Martin Sheil
7 min readJan 7, 2020


Oleksandr Onyshchenko — Money Laundering & Sheep Carcasses

There weren’t any Blockchain or cryptocurrency real estate transactions back in the 11th century when Yaroslav the Wise codified the legal code known as Russkaya Pravda(RP) that ruled the medieval state known as Kievan Rus — the earliest predecessor of modern Ukraine and Russia. And there weren’t any offshore shell companies that allowed for international money laundering to secrete Organized Crime proceeds by Russian/Ukrainian mafia gangs. Yaroslav’s interest centered on addressing the more common crimes plaguing the Kievan Rus — blood feuds and animal mutilation.

Cutting a cow on purpose could result in a fine of up to 7 grivnas — the currency back then — that was to be paid to the vera(collector). Folks like Ivan the Terrible had to grapple with the RP. But it worked pretty well. Perhaps it had something to do with paying Yaroslav’s vera 7 buckets of hops per week in lieu of grivnas.

Currency was easily exchangeable with commodities back then. One good sheep carcass was worth up to 2 nogata. One nogata was worth 1/20 of a grivna. Banks did not exist then as we know them. But loans were a necessary part of life. The RP took note when they instituted a law capping interest rates after the riots of Kiev in 1113.

Mark Ginzburg sold his Kiev apartment in 2017 via blockchain to Silicon Valley billionaire Michael Arrington using smart contracts and cryptocurrency — no loans. There weren’t any grivnas involved either. No sheep carcass and negative on the nogata as well as any bank involvement in the transaction. There may well have been some hops involved in the celebration of the first known real estate sale conducted via blockchain.

The absence of attorney involvement in the transaction really reduced the paperwork and if Ginzburg and Arrington weren’t looking for publicity no one would have been aware of the transaction including appropriate Tax veras. While blockchain enthusiasts will publicly tout the transparency of blockchain transactions, paradoxically, what they are really promoting is anonymity for the transactors.

If someone trafficks underage women to rich foreigners for their client’s sexual gratification, it is likely that ‘someone’ would want to conceal his identity from the authorities. Similarly, should a drug dealer in Brooklyn wish to secrete the enormous profits involved in trafficking Heroin he will likely be looking to legitimize his illicit proceeds, cover his tracks and ensure that his co-conspirators on the other side of the globe get paid in anonymous fashion if possible.

Cryptocurrency can be a solution for folks like those noted above but it hasn’t always been that way. Money laundering may be evolving into blockchain cryptocurrency transactions but law enforcement still has not completely cured the current still popular money laundering mode of moving illicit monies around the world via shell companies and offshore bank accounts that are set up in nominee names by well-paid intermediaries.

I.M.T. Consulting, Inc.

The International Consortium of Investigative Journalists(ICIJ) have banded together and created a database of offshore shell companies discovered being used around the world by those who needed to conceal their financial transactions. Should one click on the link for I.M.T. Consulting, Inc. — eighteen related entities and one address will be graphically represented along with I.M.T. which is reflected as an Intermediary for all of the other entities on the chart. We will restrict our analysis to just two entities. But first, we need to research the address for I.M.T. Consulting noted at the bottom of the chart — 770 Plainfield Lane, North Woodmere, N.Y., N.Y. 11581.

A Lexis address check of the above-noted address reflects Mark Ginzburg. While the residence at the above address appears to be a modest middle-class domicile, further database analysis yields another somewhat more upscale residence associated with Mr. Ginzburg at Seawane Place, Hewlett N.Y. 11557 — that includes an in-ground pool and must have cost Ginzburg some serious grivnas. How did he move up in class with regard to Long Island real estate? Working as an intermediary for folks who wish to conceal their financial transactions can be very lucrative.

A closer look at one of the entities reflected by the ICIJ graphic noted above — Vlair Development, Inc. — yields six officers, two intermediaries, and one address. One intermediary is I.M.T. with the other being Portcullis TrustNet.

The address listed in the graphic is for Portcullis which is a notorious offshore entity creator located in the British Virgin Islands(BVI). The linked case study explains that the British Virgin Islands where Trustnet’s busiest office is located thrives as the base for mass marketers of offshore companies that can be bought cheaply, used for single purposes like opening bank accounts in the name of the company rather than an individual. “Corporations in a box,” one U.S.-based offshore promoter calls them.

One officer the Vlair graphic depicts is Mark Ginzburg — Director of Vlair, and one shareholder is identified as Boris Kotlyarsky. The Opencorporates database places the Vlair address in Brooklyn midway between Brighton Beach and Sheepshead Bay. Kotlyarsky pleaded guilty to Extortion in SDNY in October of 2016. He was originally charged in a Conspiracy scheme with Boris Nayfeld — perhaps the last of the old-time Godfathers of Russian Organized Crime — Vory v zakone — “thieves-in-law” — based in the Brighton Beach section of Brooklyn. Kotlyarsky appears to have operated as a vera(collector) for Nayfeld. Besides a history of kneecapping Kotlyarsky possesses a criminal record for money laundering.

