At first glance, Lemixton Solutions Ltd could hardly have looked less remarkable: a simple, single-shareholder British company, owned and run by a 71-year-old horse-loving grandmother from Kent, that hadn’t traded since 2020.

But thousands of miles away in Central Asia, reporters from Finance Uncovered and OCCRP found Lemixton on an Uzbek procurement website, apparently winning millions of dollars in business from state-owned mining and industrial giants—activity entirely absent from its UK filings.

When reporters contacted the company’s director, Wendy Conroy, about this contradiction, it triggered a flurry of filings and accusations of fraud and deception – and the façade of a simple one-woman business began to crumble.

Further reporting revealed a hidden web of corporate complexity: a power of attorney, a nominee agreement and a trust.

Each thread pointed back to More Group, a 40-person corporate-services agency in London founded by 48-year old chartered accountant Mike Conroy—who is Wendy Conroy’s son.

For years, More Group had supplied clients across the former Soviet Union with British corporate structures designed to shield their identities.

Only after reporters began asking questions did the paperwork suddenly change. Wendy Conroy resigned, and two unfamiliar figures appeared in Lemixton's filings: first, an Uzbek table tennis federation official was briefly named, before being withdrawn and replaced by a poker-playing Colombian national living in South Korea. Even with these new names, the identity of the ultimate owner remains unclear.

The services More Group provided to the unnamed client behind Lemixton expose persistent weaknesses in the UK’s corporate registry, Companies House. Despite transparency reforms meant to flush out any hidden controllers of UK companies, it remains entirely possible—with professional assistance—to create opaque British shell entities for overseas business figures.

UK Labour MP Phil Brickell, chair of the UK parliament’s all-party group on anti-corruption, said: “This troubling case calls into question the effectiveness of some of our first lines of defence against suspect financial activity.

“The information provided to Companies House appears to have been of little to no help in identifying who really owns and controls this company. Indeed, the Uzbekistan public procurement register seems to have been of substantially more use in establishing whether it is actually being run from Kent, or Tashkent.”

A dormant company with a double life

Reporters first spotted Lemixton when examining Uzbekistan’s searchable public procurement database—introduced in 2020 as part of transparency measures designed to improve the country’s corruption-tainted reputation.

Journalists from Finance Uncovered and OCCRP—as well as Ulster University Professor of Criminology Kristian Lasslett—reviewed and analysed hundreds of tenders awarded by state-owned industrial giants.

Lemixton immediately stood out. Despite declaring itself dormant in the UK, since 2022 it had won 63 tenders, worth about $24.7 million to supply industrial materials and spare parts, mostly to Almalyk Mining & Metallurgical Complex, one of the country’s largest state-owned enterprises.

Copies of several contracts with Lemixton, available on the registry, set out the terms of its supply deals in detail. They included what appeared to be facsimile signatures of Lemixton’s director, Wendy Conroy—often visible on every page. The contracts also directed payments to an account at Kaleido Privatbank—recently renamed Banque Richelieu Switzerland—in Zurich. There is no suggestion of wrongdoing by the bank.

Looking beyond the Uzbek procurement register, journalists found customs declarations that appeared to confirm Lemixton had been a genuine supplier of goods to Uzbekistan for years. There is no suggestion of any wrongdoing in relation to the shipments made by Lemixton.

Back in the UK, Wendy Conroy had not reflected a penny from the Uzbek deals in Lemixton’s annual accounts for four years. Throughout the period, the accounts instead declared that Lemixton had been dormant.

Those filings also included puzzling details. In its 2019 accounts, Lemixton reported $3.6m in cash holdings, offset by debts. These amounts did not change for the next five years, apparently failing to accrue any interest.

Under UK law, a company that is signing contracts and shipping goods is not dormant, and directors who file false accounts “without reasonable excuse” can face prosecution.

When Finance Uncovered attempted to contact Wendy Conroy, she did not respond. Instead, a representative from More Group replied on her behalf.

Its client-relationship director, Jaime Barclay, said Wendy Conroy was merely an “internal nominee director” supplied to clients. By email, More Group later added that the agency’s client had been granted broad authority to act on Lemixton’s behalf under a general power of attorney.

