Table 2: Market intelligence on Steel Quality Business shareholders Shareholder Market Intelligence Agzamov Sanjar Nigmatovich When records were checked in 2022, the name Agzamov Sanjar Nigmatovich was listed as the head of Unit Great Trade LLC, an entity 100% owned by Leading Force Company, which specialises in polymer bags, concrete and construction.58 Leading Force Company’s primary shareholder is listed as ICS Establishment. It is registered in Liechtenstein where shareholdings and UBO (ultimate beneficial owner) information are not publicly available. Leading Force Company received a letter of thanks from the chairman of Ipak Yuli Bank in 2007, following a successful loan agreement funded with a credit line purportedly issued by the German state’s KfV Bank.59 KfV Bank is a shareholder in the Uzbekistani Ipak Yuli Bank through its subsidiary Deutsche Investitions- und Entwicklungsgesellschaft mbH.60 As will be noted shortly, Ipak Yuli Bank has helped finance the Steel Quality Business real estate project. Husanov Abdullatif Abdugapurovich When checked in 2023, Husanov was listed as a deputy director at the company Alfa Invest Insurance, which was previously known as Alfa Invest.61 Husanov has served on the supervisory board of Zamon Plus Sarmoya.62 Both Alfa Invest and Zamon Plus Sarmoya have held significant shareholdings in Ipak Yuli Bank. For example, in August 2020 the shareholders of Ipak Yuli Bank included Deutsche Investitions- und Entwicklungsgesellschaft mbH (12%), Triodos Microfinance Fund (12%), UzbekInvest National Export-Import Insurance Co. (8.43%), Zamon Plus Sarmoya (10.92%), Alfa Invest (14.87%), Kafolat State Joint Stock Insurance Company (7.11%), Mebel Invest Group (4.36%) and the Asian Development Bank (4.54%).63 Technological Generation A previous 100% shareholder is ‘Sakenov Rolan’ and the current 100% shareholder is listed as ‘Kim Irina Vladislavovna’. It is reported that in 2020 Sakenov took up a senior executive role at Alfa Invest Insurance.64 A False Sense of Legality 23