Institute for European Integrity: Watchlist Investigation

Mar 18, 2023

The third sector is a central pillar of European democracy. The voices of third sector representatives (NGOs, foundations, and educational institutions) are considered by government officials when justifying policy positions and determining how resources and political capital are spent. Europe’s third sector faces a severe crisis of credibility, due to the corruption of NGOs by oligarchic and kleptocratic wealth as well as by networks of illicit or malign finance or influence.

The NGO Watchlist identifies suspicious NGOs and investigates their funders and links to government influence. The criteria for being watchlisted is having deep involvement with or funding from an individual or entity that has been sanctioned or criminally prosecuted (Russia-invoked sanctions are excluded). Additionally, a separate category of watchlisted NGOs includes those with strong links to individuals with criminal allegations leveled by a European, EU, US, or UK government authority.

The Latest Institute for European Integrity Investigation

Check out our other investigations at https://www.iei.ngo/ngo-watchlist

Open Dialogue Foundation

NGO WATCHLIST: OPEN DIALOGUE FOUNDATION

THE OPEN SECRET ABOUT OPEN DIALOGUE

13/03/2023 | ARTICLE

IEI's special investigation into the Open Dialogue Foundation (ODF), a Warsaw-, Brussels-, and now US-based NGO operating in the human rights space, aims to present the following findings:

EXECUTIVE SUMMARY

Open Dialogue Foundation (ODF), insists that it is “the most pro-Ukrainian and definitely anti-Russian foundation” and has claimed that “Lyudmyla Kozlovska’s family members do not run business in Crimea anymore”. However, IEI discovered that multiple members of ODF President Lyudmyla Kozlovska’s close family have engineered an arguably opaque network of companies located in illegally-annexed Crimea, and this network has been awarded Russian government contracts at the company and individual levels. While denying the provenance of the family’s finances, ODF leadership has admitted that the foundation has been supported by funds from Ms. Kozlovska’s family at least as late as 2017.
The Kozlovsky network extends beyond the immediate family as it is further supported by close associates, morphing into a syndicate: a network whose behavior is more in line with those attempting to elude social, political, or economic consequences by obfuscating ownership in complex ways.
The Kozlovsky enterprise is located in and around a Sevastopol business center called Technopark Mayak. The technopark and its associated companies are overseen by its governing body, the Association Technopark Mayak (ATM). The ATM structure was founded in 2015 by fifteen companies, with seven belonging to the Kozlovsky family either directly or indirectly through a nested structure. Lyudmyla Kozlovska’s sister Elena Miroshnikova has been represented as the “owner of [the] Technopark” at a conference exclusively tailored to business owners in Crimea. Moreover, ATM is a member of the Association of Clusters, Technoparks and SEZs of Russia (AKIT), a conglomerate of technoparks throughout Russia that generates ~1.25% of Russia’s GDP. Currently, AKIT’s stated goal is import substitution that aims to offset the growing economic consequences of sanctions levied on Russia by so-called “unfriendly countries”.
A founding member of ATM is the Ukraine-sanctioned company ZSS Mayak, a shiplighting plant on whose grounds the technopark is located. Until December 2022, ZSS Mayak has been owned, in part or whole, by a rotating roster of Kozlovsky family members wherein it has bid for, been awarded, and fulfilled contracts on behalf of the Russian Ministry of Defense and well-known subsidiaries of US-sanctioned United Shipbuilding Corporation. While under the beneficial ownership of the Kozlovsky family, the Russian Minister of Industry and Trade invited ZSS Mayak to participate in a maritime defense industry trade show in St. Petersburg in 2017; then in 2020, ZSS Mayak received a 5-star review from the Russian Ministry of Defense’s 13th Shipyard of the Black Sea Fleet, and the following year received a certificate of appreciation for its work from the US-, EU-, and Ukraine-sanctioned governor of Sevastopol.
One of ODF’s foundational donors was Petro Kozlovsky, the brother and business partner of ODF President Lyudmyla Kozlovska. Since the illegal Russian annexation of Crimea in 2014, Ms. Kozlovska has repeatedly maintained that her brother lost all his businesses and assets in Crimea, which led to him now "living in exile" in the United States. However, Mr. Kozlovsky still currently retains ownership of some companies in the illegally-annexed territory and has, over the years, offloaded ownership of others, such as ZSS Mayak, to close family members. During the time ZSS Mayak was under 100% ownership by US resident Petro Kozlovsky, there exist at least two notable transactions between ZSS Mayak and US-sanctioned JSC Zvezdochka that appear to have violated regulations as set forth by the US' Office of Foreign Assets Control (OFAC).
In May 2022, ODF co-domiciled itself in the United States with an entity belonging to Elena Miroshnikova, sister of ODF President Ms. Kozlovska and at the time the co-beneficial owner of the above-mentioned Ukraine-sanctioned ZSS Mayak. Depending on the leasing agreement and financial arrangement of the working space, this cohabitation may constitute material support to ODF by Ms. Miroshnikova, who has also financially donated to ODF in the past. Occupying the suite next door to ODF’s US entity in Boca Raton, Florida is another business owned by Petro Kozlovsky.

