The Kroll report, titled "Project Ritchie," detailed multiple ways in which a group of online merchants generally tied to a now-convicted money launderer, Hamid "Ray" Akhavan, allegedly coordinated with each other to conceal high levels of chargebacks from Visa and Mastercard. The scheme operated out of the Cyprus-based Federal Bank of the Middle East (FBME)'s card services division in the early 2010s.
Portions of the report were first reported on by BuzzFeed News in a series of articles about FBME's widespread corruption, published in 2017. The full Kroll report was published by Forensic News in July 2020 and can be viewed here. The excerpt below outlines the broad features of the scheme investigated:
Max Polyakov's Involvement with FMBE's Card Services Division:
Max Polyakov is explicitly named several times in Project Ritchie. A company associated with Polyakov and his dating empire, Bulova Invest Limited, is named in a section of the report titled, "Fraudulent activity through merchants linked to Akhavan." The subscription-trap model of these sites is also explicitly highlighted:
While Kroll did not identify a direct link between Akhavan and Polyakov, Snopes notes in its reporting that Maxpayments — a credit card-processing company alleged by Kroll to be associated with Akhavan that preceded Polyakov's Maxpay — frequently advertised its services to online dating companies and hosted sponsored parties attended in at least one case by Polyakov himself.
Further, Polyakov and his dating businesses also appear in a section of Project Ritchie titled "Active accounts relating to Akhavan / FBMECS Promo Scheme" via a company, Opalta Ltd. Opalta Ltd was once a shareholder in the private predecessor to the publicly traded Polyakov dating venture Cupid plc: Easydate.
Documents contained in a collection of leaked files published by the International Consortium of Journalists (ICIJ) known as the "Panama Papers" indicate that Polyakov and an apparent relative were shareholders of that company.
Optalta Ltd, Kroll's investigators alleged, received funds from the aforementioned Polyakov dating company Bulova Invest. This company also remitted funds to a Cyprus-based account tied to Polyakov as well:
From their inclusion and descriptions above, it is clear that Polyakov's Bulova Invest Limited and Opalta Limited were "active" beneficiaries of the same scheme identified in Project Ritchie.
Maxpayments and Online Dating
The Kroll report suggests that the collection of merchants under the control of Akhavan were part of a group of merchants associated with a payment gateway named Maxpayments:
Other portions of Project Ritchie make clear these references to Maxpayments are to a specific and now defunct company that had been based based in Woodland Hills, California.
Methods Employed by FBME's Card Services Division To Reduce Chargeback Ratios
Project Ritchie described "a systematic process … developed within FBMECS for monitoring chargeback ratios and diluting these chargeback ratios with a high volume of fake transactions":
One scheme involved using internally sourced credit cards to make purchases across a large collection of online merchants all broadly linked to the scheme's operator. This, Kroll's investigators explained, "gives the effect of spreading the transactions for one merchant ID over a number of URLs over a number of different days, in order to avoid raising suspicion":
As part of that scheme, Project Ritchie states, myriad shared companies using false beneficial ownership information had to be created in the U.K. and in Cyprus:
These last two features appear to share aspects with the present set up of Polyakov's Together Networks, described in Part III of our investigation. In that scheme, multiple dating websites use a rotating and shared cast of shell companies linked to online merchants for billing while using a similarly shared collection of URLs to describe their charges on bills.