Nayfeld has been investigated for many crimes including selling large quantities of Heroin imported from Thailand — transported through Poland and smuggled via television sets. Nayfeld purportedly sold the Heroin for millions of dollars to several of the major families of Italian organized crime located in the metropolitan NYC area.

The tattoo-covered vor does not regret his life in crime advising journalists that he would do it all again. Nayfeld also noted in an interview that he is a Trump supporter — advising that “Trump is a businessman, he don’t care who give him money for project.” “I’m the same.”

Another offshore BVI entity identified by ICIJ as having been served by intermediary I.M.T. Consulting, Inc. and likely Mark Ginzburg, is something called Riviera Capital Inc. The linked ICIJ graphic reflects Portcullis Trustnet(BVI) as the offshore intermediary for Riviera in addition to I.M.T. Consulting. The only Director listed for Riviera is an individual by the name Oleksandr Onyshchenko — a Ukrainian oligarch with a Russian passport, touted by Rudy Giuliani as a source of information regarding Burisma and the Bidens.

Riviera Capital would not be Onyshchenko’s only foray into the use of questionable shell companies and dubious intermediaries. A recent Kyiv Post article recounts how “NABU said it had arranged for 500k Euros belonging to Onyshchenko to be frozen in Estonia. Law enforcement in Kyiv believes this money was stolen from Ukraine. The same day that the 500k was to be seized Onyshchenko had transferred the money from his account with Russian state-owned bank VTB to a branch of SEB in Estonia”. It is noted that SEB is now under investigation regarding allegations of massive money laundering involving non-resident accounts — primarily from Russia.

Further investigation reveals that Onyshchenko possessed sub-accounts at the notorious Latvian bank Trasta Komercbanka using shell companies, with at least one in his mother’s name(Kadyrov) but ultimately controlled by him. Trasta was documented as being in the middle of a large scale money laundering scheme called the Russian Laundromat early last decade and had its license revoked. Many Russians wished to move their riches out of Russia and neighboring environs. They ultimately invested in such luxuries as yachts and horse farms but needed shady banks like Trasta Komercbanka to wash their wealth.

Onyshchenko seems to fit that bill since he reportedly invested in one stud farm in Belgium in 2000 and a second horse farm in Germany in 2007 to support his abiding interest in equestrian competition.

Onyshchenko may well have been in need of some money laundering service given the various illicit activities he has been associated with over the years by the authorities and by the media. He currently cannot return to Ukraine, given the fact that he faces charges of embezzling millions from a Ukrainian gas company he managed with regard to trading with Central Asia.

Additionally, Onyshchenko faced “pimping” charges in 2010 in Ukraine when he was charged with soliciting prostitution in case# 2010–10–3–1047 filed under Article 303 Part 2 of the Criminal Code of Ukraine. Yaroslav the Wise would be proud to see how the RP code has evolved.

Ukraine’s Interior Ministry suggested the charges involved under-age solicitation by noting that Onyshchenko organized beauty contests involving young girls. The pimping case also accused Onyshchenko and associate Walid Arfush of trafficking women for the purpose of sexual exploitation to the Russian Federation, Kazakhstan, and UAE.

There are media reports that Onyshchenko bought the rights to Miss Ukraine Universe in 2006 from Donald Trump. There are further unconfirmed reports that Onyshchenko was a gangster in the nineties and others that he became an FSB agent when the military stationed him in East Germany. One report that bites is the allegation that Onyshchenko changed his name in the nineties from his birth name — Oleksandr Radzhabovych Kadyrov to Oleksandr Romanovych Onyshchenko in order to hide his purported extensive criminal history.

We can conclude that Onyshchenko possessed the means, opportunity, and motive to launder his income whatever the source. It is apparent that he needed to conceal his alleged gangster/FSB background and attempt to legitimize funds derived from purported human trafficking and embezzlement in order to sustain his horse farms and expensive equestrian avocation.

Hence the past need for Riviera Capital Inc — his offshore BVI shell company and Mark Ginzburg’s I.M.T. Consulting Inc. intermediary services to move and conceal his allegedly ill-gotten gains.

Given his shady background, it is hard to believe a thing Onyshchenko might have to say about Burisma unless Onyshchenko can prove the bogus dirt being proffered was procured with the right amount of appropriately laundered funds and correct currency — one chicken, a couple of nogata, and half a sheep carcass sound about the right value for further fueling the current political blood feud in Congress.

No bitcoin here.

Nayfeld the vor wouldn’t care but Yaroslav the Wise would not approve.

Time for some hops!

Martin Sheil

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Martin Sheil

Retired Special Agent IRS Criminal Investigation; Federal Contractor Deloitte & DOJ OCDETF; Letters of Commendation from Directors FBI Louis Freeh & Comey