Another entity with which ODF is co-domiciled in Europe is Silk Road Biuro Analiz i Informacji, which is owned by Bartosz Kramek, Head of the Foundation’s Board and the husband of ODF’s President Lyudmyla Kozlovska. In 2021, Mr. Kramek was detained by Polish law enforcement on suspicion of falsifying records and money laundering, having allegedly commingled laundered funds with ODF through major donor Silk Road. Sources confirm to IEI that as of February 2023, Mr. Kramek remains under investigation.
ODF’s narrative paints a pivot to cryptocurrency as a necessity for their continued work. Throughout the latter half of 2022 and currently in 2023, ODF seeks to dispel associations of cryptocurrency with financial crime and influence institutions and public opinion regarding upcoming EU legislation aimed at regulating cryptocurrency.

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On 31 October 2022, the Institute for European Integrity (IEI) placed the Open Dialogue Foundation (ODF) on its NGO Watchlist. ODF subsequently released what they refer to as a “debunking” piece directed at an external contributing author. IEI has conducted a special investigation, independent of the original external contributor, the results of which warrant ODF’s continued placement on the NGO Watchlist.

Open Dialogue Foundation (ODF) is a Warsaw-, Brussels-, and now US- based nonprofit organization claiming to focus on “human rights” in the post-Soviet space and branding itself as “the most pro-Ukrainian and definitely anti-Russian foundation”. However, the organization has for many years faced controversy regarding its tactics, subjects of advocacy, and in particular, its sources of funding and support.

IEI has bracketed off unsubstantiated rumors and speculation, and instead has relied on the foundation’s own documents, statements, and behavior while simultaneously using open-source information, proprietary intelligence, and other analytical methods to reach a meaningful conclusion. Based on proprietary intelligence and independently verified, IEI has disentangled a nested structure of companies related to the technopark and Lyudmyla Kozlovska’s family: namely, her brother Petro Kozlovsky, mother Sidonia Kozlovskaya, and sister Elena Miroshnikova. We primarily relied on List-Org’s database concerning shares of ownership. List-Org draws from Russian government sources, and the Ukrainian government’s sanctions database has utilized it extensively¹ as have leading think tanks²^,³, and academics⁴. Publicly-available information has been preserved using the Wayback Machine where possible. We note that changes through the removal, addition, or reassignment of directors and/or owners are likely to be reflected in registry entries following publication.

The primary findings of IEI’s special investigation demonstrate that, contrary to ODF’s assertion that President Lyudmyla Kozlovska’s family does not conduct any business in illegally-annexed Crimea, her close relatives are actively engaged in economic activity there and have done business with the Russian state. Over the years, Ms. Kozlovska’s family members have provided financial and possible material support to the foundation. Findings that fall outside of that, while interesting, are secondary and within the remit of investigative journalists and authorities to develop further.

I: THE BEGINNING

WHO IS PETRO KOZLOVSKY AND HOW DOES HE RELATE TO ODF?

The origins of the Kozlovsky family’s business in Sevastopol remain murky, as can be expected given the conditions that likely allowed it to develop: the collapse of the Soviet Union, the resulting privatization and property-grab of the post-Soviet 90s, and then the 2014 illegal annexation of Ukrainian Crimea. At some point, Petro Kozlovsky appears to have acquired significant shares in the Mayak shiplighting plant, a supplier of the Soviet and later Russian navies, as well as its associated properties in Sevastopol. By 2013, these grounds were serving as a business center (a/k/a/ “technopark”) referred to as “Technopark Mayak”. The technopark, located on the grounds of the Ukraine-sanctioned ZSS Mayak plant, offers commercial space to numerous tenants and includes the shiplighting company itself.

Following Russia’s illegal 2014 annexation of Crimea, Mr. Kozlovsky relocated to the United States, with his sister claiming that much of his Sevastopol assets had been seized and Mr. Kramek stating that "Petro Kozlovsky doesn’t run any business in Crimea." Despite the illegal annexation and claims of asset seizure, there continue to exist a plethora of companies linked to or owned by Petro Kozlovsky, his immediate family, and close associates actively doing business in illegally-annexed Crimea; in particular, the company ZSS Mayak, sanctioned by decree of the President of Ukraine No. 497/2021 since October 2021, which has fulfilled supply orders post-2014 on behalf of the Russian Ministry of Defense and well-known subsidiaries linked to heavily sanctioned Russian conglomerate United Shipbuilding Corporation (USC).

Petro Kozlovsky is the brother of ODF President Lyudmyla Kozlovska, a perennial business partner of her and her husband (and Head of ODF’s Board) Bartosz Kramek, and one of the foundational donors to ODF, having donated ~1.6 million zloty (~€340,000) between 2012 and 2015. Mr. Kozlovsky’s business dealings and relationships in and outside of annexed Crimea have been sources of controversy for ODF over the years, with Ms. Kozlovska, Mr. Kramek, and the Foundation itself having unequivocally asserted that neither Petro nor the Kozlovsky family has continued business in the peninsula post-annexation.

II: KOZLOVKSY FAMILY’S LINKS TO RUSSIAN CONTRACTS AND SANCTIONED ENTITIES VIA THE MAYAK NETWORK

WHAT ARE THE SOURCES OF KOZLOVSKY FUNDS?

