notes

Note: Ownership of the Max Polyakov E-Commerce Ecosystem

The Grift Empire: Documenting Polyakov's financial interest in ClickDealer, Maxpay, and their related entities.

Published Oct 5, 2022

At a Glance:

  • * Max Polyakov owns at least ~20% of ClickDealer's parent company as an individual, and may own more via a company registered in the United Arab Emirates.
  • * Max Polyakov owns 70% of Maxpay's parent company.
  • * Max Polyakov owns 90% of Covery's parent company.

GDM Group and Clickdealer

1.1. Polyakov Owns, at Minimum, ~20% Of GDM Group and ClickDealer

GDM Group, which stands for Global Digital Marketing Group, is a group of companies linked to Polyakov that includes, at minimum, the affiliate marketing agency ClickDealer. Between 2016 and the time of this reporting, the legal entity doing business as GDM Group, according to the websites' terms of service, has shifted between entities in the Netherlands, Cyprus, and Hong Kong.

According to GDM's website, the entity responsible at the time of this reporting is the Hong Kong company GDMgroup Asia Limited:

“Website” means gdmgroup.com. “You” means you as a visitor or user to the Website and shall apply to you as an individual and to your business entity if you purport to represent such an entity.

“We/us/our” means GDMgroup Asia Limited and Address: Office A, 16/F Heng Shan Centre 145 Queen’s Road, East, Wan Chai, Hong Kong.

gdmgroup.com Terms of Service

ClickDealer presently does business as GDMgroup Asia Limited as well, according to the current terms of service. As of March 2022, GDMgroup Asia Limited, according to Hong Kong business filings, is wholly owned by the Cyprus company G.D.M. Group Holding Limited.


Hong Kong Companies Registry

According to Cyprus records, Polyakov owns a significant percentage of that company's share capital. In terms of individual owners, Polyakov owns more shares than any other individual person — he owns just under 20%. Other individual owners include ClickDealer and/or Noosphere executives.

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Cyprus Department of Registrar of Companies

Only the corporate entity I.S.P. Assets FZE, registered in a United Arab Emirates Free Trade Zone, holds more shares. For several reasons outlined below, this company appears to be closely connected to Polyakov, as well.

1.2. Polyakov May Own More of GDM Group via the UAE Company I.S.P. Assets FZE

I.S.P Assets FZE is, or has recently been, a shareholder in nearly all of Polyakov's major corporate ventures. Until September 2021, I.S.P. Assets FZE, as described in detail below, was a shareholder in the Polyakov-owned payment services provider Maxpay. According to leaked files viewed by Snopes contained in a collection of documents known as the Pandora Papers, I.S.P. Assets FZE was also a shareholder in the Polyakov gaming company Murka prior to its sale to Blackstone Group.

In addition to being a shareholder in multiple entities linked by their connection to Polyakov, I.S.P. Assets FZE, based on U.S. Department of Transportation charter flight records, appears to have been an entity used in at least one instance to charter a plane from Edinburgh, Scotland (Polyakov's present residence) to Oakland, California (which services the Palo Alto region, where Polyakov formerly ran Noosphere Ventures and resided with his family):


U.S. Department of Transportation (X-40 Office)

As a result of the uncertainty regarding Polyakov’s interest in — and control of — I.S.P. Assets FZE,  it is possible that some shares in G.D.M Group owned by I.S.P. Assets are controlled by or benefit Polyakov as well. As a result, the minimum percentage of G.D.M. Group owned by Polyakov is the 20%, he owns personally, but depending on his potential share of I.S.P. Assets FZE, he could effectively own almost 90%.

Maxpay and Covery

2.1. Polyakov Owns 70% of Maxpay

As described on the terms of service page for maxpay.com, Maxpay's legal name is Maxpay Limited. Maxpay Limited, based on its most recent annual return (2021), is wholly owned by Maxpay Holding Limited — a Maltese company registered at the same address as Maxpay Limited:


Maxpay Limited Annual Return (2021)

A September 2021 return listed four shareholders in Maxpay Holding Limited: 

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Maxpay Holding Limited Annual Return (2021)

In addition to Polyakov, a man matching the name of a Polyakov legal adviser, Ihor Spodin, and the CEO of Maxpay, Artem Tymoshenko, are both shareholders. I.S.P. Assets FZE, mentioned above, held shares in Maxpay, too. A supplemental filing indicates that, after the return was filed, one of those shareholders, I.S.P. Assets, transferred 100% of its shares to Spodin:

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Transfer of Shares from I.S.P. Assets to Ihor Spodin on Sept. 9, 2021.

Based on these filings, at the time of this reporting, Max Polyakov owns 70% (1,100 shares) of Maxpay Holding Limited, Maxpay Limited, and Maxpay.com. 

2.2 Polyakov owns 90% of Covery

For most of their existence, both Maxpay and Covery were part of the Malta-based entity Maxpay Limited, as shown in Maxpay's terms of service from February 2022. References to Covery in Maxpay's terms of service were removed later, as shown in this archive of Maxpay's terms of service from September 2022.

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Covery Terms of Service, February 2022

At some point after April 2022, the Cyprus-registered company Covery AI Limited became the legal entity behind Covery.ai, per its terms of service. Covery AI Limited was registered on April 4, 2022:


Cyprus Department of Registrar of Companies

Max Polyakov owns 90% of this company's shares. Maxpay CEO Tymoshenko owns the remaining 10%:

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Cyprus Department of Registrar of Companies

Alex Kasprak is an investigative journalist and science writer reporting on scientific misinformation, online fraud, and financial crime.

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