- alone," U.S. Company-1's foreign wire transfers far exceeded its receipts of advertising revenue. Indeed, the approximately $9.7 million that U.S. Company-1 received from foreign wire transfers represented nearly 90% of all the deposits into the U.S. Company-1 Bank Account from in or about October 2023 to in or about August 2024.
40. U.S. Company-1 received its 30 inbound wire transfers from seven foreign entities—none of which were U.S. Company-1's contract counterparty, U.K. Shell Entity-1. Three of the remitting entities ("Turkish Shell Entity-1" through "Turkish Shell Entity-3") listed identical addresses at an office building in Istanbul, Turkey. Three of the remitting entities ("U.A.E. Shell Entity-1," "U.A.E. Shell Entity-2," "U.A.E. Shell Entity-3") listed different addresses in Dubai and Ras Al-Khaimah, United Arab Emirates. And the last remitting entity ("Mauritius Shell Entity-1") listed an address in Mauritius. Of the seven foreign entities, only U.A.E. Shell Entity-1, U.A.E. Shell Entity-2, and Mauritius Shell Entity-1 have websites.
41. Like the website of Czech Shell Entity-1, the websites of U.A.E. Shell Entity-1, U.A.E. Shell Entity-2, and Mauritius Shell Entity-1 reflect seemingly odd and inconsistent information. For example, Mauritius Shell Entity-1 appears to maintain two websites using nearly identical domain names; one claims to supply agricultural products, and the other purports to be a digital marketing agency. As another example, the website of U.A.E. Shell Entity-1 states, in part: "Our company is always happy to create and implement new projects on the market. We are ready to provide a full range of services from creating a project to bringing it to the world's top ratings." And the website of U.A.E. Shell Entity-2 claims to provide a random array of services ranging from "construction projects," to "[a]nalysis of investment attractiveness," to "yacht consultancy," as well as the sale of textile products, electronic goods, and jewelry. The websites of U.A.E. Shell Entity-1, U.A.E. Shell Entity-2, and Mauritius Shell Entity-1 make no mention of "Eduard
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