Special Services

The detention of K. (name withheld pursuant to Poland’s privacy laws) resulted from an investigation into the legality of financing of a different entity – the Open Dialog Foundation (ODF) – and the legality of financial operations carried out by its managing staff. As found by the investigators, the ODF was largely financed by SILK ROAD BIURO ANALIZ I INFORMACJI Sp. z o.o. (hereinafter referred to as SILK ROAD). K., as the owner of the latter company, was also the board member of the ODF.

Almost all of the money transferred to SILK ROAD’s accounts came from fictitious entities registered in tax havens and/or from companies related by capital or personally with K. With the provisions of occasional services these entities would simulate the lawfulness of their operations. Sales documents issued by K.’s company would provide legal grounds for the introduction of foreign funds into the Polish banking system. As much as PLN 5.3 million would be laundered through this scheme.

K. was presented with charges upon a solid (40 volumes of files) and a comprehensive evidence. It comprises, among other things, witnesses testimonies, outcomes of controls and tax proceedings, and analyses of financial flows based on several dozens of the obtained bank account records.

The evidence in this case suggests that between 2012 and 2016 K. issued a number of VAT invoices for the provision of unspecified consulting services invoiced as “consultancy services”, “IT services” and “VOIP services”. In a more detailed way, during the said period as many as 46 such invoices were issued for the benefit of 11 foreign contractors, whose total amount reached PLN 5.3 million. These contractors included exclusively the entities registered in tax havens – Belize or Seychelles – or companies registered under virtual addresses that only appeared to conduct their economic activities. As found by the Internal Security Agency, K.’s company never provided any real services to these parties and never engaged in any economic relations with them. The entities involved in this criminal scheme were set up by professional Latvian or Estonian intermediaries. The bank accounts of these entities were run in Latvia, among others, with the actual beneficiaries of their activities being Russian and Ukrainian nationals.

As indicated by the evidence, the objective of K.’s actions was to obtain material benefits from foreign financial sources under a false pretense of carrying out an activity aimed at the protection of human rights, political freedom and the freedom of economic activity.

In Poland, money laundering is punishable by jail term of up to ten years.

Stanisław Żaryn, Spokesman for Poland’s Minister-Special Services Coordinator