Mr. Khromayev. A "Thimble-Rigger" Story

Tymur Khromayev, Head of the National Securities and Stock Market Commission of Ukraine, has turned out to be a director and beneficiary of a company in the USA that cannot be found in his declaration.

One can’t find it, perhaps due to Khromayev’s attempts to deceive the securities market regulator, similar to that headed by him in Ukraine, while having business with that company.

As a result, his company GASE Energy has been subsumed under OTC Pink No Information.

OTC Pink is the lowest and the most speculative level of three trading platforms for pink sheet stocks trade.

According to the data from the Security Service of Ukraine, Khromayev has helped Serhiy Dunayev, adherent to Luhansk and Donetsk People's Republics (LDNR), to transfer hundreds of millions UAH before the bankruptcy of his glass factory. It all became possible in the course of fictitious transactions.

If you start to analyse this story from the very beginning you may find out that the company GASE Energy, Inc. (formerly Great East Energy, Inc.) was registered under the name of Epsilon Corp. on the 17^th of October 2011 in the state of Delaware.

On the 10^th of September 2013 the company primarily changed its name into «Gase East Energy», and already on the 13^th of June 2013 the company was renamed to GASE Energy, Inc., that we were actually interested in.

Initially, the business plan of GASE Energy consisted in “creation and operation of an online social network for new companies (start-ups) in the high-technology industry sector where entrepreneurs, investors and industry experts could meet”.

The company started its securities trade on the over-the-counter securities market of the USA (OTC) and got its unique identifier – a ticker (used in order to avoid typing full names of securities or other objects of trade in summaries) and a SIC code from the securities market regulator of the USA (SEC) №0001539574 (used in order to denote different branches of industry according to their functions and products).

After listing the company immediately stopped activities in the field of online social services and changed its business plan to ‘purchase and development of Ukrainian objects in the field of natural gas’.

From the moment of the SIC code obtainment and till the 16^th of July 2015 GASE Energy had been obliged to publish the reporting data in the information disclosure system for the Securities and Exchange Commission (USA).

Somewhere in this part you should have a question “What has Khromayev got to do with it?” and the story is as follows.

GASE Energy (the USA) is the owner of the offshore company BEZERIUS HOLDINGS LIMITED, which in its turn owns the Ukrainian company ‘Gase Energy’ together with another firm of Tymur Khromayev – the asset management company “ARTA”. The main type of activity of this company is “rendering of other information services”.

In its turn Bezerius Holdings Ltd (Cyprus) possesses Cyprian Synderal Services Ltd including NPK-Contact and Lyspromgaz in its ownership.

Khromayev’s company Epsilon Corp. closed an option transaction with Bezerius Holdings as to the purchase of Ukrainian assets for $1.25 million. It happened through its subsidiaries. And due to Gase Energy (Ukraine) Khromayev has become an owner of two companies that are directly connected with natural gas extraction and trading on the territory of Ukraine:

· NPK-CONTACT, LTD., the type of activity is prospect boring, oil and natural gas extraction. It has 6 wells (2 productive wells, 2 prospect wells and 2 degassing wells).

· LYSPROMGAZ, LTD. dealing with distribution of gas fuel through local pipelines, and since May 2010 also with delivery of natural gas at uncontrolled price. In fact, it’s an operational company that possesses 13,5 km of pipelines and delivers natural gas via them to two consumers:

1. Lysychansk glass factory “Proletariy” (gas was used in a foundry), that was declared bankrupt in 2017.

2. Lysychansk brewery (gas was used in a boiler).

According to the information of GASE Energy, presented in 2014, Lyspromgaz is a company that has all the permissions, controls technical and human resources and possesses two gas objects with the monthly productivity of more than 350 million cubic metres of gas.

Herewith, GASE Energy doesn’t carry on any factual activity in the USA and has only a few employees on its territory. Its legal address at 173 Keith St. Suite 300 Warrenton, VA 20186 (Virginia) was used by the the accounting company Belmont Acconting & Bookkehing as well as the legal company Belmont Partners LLC and the stock broker Pacific Stock Transfer that carried out their activities. And Larysa Prymenko, the main signatory and executive director of GASE Energy, is the director of Khromayev’s company ARTA and resides permanently in Kyiv.

What is the purpose of such a complicated scheme with possession of Ukrainian assets through companies on one of the most transparent stock markets in the world?

It seems that activities of GASE Energy took place only in Ukraine, and all the transoceanic relations were fictitious and had been organized within a framework of capital transfer to the USA.

GASE Energy has already been involved in the international scandal with participation of the securities market regulator of the USA (SEC). While signing the reporting documents of GASE Energy for the year 2013 (whereof Khromayev could not had been unaware), SEC officially declared dissatisfaction by its report for the year 2013, due to the attempt of exceeding gas reserves extraction allowed.

It was being done in order to place more stocks on the securities market that could be bought by “investors”, and in such a way to transfer money under the jurisdiction of the USA for the following legalization operations.