Located on the grounds of the Ukraine-sanctioned ZSS Mayak plant in Crimea's Sevastopol, Technopark Mayak is a 215,600 square meter business center claiming to rent commercial and industrial space to over 30 business entities. The Technopark and its associated companies are overseen by its governing body, the Association Technopark Mayak (ATM). The ATM structure was founded in 2015 by fifteen companies, with seven belonging to the Kozlovsky family either directly or indirectly through a nested structure. Of the 15 companies forming ATM, seven demonstrate a historical pattern of beneficial ownership by the Kozlovsky family for significant durations between 2017 and up to at least eleven days prior to Russia’s imperialist invasion of Ukraine⁵^. Eleven days prior to the February 2022 invasion, five were beneficially owned, most notably the Ukraine-sanctioned ZSS Mayak. From 2017 to early 2022, three companies were continuously beneficially owned: OOO ZSS, OOO Plosk, and OOO Ios. The family or its associated companies consistently held at least a minority ownership in the other four.

IEI detected a pattern in which beneficial shares in certain companies were anonymized that were previously held by a Kozlovsky family member or associated company; these shares were often recycled back to the previous owner or another Kozlovsky member or entity–or a combination of both–after a period of anonymity. These periods of anonymity prevented IEI from being able to definitively conclude that beneficial ownership was continuously held in all seven cases. While the Kozlovsky family shares of ATM continually fluctuate and cycle through periods of anonymity, Lyudmyla Kozlovska’s sister Elena Miroshnikova appears to have resolved this issue when she was publicly represented in 2021 as “owner of [the] Technopark” at a Crimean business conference in which the Technopark was a partner.

The total Kozlovsky company structure throughout Sevastopol – located at the technopark or the adjacent Vakulenchuka St 31B – consists of at least 20 companies that are currently or have at some point historically (post-annexation) been beneficially owned by Mr. Kozlovsky, his mother Sidonia Kozlovskaya, sister Elena Miroshnikova, or his wife Viktoria Khukhra, either directly or through a nested structure of companies. A 21st company, JSC Sevastopolsky Mayak, was owned by Petro Kozlovsky at a significant 39.5% minority stake from 2016 until the anonymization of shares in May 2022; all other portions of shares are now, and have historically been, anonymous.

IEI discovered the nested Kozlovsky structure by inspecting the shareholdings associated with Elena Miroshnikova, Petro Kozlovsky, and companies owned by them. These companies would then own shares of other Kozlovsky entities in the broader network. An example of this nested structure can be visualized through the expansion of the Kozlovsky company OOO Atoll.

When partially expanded, the company network presents a convoluted and arguably opaque structure. While we cannot speculate as to the motive behind the engineering of this complex nested structure, what is clear is the following: the opacity has allowed the family’s business network to continue to operate in illegally-annexed Crimea while distancing itself from its own controversial entities and, to date, eluding social, political, and/or economic consequences of its business affiliations and/or transactions. The below diagram demonstrates a sample of 10 companies and ownerships involving the Kozlovsky family as of 13 February 2022, eleven days before the Russian invasion of Ukraine; anonymizations, changes, and rotations in ownership and directorship have occurred since that date.

Nested Structure of Kozlovsky Family Companies

As of February 2023, Petro Kozlovsky and Elena Miroshnikova continue to own companies in Crimea. In short, Petro Kozlovsky may not be currently running any businesses in Crimea, but he and his family certainly continue to own them.

Map of Kozlovsky Companies at Technopark Mayak and Adjacent Address

Map by registered address of 21 companies currently or historically (due to pattern of recycling and anonymizing ownerships) owned by Kozlovsky family members in and adjacent to Technopark Mayak, which are located at Fiolentovskoe Highway 1/2, 1/17, and Vakulenchuka St 31B in Sevastopol. Also included is the initial registered address of a branch of a Russian political party described below.

The ATM is a member of the larger Russian state-backed “Association of Clusters, Technoparks and SEZ of Russia” (AKIT), which is overseen by its Chairman Alexander Kozlovsky (family relation not implied), a Deputy of the Russian State Duma who is sanctioned by multiple Western governments. ATM applied in 2015 and was accepted into this group in 2016, which according to the admission document, required the payment of a steep entry fee, a yearly membership fee, and the written consent of over half of AKIT’s members. AKIT cooperates with numerous Russian state ministries and, at the time of this writing, claims to generate nearly 1.25% of Russia’s GDP (which is ~1.5 trillion rubles or the equivalent of €19.5 billion)⁶. AKIT’s current stated goal is to promote an increase of domestic production to substitute for imports lost to sanctions by “unfriendly countries” as a result of Russia’s illegal invasion of Ukraine. While ODF publicly decries this invasion, the Kozlovsky family’s business interests are at best working to mitigate its consequences for the Russian economy, and at worst, have directly supported the Russian military, as detailed below.

ODF has claimed that the Kozlovsky family are no longer involved in business in Crimea. IEI has found this to be false. Not only are Petro Kozlovsky and the larger Kozlovsky family still involved in business in illegally annexed territories, their ventures have also included work with the occupying Russian authorities. Ms. Kozlovska admitted to Polish Newsweek in 2017 that ODF was being supported in part by “[her] family’s resources” as well as through business with Petro Kozlovsky. In 2022, material support was possibly still being given to ODF from at least one Kozlovsky family member owning a Ukrainian sanctioned company, ZSS Mayak, that has conducted business with the Russian military complex.

