Image: Steel Quality Business’ registered address when checked on 26 June 2020 It is apparent that two individuals (Husanov and Sakenov) who have directly or indirectly held shares in Steel Quality Business have executive ties to Alfa Invest (Sakenov/Husanov) and Zamon Plus Sarmoya (Husanov). Both companies, in turn, have held significant shareholdings in Ipak Yuli Bank, which has helped to finance the Nur development. Moreover, when Steel Quality Business’ record was first checked in 2020, its registered address was the same as that of Alfa Insurance, a subsidiary of Alfa Invest Insurance, a company that has held shares in Ipak Yuli Bank. Given that professional nominees are frequently and lawfully used in Uzbekistan, often drawn from the corporate group’s managerial team, it is unclear if the shareholders cited above are the ultimate beneficial owners of Steel Quality Business, or are instead acting as professional nominees for a third party or third parties. Nevertheless, it does appear from the corporate filings that Steel Quality Business, Alfa Invest and Ipak Yuli Bank are interlinked companies. Requests for comment were sent to Steel Quality Business and Ipak Yuli Bank. No reply was received. Image: Steel Quality Business’ registered address when checked on 26 June 2020 24 A False Sense of Legality