: NAC Foundation, LLC. Thatm, according to documents filed in the prosecution of Abramoff is a "Nevada limited liability corporation formed on or about 13 February 2014 by conspirator Rowland Marcus Andrade, not a defendant herein. Andrade was the founder and chief executive officer of NAC Foundation, which was also referred to as the National AtenCoin Foundation. The stated purpose of NAC foundation was to develop and manage a new cryptocurrency called AML Bitcoin. Andrade claimed to be the creator of the cryptocurrency AML Bitcoin and the inventor of AML Bitcoin technology. He also, court papers say, claimed to have invented a predecessor cryptocurrency, AtenCoin and sold "Black Gold Coin."

Andrade wasn't new to the game. In 2015, he issued, via PR Newswire, the following "

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