FUNDS LINKED TO RUSSIA’S MILITARY AND OTHER SANCTIONED ENTITIES

Having owned a company that has been awarded Russian government contracts, the Kozlovsky family are beneficiaries of the very same Russian state and military apparatus that commits what ODF’s Lyudmyla Kozlovska recently called “the Russian war crime.” ZSS Mayak was sanctioned by Decree of the President of Ukraine №497/2021 in October 2021. The company is listed as the recipient of two contracts from the 13th Shipyard of the Black Sea Fleet in Sevastopol, an entity owned directly by the Russian Ministry of Defense, which awarded ZSS Mayak a 5-star review in 2020 stating, “Everything is great. We will continue to work” (see below), suggesting that the family network could be an accredited subcontractor for the Russian Ministry of Defense.

5-Star Review of ZSS Mayak from the Russian Ministry of Defense

Auto-translated from Russian into English

Further demonstrating a mutually-beneficial relationship with the Russian state are the following events: in 2017 ZSS Mayak received an invitation to a maritime defense industry trade show in St. Petersburg from the Russian Minister of Industry and Trade; subsequently the company participated in another St. Petersburg trade show in 2019, represented by former ODF donor Arkady Agarkov, after which it revealed that “the main consumer of ZSS ‘Mayak’ products is the Russian Navy.” Lastly, in 2021 ZSS Mayak received a certificate of appreciation from US-, EU-, and Ukraine-sanctioned Sevastopol governor Mikhail Razvozhaev.

In addition to the direct contracts from the Russian Ministry of Defense, invitations to defense-oriented trade shows, and accolades from a Russian government official, the ZSS Mayak company, which has been beneficially owned post-annexation by Petro Kozlovsky, Elena Miroshnikova, and Sidonia Kozlovskaya, has also bid for and received contracts from then US-sanctioned JSC Zvezdochka in 2017⁷ as well as at least three other Russian companies now sanctioned by the United States: PJSC ASZ, JSC PSZ Yantar, and JSC SP ERA.

These three companies, with whom ZSS Mayak has been awarded contracts at various points since at least 2017, are well-known subsidiaries for United Shipbuilding Corporation, a Russian state-owned shipbuilding enterprise established by Vladimir Putin in 2007⁸. USC was among the first Russian entities to be sanctioned by the US in 2014. Zvezdochka has been owned by USC since 2008. ASZ was acquired in 2009 at 59%, Yantar in 2008, and ERA was the first to be acquired in 2007, meaning that at the time Mayak was engaged in business with these entities they were publicly known to be linked to a heavily-sanctioned entity⁹.

In fact, in 2016, the head of USC told TASS that 2016 US sanctions specifically leveled on Zvezdochka would not adversely affect it as the entity was owned by USC and had thus already been subject to sanctions as of 2014. In 2015, employees of the Mayak plant told local Sevastopol press that though it was threatening bankruptcy, the plant was actively fulfilling contracts from Zvezdochka. ZSS Mayak continued to bid for and be awarded contracts from the US-sanctioned Zvezdochka throughout 2017, at which time ZSS Mayak was under the sole beneficiary ownership of US resident Petro Kozlovsky. Per the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury, “all persons and entities within the United States” are obligated to comply with the regulations as set forth by OFAC, which these transactions appear to have violated.

Lyudmyla Kozlovska and her husband Bartosz Kramek were, by ODF’s own admission, engaged in private commercial activity with Petro Kozlovsky until at least 2017, using funds from this activity to support the foundation. Nevertheless, while concurrently being engaged in business with Petro, ODF issued statements denying Petro Kozlovsky’s involvement with the Mayak plant and claiming ignorance as to its work with the Russian Navy. A Facebook profile claiming to belong to Petro Kozlovsky, which Lyudmyla Kozlovska herself has tagged on the platform using her verified account, has repeatedly interacted with the Facebook page linked to ZSS Mayak; in particular, Mr. Kozlovsky “liked” a 2019 post on the shiplighting plant’s company-run page openly stating that “the main consumer of ZSS Mayak products is the Russian Navy”.

Post on the Facebook page of ZSS Mayak from October 10, 2019 from an industry conference in St. Petersburg, stating “We also found out that the main consumer of ZSS Mayak products is the Russian Navy, although civil shipbuilding also has a wide need for our products.” The post is “liked” by accounts claiming to be Petro Kozlovsky as well as Kozlovsky and ODF associate Konstantin Kozyrev. The beginning of the post is preserved in part here (and in full, untranslated here), including then-owner and US resident Petro Kozlovsky's acknowledgement of ZSS Mayak's meeting with the network of then-US-sanctioned United Shipbuilding Corporation. (Auto-translated from the original Russian.)

THE NETWORK OF FAMILY VENTURES IN RUSSIAN-ANNEXED CRIMEA

The ownership of ZSS Mayak included 50% of shares held by Elena Miroshnikova, the sister of Petro Kozlovsky and Lyudmyla Kozlovska; however, in December 2022, Elena was removed as an owner and the shares previously assigned to her were anonymized. Along with ZSS Mayak, Elena Miroshnikova has owned several businesses in illegally-annexed Crimea that continue to remain active in 2023. She operates as a sole proprietor in several ventures and is listed as such on the Technopark Mayak website in addition to her ownership of companies based there.