In fact, Khromayev was caught when he was attempting to forge the reporting documents, where his company wanted to represent 7 working mines, while in reality only one mine for natural gas (methane) extraction was being used. As they got caught they had to admit their “carelessness” and to correct their report.

But SEC didn’t accept these corrections and the officials threatened GASE Energy to publish the correspondence data with concrete complaints against reporting documents that happened after a while. The correspondence is public at the moment and remains in the information disclosure system of SEC.

In fact, the securities market regulator of the USA applied sanctions against the company GASE Energy due to the suspicion of an attempt to forge the reporting documents. It all meant that Tymur Khromayev didn’t go along with the principle of sound business reputation that was the obligatory condition for the position of the head of the National Securities and Stock Market Commission.

Since May 16, 2015 GASE Energy has stopped filing reporting documents to SEC and hasn’t been able to publish its report for the year 2015. The information for the year 2014 hasn’t also been presented, and was only included in the report for the year 2013 as corrections.

SEC also sent a letter to the company’s signatory Larysa Prymenko. Facts of nonfulfillment of works on implementation of corrections as well as the information about application of sanctions were presented in the letter.

As a result of sanctions, one of the basic platforms of the over-the-counter market, where GASE Energy was accomplishing its auctions, subsumed the company under OTC Pink No Information. OTC Pink represented the lowest and the most speculative level of three trading platforms for pink sheet stocks trade.

The «No Information» category is intended for the companies that don’t disclose any information to the investors, the regulator or ОТС Markets group at all.

Also that category includes companies that don’t spread information about themselves through the ОТС Disclosure and New Service, and even if they do so, the information has not been updated for at least 6 months.

Stocks of non-existent companies or companies with doubtful reputation may be listed on this stock market. That’s why to enter this market means to destroy the reputation.

So, current head of the National Securities and Stock Market Commission Tymur Khromayev is a former director and beneficiary of the company, sanctioned by the securities market regulator of the USA (SEC) that is similar to that headed by him in Ukraine. And his own company has found itself at the bottom of the ОТС stock market of the USA due to fabrications during the period of his management. The violations detected by the regulator haven’t been corrected in the annual report.

#Victory

At the moment the reporting documents were submitted (15.04.2014) on the securities market of the USA (SEC) Khromayev was not only the main executive director of the company but also its owner. Khromayev indicated in his declaration for the year 2015 that he held stocks of Bezerius Holdings Limited (purchased in December 2012) and Epsilon Corporation (purchased in May 2013).

Except for Khromayev, one could find the name of Ihor Umanskyi, former First Deputy Minister of Finance of Ukraine, among the members of council of Gase Energy, Ltd (USA). In due time he was related to NJSC Naftohaz through JSC Ukrtransnafta and obtaining a position at such a company wasn’t accidental.

There is an even more interesting piece of information one may find while delving in reporting documents of GASE Energy subsidiaries.

The main gas purchasers of LYSPROMGAZ, LTD. were two companies: Lysychansk brewery and the glass factory ‘Proletariy’. Take into consideration the annual report of that same year, it became clear that the glass factory “Proletariy” had been cooperating with GASE Energy for 9 years (2005-2014), leasing out premises as a substation. So having the aforementioned facts it could be highly possible that the gas was delivered there.

But in fact there were no actual deliveries to the glass factory. You may easily make sure hereof, if you have a look at the annual report of GASE Energy (FORM 10 K/A): it’s indicated there that during the period from 2012 till 2013 natural gas had been sold to the only client named Lysychansk brewery, Ltd.

In addition, in 2014-2015 there were no gas shipments from the main supplier NJSC Naftohaz to the factory “Proletariy” because they had huge debts to NJSC Naftohaz for the years 2011-2012.

Why did Khromayev forge reporting document for the state authorities of the USA?

My assumption is the following: he did that in order to transfer and legalize his clients’ finances in the USA.

In 2009 Serhiy Dunayev, mayor of Lysychansk, became the owner of the glass factory, that took part in fake gas deliveries. Dunayev was elected as deputy of Verkhovna Rada of Ukraine from the Party of Regions in 2012. He got his post as a deputy owing to Yuriy Boiko who was a deputy prime-minister at that time.

There’s an interesting fact for you: mayor of Lysychansk Serhiy Dunayev ensured protection to militants, who had occupied Luhansk Security Service of Ukraine, and prevented Ukrainian law enforcement officers from assaulting the building. Later the building occupied by the militants was visited by Serhiy Tyhypko together with Mr. Dunayev in order to conduct negotiations on the part of Ukraine. Having resigned from the Party of Regions, Dunayev became a member of Tihipko’s deputy group.

I should also mention Vasyl Khmelnytskyi who owned the glass factory ‘Proletariy’ earlier. He purchased junk bonds to the amount of 2 billion UAH with the help of the bank Khreshchatyk and after that the bank went bankrupt.