Suppose you’re a gambling (or “iGaming,” as it is called nowadays) company and you want to process multiple payments, potentially not legal, as smoothly as possible. It seems natural to assume this shouldn’t be allowed. After all, compliance regulations in the banking industry are generally stringent, and such “commercial initiatives” would typically be nipped in the bud.
However, there is a loophole.
This loophole is called Dominica, a small island state in the Caribbean. Dominica’s banking law is extremely liberal. It allows one to register a bank for just $2 million: $1 million for a license fee, and $1 million deposited in a local bank. This isn’t a high bar for the finance industry. Moreover, Dominican law fails to clearly distinguish between payment processing systems, banks, and other financial services providers. Serving so-called “high-risk” clientele represents a lucrative business opportunity—these clients want to use banking and payment services but are denied by mainstream institutions. High-risk clients are vulnerable and unlikely to complain to the authorities, which makes them prime targets for exploitation. This combination makes Dominica a sweet spot for shady financial intermediaries, especially after the advent of the crypto industry.
One of these intermediaries was Migom.
What is Migom?
Migom is more like a payment platform, imitating a “bank” by offering services commonly provided by banks, such as holding money in a virtual “deposit.” It was registered in Dominica’s capital, Roseau, at 75 Hillsborough Street—the same address as the constituency office of Melissa Ponponne Skerrit, a member of Parliament and wife of Prime Minister Roosevelt Skerrit. This curious overlap raises questions: Could Migom have grown (and fallen) under political patronage from Dominica’s top government officials? History may eventually provide answers.
Roseau, at 75 Hillsborough Street
Migom Bank was founded by Michael Guss around August 2019. Guss, formerly known as Mikhail Syroejine in the 1990s, has a history that includes a felony conviction for money laundering in 1996. This conviction ostensibly barred him from the legitimate financial industry, but Migom’s creation indicates otherwise. Through U.S.-registered Heritage Equity Fund LP, Guss and his wife Lidia Zinchenko structured Migom’s operations to appear legitimate while siphoning client funds and evading scrutiny. Guss operated in the shadows, and Zinchenko formally owned Heritage Equity Fund, which had been purchased from its previous owner, Oleg Jitov.
One former Migom employee, when asked about Michael Guss, declined to name him outright, quipping, “I want to live.” While perhaps joking, the comment underscores Guss’s reputation for being a potentially dangerous figure.
Michael Guss/Syroejine
The Business Model
However, that wasn’t the main Migom financial innovation. Michael Guss realized that the best way of operating a shady payment platform is to lure customers by a promise of stable service, but suddenly deny withdrawal of funds and completing transactions, asking for more and more additional “compliance fees,” which may sound like a reasonable cause of concern. It happens with any financial institution, but Migom managed to make this practice a key element of making profits. Of course, this venture can work only if a constant influx of clients is maintained, making this “model” very similar to a financial pyramid. The client’s funds were siphoned out, sometimes to crypto-accounts. A famous British investigator, Andrew Wordsworth, with wide experience of working with Russia, may have helped Migom to forge police reports, according to court case materials. It is also reported that Michael Guss bought a 60-meter yacht, a private jet, real estate in the UAE and England, but these properties are extremely hard to pin down. It’s also possible that Migom was also used by those actors in Russia and Iran that are troubled by sanctions.
Migom adopted the “neobanking” model, a trend in the financial sector where banks outsource many key functions—such as accounting, marketing, and client support—to reduce costs. This also blurred the lines of responsibility, enabling Migom to evade financial controls. Its business heavily relied on “high-risk” clients, individuals and entities shunned by traditional banks.
Marketing operations, outsourced to Cyprus-registered Deronica Ltd and led by Evgeniy Kabanov, were highly effective, attracting a broad spectrum of clients, including those outside the high-risk category. A former Migom employee noted the disparity in staffing, with marketing teams significantly outnumbering compliance and operational staff. These tactics resulted in an influx of funds, which Migom’s leadership used to fuel their fraudulent schemes.
Evgeniy Kabanov
Migom promised stable service but routinely blocked client withdrawals, citing fabricated “compliance fees.” Client funds were then siphoned into external accounts, often converted into cryptocurrencies. Key financial partnerships with Lithuania’s Transactive Systems UAB and Switzerland’s Incore Bank bolstered operations until these institutions severed ties upon discovering Migom’s malpractices.
