It is a well-known fact that the villains behind cybercrime organizations and scams (as a manifestation of cybercrime) do not present themselves publicly. They typically operate their legal entities through trustees and nominee directors. The so-called Companies Builders or Corporate Services providers thrive well on cybercrime. In many cases, such as obtaining a crypto license in Estonia, local directors are needed. Therefore, a booming corporate services business with Nominee Directors and trustees has developed around the (worthless in a regulatory sense) Estonian crypto licenses. The Estonian regulator FIU is openly watching or overwhelmed with their supervisory obligations.
About being a Monkey!
Nominee Directors – the scammers, call them “Monkeys” for a reason – increasingly complain to FinTelegram that we would mention their names when we uncover scam structures and their legal entities. They claim that they are merely Nominee Directors, have no real responsibility, and have not been operationally active. Being a legal representative of a legal entity is public information in the first place and not a private matter. These claims may even be correct, but unfortunately, they do not help the Nominee Directors. In fact, inactivity is even a breach of duty for directors.
We know that scammers expect their Nominee Directors to be a Monkey – a Wise Monkey seeing no evil, speaking about no evil, hear no evil! Unfortunately, being a Monkey violates your duty as a director and brings you into conflict with the law. Don’t be a Monkey! Don’t ruin your reputation and other people’s life!
About your duty!
A director acting diligently shall perform appropriate KYC, verify the principals (a/k/a Ultimate Beneficial Owners or UBO for short), and the business’s legitimacy. Besides, you as a director have to constantly supervise the company’s activities and its employees and ensure that no illegal activities such as investor fraud or bank fraud are carried out. Inactivity is no excuse but a breach of your duty!
As a director and legal representative of a legal entity, one has responsibility for the activities of that legal entity, regardless of whether you are a “real” or a nominee director (a “monkey” in the scammers’ lingo). If such a Legal Entity engages in scams or is involved in cybercrime, the directors are liable. Before civil and criminal law. Dear Nominee Directors and Monkeys, you usually get paid for your service, right? For legal entities that run scams and steal money from consumers and small investors, your money comes from illicit and criminal proceeds—money from the desperate victims.
The Monkey Hotline
Dear Nominee Directors and Monkeys, you are fraud and money-laundering facilitators when working for scam ventures. Like participating payment processors, you enable the scams in the first place and help steal money. In this respect, do not complain when your names are mentioned as co-conspirators. In case you are wronged and/or threatened, we have set up a Monkey Hotline. However, we also expect Nominee Directors to disclose the data to help expose the scammers and thus enable the victims to get their money back.