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E-money: A Case Study of Human Trafficking (Part 2)

In Part 1 of our series, we discussed electronic money and the rules that have allowed e-money institutions to flourish in the European Union with less regulations than banks. This week, we look at an example of how these European businesses have real and widespread influence on criminal operations in the US.

A Haven for Illicit-Massage Seekers

Rubmaps is an online guide to illicit massage parlors throughout the US. It gives registered users detailed information about a massage parlor's offerings with user-generated reviews and descriptions. Although Rubmaps claims to be against prostitution and human trafficking, the illicit massage industry is inextricably connected to these practices. According to a report on human trafficking by Polaris, a nonprofit, non-governmental organization, illicit massage parlors rank second only to escort services in reported human trafficking cases in the US. Rubmaps is frequently in the news for helping facilitate vast criminal networks related to indentured servitude. Listings on Rubmaps provide detailed physical descriptions of the masseuse, and list the services offered, including explicit sexual services.

Who Runs Rubmaps?

It is difficult to say definitively who operates rubmaps[dot]ch. On the surface, the website appears to be operated by Miracomm Holdings Ltd., a Cyprus-registered company. Whois registration information for the domain name lists the following information:

Miracomm Holdings Ltd
alexei grigori
Grigori Afxentiou 133
CY-2369 Nicosia

We were unable to identify a person named Alexei Grigori related to the operation of Rubmaps. However, Whois registration information for the original domain name - rubmaps[.]com - which now redirects to the flagship website, lists the registrant as Georgios Veniaminidis. This person is listed as an officer in dozens of Cypriot companies (with his name written in Greek), including Miracomm Holdings Limited and a company called Kuil Limited, which owns many trademarks related to eros[.]com, an adult escort review website. Kuil Limited is also the most recent non-anonymous registrant organization of the domain name eros[.]com. Domain names associated with Miracomm Holdings and Kuil Limited (miracomm[.]eu and kuil-ltd[.]com, respectively) use name servers that are subdomains of uhostgate[.]com. A name server's function is to point a domain name to an IP address with content. The most recent non-anonymous Whois information of uhostgate[dot]com lists the registrant as David Azzato.

According to "Following the Money: How Human Traffickers Exploit U.S. Financial Markets," a report prepared for the US Committee of Financial Services, Miracomm is likely a shell company used to hide the beneficial owners of the website. The report states, "Miracomm Holdings Ltd currently lists Georgios Veniaminidis, a 74-year old resident of Cyprus, as its sole shareholder. Miracomm Holdings Ltd was formed by CDP Media AG, a Swiss entity controlled by individuals other than Veniaminidis. Veniaminidis does not appear to be the ultimate beneficial owner of Miracomm Holdings Ltd." Third-party directories list David Azzato as a former officer of CDP Media. Azzato is the current or historical registrant of more than 680 domain names, most of which have names that appear related to pornography or sexual services, including rubads[.]com, rubclassified[.]com, rubmapads[dot]com, rubmaplive[.]com, rubmapsad[.]com, and rubmapsads[.]com. At the time of our review, these websites were all parked, displaying no unique content.

Rubmaps and the E-money Connection

To access reviews and details of what can be expected at a given massage parlor, Rubmaps users pay a monthly fee. This is where e-money comes in. When signing up for premium membership, users are directed to secure[.]mmgbill[.]com to pay via credit card.

MMGbill[.]com is owned/operated by MMG Corporation SRO, a company registered in the Czech Republic whose principals include Vincent Frantisek Moravec and Tibor Moravec. Vincent Moravec is also the historical registrant of the related company domain name mmggate[.]com. MMG operates as an E-Money Directive (EMD) agent. As mentioned in Part 1 of this series, EMD agents use the license of an e-money institution, essentially acting on the institution's behalf with its permission. In the words of the UK Financial Conduct Authority, "the principal is generally responsible for the activities of its appointed representatives/agents."

The authorized electronic money institution for MMG is One Stop Money Manager Limited (OSMM), according to the Financial Services Register.  Corporate records for OSMM list two active directors: Lesley Anne Goudman-Peachey and Paul Edward Goudman-Peachey. The company website's About Us page lists Paul Peachey as Executive Chairman of the Board, and the most recent non-anonymous, non-redacted registrant of the domain name is Rachael Goudman-Peachey.

As a "tied agent," MMG gets its ability to process payments from OSMM. Therefore, a payment to Rubmaps runs through the Czech Republic (MMG), with a nod to the UK (OSMM), on to Cyprus (Miracomm Holdings), and then Switzerland (CDP Media) before disappearing into the murky and anonymous world of offshore banking. While the actual operators of Rubmaps are ultimately responsible for its content, the website could not function without the support of third-party companies that facilitate payment processing and internet services.

LegitScript monitors the payments space for merchants engaged in illicit activity, including illegal pharmaceuticals, gambling, transaction laundering, and human trafficking. We help our clients keep their merchant portfolios and ecosystems clear of bad actors, and we stay ahead of the curve when it comes to regulatory and reputational threat. Learn more about our investigative analyses or contact us to discuss how our services can help you.

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