Barclay also stressed that Wendy Conroy had never signed any Uzbek contracts, calling the situation “a major fraud for us”.

It is not illegal for a person to repeatedly use a facsimile copy of their own signature on legal paperwork. However, to add another person’s signature to an agreement without their permission is considered forgery, a criminal offence in both the UK and Uzbekistan.

Asked who filed Lemixton’s paperwork at Companies House, Barclay explained filings were made through More Group.

“Ms Conroy is an old lady. She…would not be able to file [documents] on Companies House,” Barclay said. “We view everything before asking her to sign anything.”

Later, More Group said it intended to end its relationship with the unnamed client behind Lemixton because of “the accounting irregularities created by [the client] not providing us with these [Uzbek contracts].” The agency declined to identify who that client was.

A second shell...

Lemixton wasn’t the only UK-registered shell company reporters found winning lots of tenders on the Uzbek procurement register. Another was Golders Business Limited, which was also fronted by More Group. Like Lemixton, Golders had filed several years of dormant accounts in the UK—yet the Uzbek register suggested it had won 77 state tenders worth $21.1 million since 2022.

Its contracts, too, directed payments to an account at the same Swiss bank, and it was also run by a More Group nominee director. There is no suggestion of wrongdoing in relation to Golders’ supply of goods to Uzbekistan.

Ultimately the two companies had the same owner. When reporters asked More Group about this second company, the response was familiar: resignations and accusations of fraud and deception.

In a statement, More Group said: “We wish to confirm that we are not associated with the matters referenced, nor do we have any involvement with the information stated or the documents used. Any suggestion of our connection is incorrect.”

AMMC, Uzbekistan’s large state-owned mining complex, which did not respond to reporters’ questions, states on its website that it “is committed to the principles of transparency and accountability in the management of natural resources.”

A spokesperson for Banque Richelieu Switzerland said: “We do not comment on the banking activities of individuals or legal entities. We will therefore not comment on the case mentioned.”

Holes in the UK's transparency regime

As well as raising questions about the omission of Uzbek income from annual accounts, the story of Lemixton throws a spotlight on a major weakness in the UK’s ownership transparency rules, giving the lie to claims the UK has shrugged off its reputation as a secrecy haven.

Until early December, More Group ensured that Lemixton outwardly presented itself as the simplest possible UK corporate body: a one-person limited company, owned and operated by Wendy Conroy. But behind that veneer was an unseen ownership structure allowing the ultimate beneficial owner to remain hidden from view.

The issue of anonymous foreign actors using UK shell companies is nothing new. In the 2010s, Britain’s corporate register became a major international hub for shell companies controlled by hidden figures, based overseas, often in the former Soviet Union. More Group, which previously had offices in Moscow and Riga, and published a version of its website in both English and Russian, was part of a cottage industry of corporate services providers catering to this market. There is no suggestion that opaque shell firms set up or fronted by More Group were ever involved in criminal behaviour.

For many years, More Group and other agencies lawfully set up companies for their overseas clients that revealed almost nothing about who actually owned them. Many of these vehicles were “limited liability partnerships” or “limited partnerships”, which involved little red tape and required no individuals to act as directors.

Opaque LLPs and LPs could be formed using just a pair of nominee companies, including at least one based in secrecy havens such as the Seychelles, Nevis or the British Virgin Islands.

From at least 2011, More Group used a small number of its own nominee companies to form hundreds of UK shell firms for clients. Mike Conroy’s signature appeared on the paperwork for many of them—even though he had no involvement in their activities and they were owned and controlled by More Group clients.

The rapid proliferation of this kind of shell firm prompted the UK to phase in new transparency laws in 2016-17. These rules required companies registered in the UK to publish the names of any “persons with significant control” (PSCs)—anyone holding more than 25% of shares or otherwise having significant influence.

The impact on anonymous shell firms was swift. Thousands of previously opaque firms promptly dissolved rather than reveal their true controllers, and the creation of new LLPs and LPs fell sharply.

A similar pattern was seen among the more-than 300 More Group-linked LLPs and LPs examined by Finance Uncovered: only a minority disclosed a PSC, while many others filed temporary statements explaining that they were taking steps towards transparency, but ultimately dissolved before naming anyone.