The Collapse
By Fall 2022, Migom’s operations began to unravel. The collapse was precipitated by the suspension of Transactive Systems UAB’s license, which disrupted Migom’s ability to process transactions. Even before its downfall, Migom had redirected significant sums to purportedly legitimate investments, including shares in Latvia’s Baltic International Bank SE. This institution, however, also had its license revoked amidst allegations of laundering funds for Russian oligarchs and Mexican cartels.
To distract from its fraudulent practices, Migom financed articles that blamed its collapse on supposed fraud by Latin American operatives. These articles were often anonymous or attributed to fake names, including one published under a hijacked identity. If you steal money, sooner or later you might steal names too.
Key Players
- Michael Guss (Mikhail Syroejine): The mastermind behind Migom, Guss controlled operations through proxies, maintaining a reputation that oscillated between conman and shadowy informant. Another source from among Migom employees said he had never heard about Michael Guss but told an elaborate story involving prominent members of the business and political establishment, potentially including high-ranking Western securocrats. While this narrative may have been fed to low-ranking employees, it hints at Guss’s audacious style.
- Lidia Zinchenko: Guss’s wife and a key proxy, formally owning Heritage Equity Fund and managing related entities.
- Evgeniy Kabanov: Head of marketing, whose aggressive strategies inflated Migom’s client base.
- Mark Berkovich: A senior manager responsible for coordinating client acquisitions. Residing in the UAE, he remains closely linked to other Migom offshoots.
- Anna Oravcova: As director of Deronica Ltd, she oversaw Migom’s largest operational department—marketing. According to former employees, Oravcova prioritized expanding client numbers over addressing structural weaknesses.
- Rosaline Agiamoh: Former head of business development at Deronica Ltd and Regional Sales Head at Migom DMCC. Rosaline played a crucial role in expanding Migom’s client portfolio. She later transitioned to roles at Ghraizi & Partners Limited and Monetex, raising questions about these firms’ ties to Migom.
- Thomas Shaetti: A ceremonial president who publicly defended Migom but is implicated in unauthorized transactions.
- Tatjana Gutschmidt El Chbeir: A Swiss manager and former Rothschild & Co. employee, who played a role in financial operations.
- Igor Vakhonin: Migom’s key operative in the UK, responsible for attracting clients and expanding operations into Russian and Hong Kong markets.
Systematic Fraud and Offshoots
Desiring to remain in the shadows, Michael Guss and his assumed accomplices employed a handful of figureheads to manage Migom. One of the most important of them was Thomas Shaetti (or Shätti), who was a formal president of Migom Global Corp and Migom’s media representative of sorts. In January 2023, Shaetti ranted on Twitter regarding Migom’s and Baltic International Bank’s problems, asserting that Migom’s collapse was a result of an attack on its totally decent reputation by some mysterious adversaries. The rant was richly illustrated by one of the most cringeworthy attempts at attention-grabbing in the history of finance, which is surely a success, but the meager public reaction likely left Guss much to be desired. Paradoxically, in one of the lawsuits Shaetti is accused of investing in the Baltic International Bank on his own accord, without approval of “Migom shareholders.” One of our sources from former Migom employees insisted that Shaetti was only a ceremonial head.
Some Migom employees as defendants. Michael Guss is conspicuously absent
However, Schaetti doesn’t look like a clueless pawn or a muppet. His connections could stretch to the highest levels of Austrian politics. One lawsuit names Johann Gudenus as his helper — he was a former deputy leader of the Austrian Freedom Party (FPÖ) and the member of the National Council, taken down after a video recorded in Ibiza emerged in 2019, in which Gudenus discussed exchanging government contracts for positive media coverage with a Russian woman pretending to be a relative of a Russian oligarch. The ensued scandal toppled the Austrian government and triggered a snap election; Gudenus became unemployed. Hopefully, Migom helped him to sustain himself. It’s remarkable that Gudenus knows Russian and acted as an interpreter in the video. Could he also have helped Schaetti to communicate with Michael Guss and Migom’s clients from Russia?