Ms. Miroshnikova was active enough in the business scene that she, as a sole entrepreneur, was the plaintiff and winner of a 2018 lawsuit in the Russian Federation courts. The suit was brought against a Russian company for back rent accrued from June to September of 2017, the very month in which ODF claimed none of Ms. Kozlovska’s family members were involved in businesses in Crimea, stating that “it is connected to the Russian occupation of the peninsula.” In fact, Elena has partnered with and participated in multiple conferences in 2020 and 2021 with the Alliance Strategist Crimea, a business network serving "business owners only” in Crimea. At one of these conferences in 2021, in which Technopark Mayak was a partner, Elena was represented as “the owner of [the] Technopark”.

Elena Miroshnikova Featured as "Owner of Technopark" on Alliance Strategist Crimea's VKontakte Page

Elena Miroshnikova (left), pictured above in 2021 at Alliance Strategist Crimea, which represents her as "owner of Technopark". The Technopark Mayak logo can be seen in the bottom right corner. The text is auto-translated from the original Russian. On 11 September 2017, Open Dialogue Foundation, responding to allegations that the family still had business in Crimea, claimed the following: “It’s not true. Lyudmyla Kozlovska’s family members do not run business in Crimea anymore. It is connected with the Russian occupation of the peninsula.”

In October 2022, Sidonia Filippovna Kozlovskaya, the mother of Elena, Petro, and Lyudmyla, was removed as the other beneficial owner of ZSS Mayak. However, public records list a replacement by Olga Timchenko (a/k/a “Olga Kukhta”), a well-documented Kozlovsky family associate who, according to her social media, frequently travels to Moscow. Ms. Kukhta also participates in Alliance Strategist Crimea conferences alongside Ms. Miroshnikova and perennial Mayak/Kozlovsky associate, Natalia Sebyakina-Mailis.

Olga Kukhta in Moscow on January 6, 2023

ZSS Mayak partial owner and Kozlovsky associate Olga Kukhta (a/k/a Olga Timchenko) pictured on her personal Instagram in Moscow on 6 January 2023. The post was “liked” by an account purporting to be Petro Kozlovsky’s wife Viktoria Khukhra, which is followed by Lyudmyla Kozlovska's verified Instagram. Previous Moscow excursions were documented by Kukhta in November and December 2022.

As for Sidonia Filippovna Kozlovksaya, a 2017 claim by ODF stated that, “Petro Kozlovsky and his family members do not run business in Crimea. Lyudmyla’s mother is a pensioner, an elderly person at the age of 74.” Sidonia not only conducts business in the occupied peninsula but benefits directly from the occupying Russian authorities. In September 2022, under her entry as “IP Kozlovskaya Sidonia Filippovna ¹⁰", this “elderly pensioner” won a bid to receive a Russian government grant ¹¹, worth 14.89 million rubles (~€260,000 at the time), for the construction of modular hotel or camping structures in occupied Crimea. Furthermore, Ms. Kozlovskaya also became the owner of property once belonging to the Mayak apparatus at the nearby Karavella recreation center and campground. In 2019, she entered into a series of court cases with the Sevastopol Land Department for rezoning of the property. Lastly, Sidonia is a resident of Technopark Mayak as an individual entrepreneur, with documents featuring her name and signature in 2019 and 2021. The documents are publicly downloadable on a Technopark website and select documents are archived by IEI in case of removal.

Until recently, Petro Kozlovsky’s wife Viktoria Khukhra had also been doing business in occupied Crimea. Ms. Khukhra–who married Petro in 2014–was an ODF donor in 2013, 2014, and 2015 and currently resides in Boca Raton, Florida. Ms. Khukhra is listed in public records as an owner of OOO Monolit, a company founded in 2020 in Crimea at the Vakulenchuka St. 31B address. In 2021, she was listed as owning 99% of shares in Monolit; however, later in that same year ownership was anonymized¹². Ms. Khukhra and Petro Kozlovsky have interacted with and advertised the Technopark Mayak Facebook page prior to and consistently during the Russian annexation, including through 2014, 2015, 2016, 2017, 2018, 2019, and mid-2020, after which point the frequency of Technopark Mayak's posts on Facebook declined drastically. The Facebook account purporting to be Ms. Khukhra's is friends with Lyudmyla Kozlovska's verified account; Mr. Kozlovsky's was publicly tagged by the same verified account.

Viktoria Khukhra Requesting Landscaping Advice for Technopark, August 2014

A Facebook account claiming to represent Viktoria Khukhra asking for landscaping advice for the Technopark Mayak in August 2014, reposting the Technopark’s own message. This post comes six months after the invasion and annexation of Crimea, an event Ms. Kozlovska told Polish Newsweek caused Petro Kozlovsky to “lose everything he left in Crimea” and live "in exile" after his businesses were “unlawfully taken over by occupation authorities”.

The Kozlovsky network extends beyond the immediate family as it is further supported by close associates, morphing into a syndicate; a network whose behavior is more in line with those attempting to elude social, political, and/or economic consequences by obfuscating ownership in complex ways.