Campaigners claimed the drop in new LPs showed the reforms worked. But the corporate secrecy industry soon learned there were loopholes in the new rules. One loophole stemmed from LPs formed outside of Scotland being exempt from the transparency rules—a gap that was later exploited at scale.

Another weakness involved the use of trusts. And it is the use of a hidden trust arrangement that appears to explain the mystery of how pensioner Wendy Conroy came to be named as the “person with significant control” over Lemixton, the supplier of industrial materials in Uzbekistan.

Trust Trickery

Even before it fully came into force in mid-2017, Britain’s ownership transparency regime was heralded by then-prime minister David Cameron as “the gold standard” of corporate transparency, allowing public “unrestricted [public] access… so that people can see who really owns and controls companies.”

But the PSC regime looks narrowly at who has the decision-making powers associated with ownership control, rather than who benefits financially from owning a company.

In most cases they are one and the same person; in many trust arrangements they are not.

A trustee can hold and control a company’s shares on behalf of an undisclosed beneficiary, exercising the voting rights while the beneficiary receives the financial gain.

And under the PSC regime, only the trustee—who officially controls the trust—must be named, allowing the financial beneficiary to remain invisible.

In early December, Finance Uncovered asked More Group about whether Wendy Conroy—listed for years as Lemixton’s sole shareholder and PSC—was actually holding shares in the company on behalf of someone else. The agency had already said that she had been acting as a nominee director. But had she also held the company’s shares as trustee, on behalf of a hidden beneficiary?

More Group never answered these questions clearly.

By phone, Jaime Barclay said that Wendy Conroy had been named as PSC of Lemixton in error. But Companies House records show she remained listed as PSC up until her termination as director on 2 December, the day reporters first spoke to More Group. The agency has so far not corrected the filings.

Since journalists approached More Group there have been seven filings at Companies House, four of which either added or removed names as PSCs—including Felipe Andres Guerrero Pulido, a Colombian, and Uzbek table tennis official Grigoriy Khvan—several of them backdated by years.

Meanwhile, More Group’s website has for years promoted services including the use of “nominee directors” and “nominee shareholders” aimed at preserving client anonymity—even while acknowledging that the UK’s PSC regime must be complied with.

When Finance Uncovered asked for clarification on how nominee shareholder services could be offered in compliance with the PSC regime, More Group did not respond.

Last month, however, a new Lemixton filing at Companies House offered the first clear indication of an additional layer of ownership behind Wendy Conroy’s reported “ownership” of the company's 100 issued shares.

The filing disclosed that one of the men newly introduced in the PSC filings, Guerrero Pulido, had in reality been a PSC since Lemixton was set up in 2018.

Most tellingly, the new filing also explained that Lemixton was owned via a trust arrangement. This was the first time any trust had been referenced in the company’s corporate filings.

For years, Lemixton’s paperwork suggested the company was a simple, one-woman British business. This new disclosure suggests that Conroy was a front twice over: as director and as shareholder.

Experts say this case strikes at the heart of Britain’s transparency regime. “When you have a nominee acting as an entity’s director, sole shareholder and PSC, yet taking instructions from a client, it is hard to see how this is compliant with UK law,” said Steve Goodrich, head of research and investigations at Transparency International.

Tymon Kiepe of Open Ownership added that the PSC register failed to capture or publish sufficient details to expose such complex arrangements—like trusts.

Meanwhile, back in Uzbekistan, none of Lemixton’s corporate upheaval appears to have slowed it down. According to the procurement register, the company has continued to win tenders even as More Group removed its nominee director and submitted new PSC details to Companies House.

The most recent contract—dated 5 December—bears the same facsimile signature, purporting to be Wendy Conroy’s, despite her resignation three days earlier.

And as long as British companies can be structured to hide those who benefit from them, cases like Lemixton are likely to persist.

*Main image: One of the mining sites run by Uzbek giant Almalyk Mining and Metallurgical Complex (Photo: www.agmk.uz)

*Fact-check: Malia Politzer

*Editors: Malia Politzer, Ted Jeory and Nick Mathiason