Another notable figurehead was “His Royal Highness Prince Maximillian Habsburg,” Chairman of the Board of Directors of Migom Global Corp and the formal head of Migom’s French branch. Featuring a number of low-profile financial companies in Austria, his position lent an air of aristocratic legitimacy to the enterprise while obfuscating the firm’s shady dealings. We have also seen him posing as an executive for several other dubious ventures involving opaque sources of funding and significant investor losses, including a “highly promising” medical startup targeting investors from post-Soviet countries—who all ultimately lost their money.
Key associates destroyed financial records and manipulated accounting systems to obscure evidence, with Juergen Blaha and Stefen Lehnhart leading these efforts. Benno Klebl, despite lacking a documented connection to Migom, likely advised on financial maneuvers, leveraging his background in German and Austrian central banks.
One of Migom functionaries is Tatjana Gutschmidt El Chbeir, disclosed as a general partner in Heritage Equity Find LP in Migom SEC documents, who is currently a managing director of the Swiss branch of Migom Bank, Migom Verwaltung AG. She is also a board-president of an old people’s home of St. Nicholas in Maur, Zürich (A possibility to redeem herself?). She seems to possess some expertise in financial matters: she worked in Zürich as relationship manager for Rothschild & Co. and as “officer” for leading British bank Coutts. It’s unlikely that she was unaware of what is going on in Migom.
A notable Guss’ comrade-in-arms was Mark Berkovich, who was a former manager of Latvian and Russian branches of Migom and also a “consultant” to Kabanov in Deronika Ltd – he seems to be a dear friend or partner to Kabanov and lives in the UAE. He has likely helped Kabanov attract clients and Guss — orchestrate the whole stunt.
The team would be incomplete without another member, Georgi Parrik, former CEO of Migom Global Corp, and also CEO of a number of Estonian and Canadian companies, connected to entertainment industry and financial services.
Georgi Parrik himself
According to the market insiders, the key Migom’s operative in Britain was Igor Vakhonin, formally Migom’s vice-president in investments and business development. Vakhonin ostensibly met a number of prospective clients in the UK, explaining to them the benefits of working with Migom, but some Migom’s employees in the London office do not know him (or knew him under a different name). He also worked with Russian and Hong Kong markets. However, he denied his current involvement with Migom.
Igor Vakhonin
Some clients also worked closely with Rosalia Agiamoh, former head of business development at Deronica Ltd and Regional Sales Head at Migom DMCC. She now works for Ghraizi & Partners Limited (G&P Ltd), offering company formation, banking, HR, and consulting services, and also for a payment aggregator Monetix. Can these companies be Migom in disguise? It’s not confirmed as of yet. But Guss and his henchmen definitely grew a number of sprouts from Migom.
Legal Actions and Investigations
Authorities in the U.S. and Latvia have launched investigations into Migom’s fraudulent operations:
- United States: The SEC is probing fraudulent filings and misuse of funds, with Michael Guss and Lidia Zinchenko as primary targets.
- Latvia: Investigations focus on Migom’s ties to Baltic International Bank, revealing efforts to destroy financial records and obscure transactions.
- Switzerland and the UK: Despite clear indications of Migom’s activities, investigations in these jurisdictions remain slow.
- Dominica: We have contacted several officials there but they refused to comment.
Lessons from Dominica
Migom’s rise and fall exemplify the risks posed by lightly regulated financial jurisdictions like Dominica. Its loopholes allowed entities like Migom to operate with impunity, exploiting high-risk clients and siphoning billions under the guise of financial innovation.
The next chapter in this story will explore how the same individuals and their offshoot ventures continue to exploit these gaps, creating new entities poised to repeat Migom’s fraudulent trajectory. It is highly likely that the funds being used to establish these ventures are drawn directly from Migom’s defrauded clients, adding another layer of injustice to an already egregious scheme. Unless regulatory frameworks adapt, these schemes will persist, perpetuating harm to global financial systems.
If you have any information about Migom or the companies and individuals associated with it, please contact us at [email protected]. Your input could greatly assist our ongoing investigation, which is far from over.
Our thanks go to the team at https://AssetTracing.com for their assistance in preparing this investigation
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