Tenants of Technopark Mayak in Sevastopol feature a number of known Kozlovsky associates as well as former ODF donors such as Dmitry Kalinovsky and Maksim Teneshev. Both of these individuals serve as directors of Kozlovsky-owned companies while simultaneously owning their own companies¹³. Teneshev's private security firm SIGMA-KRYM, based at Vakulenchuka St. 31B, holds licenses from Rossgvardiya, Russia's National Guard; Kalinovsky and his activities will be discussed in a subsequent section.

When critics of the foundation alleged in 2017 that Teneshev had “joined the occupation authorities”, ODF countered by saying “The phrases used in Maxim Teneshev’s biography remain broadly unknown to us.” Public records show that Teneshev did in fact swiftly “join the occupation authorities” following the illegal annexation in 2014 by running for political office under a Russian party of which he was a founder.

ODF’S NEW UNITED STATES LOCATION TIED TO THE KOZLOVSKY FAMILY

ODF’s cooperation with the Kozlovsky family may currently extend beyond business links and into material support. IEI analysts identified a stealthily launched United States-based branch of ODF. Open Dialogue Foundations, Inc. was established in May 2022 in Boca Raton, Florida, and its key registrants are Lyudmyla Kozlovska and Bartosz Kramek. It is co-located at an office shared with a consulting company owned by Elena Miroshnikova, who at the time was the beneficial owner of the Ukraine-sanctioned ZSS Mayak. Depending on the terms of the leasing agreement and financial arrangements, this may constitute material support given to ODF. After 6 months of co-domiciliation with ODF, Miroshnikova’s EPK Consulting appears to have been legally closed on 2 November 2022, although IEI confirmed that as of January 2023 EPK signage remained visible on the suite door. Additionally, ODF and EPK Consulting are/were located in the same building as and directly adjacent to the suite occupied by Petro Kozlovsky’s IT business Big Data Services, which deals among other things in cryptocurrency mining. In fact, EPK was initially registered in 2019 directly at Petro Kozlovsky’s companies’ address before relocating to the suite next door in 2021.

EPK Consulting Signage Outside Suite 3004

A sign identifying EPK Consulting outside the office at 950 Peninsula Corp Circle, Suite 3004, Boca Raton, Florida, as posted by Petro Kozlovsky’s employee and perennial Kozlovsky associate Alexandr Staroverov in September 2022. At the time the suite housed Open Dialogue Foundations, Inc. alongside EPK Consulting, registered to then-ZSS Mayak owner Elena Miroshnikova. The adjacent suite 3005 was occupied by Petro Kozlovsky’s business Big Data Services/Clever Miners. IEI confirmed EPK signage was still visible at the site as of January 2023.

In September 2022, Petro Kozlovsky’s employee Alexandr (a/k/a “Oleksandr”) Staroverov, serving as the registered agent for EPK, used his Facebook account to advertise for sublease the partially vacant suite once occupied by EPK (above). Mr. Staroverov is a Kozlovsky associate from Sevastopol and a founder of the Russian Party of Pensioners, who relocated to Boca Raton and now works for Petro Kozlovsky as a Project Engineer at Big Data Services. Presently, he is the registrant for at least three websites serving the Technopark which are maintained by Dmitry Kalinovsky; technoparkmayak.info and mayak.tech are registered to him at a Sevastopol address. Ipmayak.info, which possesses a subdomain that appears to serve the Technopark, is registered to Mr. Staroverov with a Sferos.com email and a Boca Raton, Florida address.

The landing page of ipmayak.info, registered to Oleksandr Staroverov at a Florida address, and a subdomain, inv.ipmayak.info, which showcases the Technopark Mayak logo and translates to “Storage.Mayak Management.”

Further demonstrating the convergence between the parties in Boca Raton and Technopark Mayak in Sevastopol is a US company held by Mr. Staroverov, Smart Load Systems LLC, which has recycled its authorized representatives remotely from Sevastopol. At its 2020 founding, Technopark Mayak tenant and ATM member Konstantin Korolkov was listed as an authorized representative with the ability to file business documents with the state of Florida. From 2021 to 2023, Technopark resident and current ZSS Mayak owner Olga Kukhta replaced Korolkov as an authorized member. Subsequently on January 30, 2023, Ms. Kukhta was then replaced by Petro Kozlovsky’s Florida-based wife Viktoria Khukhra, who owns the residential property where the company is presently based which is also a registered address of Petro Kozlovsky. Smart Load Systems, like Mr. Kozlovsky's own business, deals with cryptocurrency mining and advertises servers branded with Kozlovsky’s Big Data Services logo.

Despite a 2019 assertion by Mr. Kramek that some Kozlovsky family members are “vatniks,” (a pejorative term for pro-Russian sympathizers or collaborators), professional ties between ODF, Lyudmyla Kozlovska, and her siblings Petro and Elena, both of whom have been beneficial owners of a plant that has served the Russian navy, appear to have been active up to mere months before the publication of this investigation, as evidenced by their simultaneous use of the same business location during 2022.

While touting itself as a defender of human rights and a staunch ally of the Ukrainian people in the face of Russia’s imperial conquest of Ukraine, ODF has without public mention domiciled its US presence hand-in-hand with the owner of a Ukrainian-sanctioned entity that has supplied Russia’s military apparatus, and who has publicly been presented as the owner of a Technopark serving the interests of the Russian government. It is a particularly interesting choice of domiciliation for Ms. Kozlovska, given ODF's claims that she was the “leader of the campaign for the removal of the Black Sea Fleet of the Russian Federation from Sevastopol in 2005-06”. Yet she established the US branch of her organization in apparent cooperation with and alongside an owner whose company was awarded a 5-star review by the leaders of that same Black Sea Fleet.

III: BIRDS OF A FEATHER: CONTROVERSIAL FUNDING SOURCES

WHO OR WHAT FUNDS ODF?

Open Dialogue Foundation’s sources of financing have historically been mired in multiple controversies, and the organization pivots from one source to another when one becomes politically, socially, or legally inconvenient. While changing sources of funding over time is by no means unusual for an NGO of ODF’s age, it raises many questions from others in the space that the dominant sources of its funding are continually linked to allegations of financial misconduct. The organization has cycled through controversial family support, to support from companies facing allegations of financial criminality, and finally to degrees of anonymity in the form of crowdfunding and cryptocurrency.

In the early days of ODF, the foundation was funded almost entirely by Lyudmyla Kozlovska’s family and their business network. Petro Kozlovsky was by far the primary individual funder, having contributed ~1.6 million zloty (~€340,000) between 2012 and 2015, after which ODF claims he lost his financial stability following the occupation of Crimea, left for the United States, and ceased contributions to ODF. However, as demonstrated in the above sections, Mr. Kozlovsky has consistently maintained and still maintains business interests in illegally-annexed Crimea, both personally and through his close family members and associates. Additionally, ODF’s leadership has stated that at least as late as 2017, they were personally funding the foundation using funds from Ms. Kozlovska’s family members and private business with Mr. Kozlovsky.

For the most part, other early top individual donors of ODF are also linked to the Kozlovsky family and their Sevastopol network, including the following names, most of whom have been mentioned in the above sections:

Arkady Agarkov, a ZSS Mayak employee who gave 441,894 zloty (~€94,000) between 2013 and 2014. In 2019, Agarkov represented ZSS Mayak at an industry trade show in St. Petersburg.

Viktor Miroshnikov, nephew of Lyudmyla Kozlovska and son of Elena Miroshnikova. A perennial business partner of Bartosz Kramek, Miroshnikov contributed 338,341 zloty (~€72,000) between 2013 and 2016.

Andrei Vladimirovich Brovchenko, possibly the son of a former co-owner of the Mayak Sevastopol plant, Vladimir Brovchenko. Andrei has used an email address whose suffix, lumino.ru, presently redirects back to the ZSS Mayak Sevastopol Facebook page. Andrei contributed 176,353 zloty (~€37,000) in 2013.

Maxim Teneshev contributed 64,457 zloty (~€14,000) in 2012. Teneshev is currently part of the Technopark Mayak structure and the broader Kozlovsky business network as the director of OOO Tinos, a company in the Kozlovsky network of which Petro Kozlovsky is the ultimate owner. Teneshev is also a founder of the Sevastopol branch of the Russian Pensioners’ Party for Social Justice and ran for election as part of that group in August 2014.

Viktoria Khukhra, the wife of Petro Kozlovsky (married in 2014), donated 44,895 zloty (~€10,000) between 2013 and 2015. Ms. Khukhra was also an owner of the Sevastopol company OOO Monolit, founded in 2020, six years after the illegal annexation.

Elena Miroshnikova, the sister of Petro and Lyudmyla Kozlovsky, is the owner of a number of the companies in the nested structure, and until December 2022 a 50% owner of the sanctioned ZSS Mayak plant. Elena donated 29,958 zloty (~€6,000) in 2014. Elena’s company and Lyudmyla’s ODF branch in the US were simultaneously domiciled in the same Florida office suite from May 2022 until November 2022.

Dmitry Kalinovsky is a minority owner of OOO Ilion in the Kozlovsky/Mayak structure alongside Elena. Kalinovsky donated 23,970 zloty (~€5,000) between 2013 and 2014. Kalinovsky is most notably an administrator of the Sferos.com domain, on which numerous Kozlovsky-linked websites and email addresses are registered. He is also the director of the Kozlovsky-owned OOO ZSS and owns his own company, OOO Degenerator, located at the Technopark.

The above names are in addition to Lyudmyla Kozlovska and her husband Bartosz Kramek themselves, who have both made substantial personal donations to ODF over the years, as well as through their company Silk Road.

After the illegal annexation of Crimea, ODF apparently shifted, in part, its funding to Silk Road and to Ms. Kozlovska and Mr. Kramek personally; however, in July 2017, they stated that some of these personal donations were made possible by “funds from [Ms. Kozlovska’s] family members”. Silk Road has served as a major donor, and sources confirm to IEI that Mr. Kramek remains under investigation as of February 2023 for allegedly falsifying records and money laundering involving the company. Ms. Kozlovska and Mr. Kramek were doing business with Petro Kozlovsky at least as late as 2017, during which time Mr. Kozlovsky was the beneficial owner of an entity receiving contracts from at least one Russian company subject to US sanctions. Furthermore, as discussed above, ODF may have materially benefited from proximity to Russian-linked businesses in 2022, based on the co-domiciliation of its US branch with ZSS Mayak owner Elena Miroshnikova’s Boca Raton company EPK Consulting, located one suite away from the office used by Petro Kozlovsky.

One of ODF’s top donors was Igoria Trade, which donated a total of 449,819.96 zloty (~€96,000) in 2014 and 2015. Following 2015, it is alleged that Igoria Trade knowingly became part of a conspiracy to defraud cryptocurrency investors, in part, by having their funds deposited into Igoria accounts. In 2021, Igoria Trade was named as a co-defendant in a multi company class action lawsuit pertaining to a fraudulent cryptocurrency scheme that defrauded investors of at least $15 million dollars. OneCoin, an entity responsible for orchestrating one of the largest multi-billion-dollar cryptocurrency Ponzi schemes in history, was according to uncorroborated allegations directing their clients to deposit funds into an account held by Igoria Trade.

Kramek and Kozlovska’s company Silk Road, which is co-domiciled with ODF, was a major donor to the foundation, contributing nearly 2.6 million zloty (~€555,000) from 2014-2019. In 2020, the company donated a small sum of ~6,000 zloty (~€1,300) as funding shifted to largely unattributable online “crowdfunding” campaigns. Subsequently in June 2021, Mr. Kramek was detained in Poland on suspicions of money laundering activities between 2012 and 2016 involving key ODF donor Silk Road, with allegations of having commingled laundered funds with ODF.

Subsequent to Mr. Kramek’s arrest on suspicion of money laundering and in the wake of the Russian invasion of Ukraine in February 2022, the foundation claimed to be collecting donations through cryptocurrency, a funding mechanism known for its anonymity and difficulty to trace. Ms. Kozlovska touted ODF’s use of cryptocurrency in late 2022, citing an unspecified amount of cryptocurrency donations from the US and EU via Bitcoin and Tether. Although their website does not provide a crypto wallet or other means by which to donate cryptocurrency, a June 2022 tweet by the foundation states that without the ‘crypto community’, “many of the donations we receive wouldn’t happen.”

Recently, Ms. Kozlovska, married to a man under investigation for money laundering and herself serving as the VP of the company linked to alleged money laundering; whose brother, former business partner, and ODF’s Boca Raton neighbor owns a business dealing in cryptocurrency mining; has gone on the conference circuit touting cryptocurrency’s expediency in human rights situations and painting a pivot to cryptocurrency as a necessity. Throughout the latter half of 2022 and currently in 2023, ODF seeks to dispel associations of cryptocurrency with financial crime and influence institutions and public opinion regarding upcoming EU legislation aimed at regulating cryptocurrency, with Ms. Kozlovska fearing that new legislation could result in them “losing access to the services of crypto providers [if] Bitcoin service providers are regulated in the same way as banking and financial institutions.” Ms. Kozlovska has been joined by fugitive-turned-asylee and frequent ODF associate Botagoz Jardemalie, who has also been linked to accusations of money laundering. According to documents seen by investigative journalists at BuzzFeed, Ms. Jardemalie was linked to a number of companies frozen by a UK judge who stated "... that there is good reason to believe that they are all in Mr. Ablyazov's ultimate beneficial ownership,” referring to fugitive kleptocrat and fraudster Mukhtar Ablyazov.

By Ms. Kozlovska’s own admission and corroborated via documents seen by IEI, Open Dialogue Foundation, in the latter half of 2022 and in conjunction with its participation in public panels, has begun attempting to engage EU and other Brussels-based institutions in an attempt to influence policy and public opinion by de facto lobbying against, among other things, the upcoming implementation of EU legislation that will increase regulation for cryptocurrency transactions. This is an issue the Foundation and its leadership prefers to link to human rights applications, but in light of their donor pool and the myriad of charges therein, should raise eyebrows in the third sector and well beyond.

IV. QUESTIONS ABOUT THE OPEN DIALOGUE FOUNDATION

WHY DOES ODF DENY THE PROVENANCE OF KOZLOVSKY FUNDS?

Valid questions about the Open Dialogue Foundation have been raised for years. ODF and its leadership–Ms. Kozlovska and Mr. Kramek–have been given ample opportunity and platforms to address these questions with honesty but have, for over half a decade, persisted in disseminating a narrative that the Kozlovsky family maintains no business interests in illegally-annexed Crimea and that any evidence to the contrary is falsified. The foundation has sought to deflect warranted skepticism by framing themselves as a perpetual victim of political persecution, and in doing so conveniently avoids addressing said skepticism.

Over the years, the human rights space and prominent Western institutions have been asked to believe the Open Dialogue Foundation is “the most pro-Ukrainian and definitely anti-Russian foundation”. However, the foundation’s deliberate position of willful blindness casts doubt on such a classification and begs the question: Why has the self-proclaimed “most pro-Ukrainian and definitely anti-Russian foundation” drawn support from and co-domiciled itself with family members that have engaged in business relationships with the Russian state in the illegally-annexed territory of Crimea, while unequivocally denying that such business is taking place?

Publicly-available databases confirm the Kozlovsky family’s consistent business interests and relationships in Sevastopol, corroborated by the family and its network’s own behavior in Crimea, in Florida, and on social media. Denying, ignoring, or feigning lack of knowledge of this business while receiving support from the family speaks, at best, to ODF’s deliberate moral and financial willful blindness.