lyudmylakozlovskaOn 13 August this year, Lyudmyla Kozlovska was deported from the EU. The authorities in Brussels had been alerted through the Schengen Information System (SIS) that the Ukrainian posed a danger to Polish national security, and therefore to the safety of the European Union as a whole.

The reason that Poland’s Internal Security Agency took this major step was that they had ‘serious doubts’ around the funding of the NGO of which Kozlovska is president.

There have been concerns raised from other sources too about the ODF and its financing – and not only from Poland. MEPs from Latvia (Iveta Grigule-Peterse) and Romania (Andi Cristea) as well as three from Poland have all tabled questions about the issue.

The organisation’s accounts published on its website certainly make interesting reading. The largest ODF donor by far is Silk Road Biuro Analiz i Informacji, a company owned and run by Bartosz Kramek who is Kozlovska’s husband and head of the ODF board. In fact, if you take out revenue from Google Adwords, Silk Road provides an astonishing 95% of institutional donations. The couple, whose only known income comes from Silk Road, manage to make a further 80% of individual donations to their own NGO.

With total donations totalling about $200,000 every year, self-funding on this scale is quite an operation, especially as Silk Road’s returns show it has negligible turnover. The company ostensibly gives advice on relocating to Poland, but at least one team of investigative journalists say almost all its income come from hard-to-trace Western Union transfers.

The organisation’s accounts appear to be very accurately kept, but the small print points out that some individual donors are not identified because disclosure would ‘not contribute to their comfort’. So who might these sensitive individuals be? For a human rights NGO, the ODF undoubtedly has some very rich friends. Take Mukhtar Ablyazov, a man accused of embezzling more than $7 billion – the biggest case of financial fraud in history. Ablyazov was chairman of BTA, a bank in Kazakhstan, between 2005 and 2009. Money was siphoned off into a huge network of shell companies owned by the oligarch – over a thousand of which have been identified to date. Wanted in the former soviet republic to start a 20-year jail sentence, he remains in exile, denying the charges.

Ablyazov’s claim that the Kazakh government is politically motivated is repeated again and again on the ODF website, but it’s not a view shared in the UK. He now has $6 billion in outstanding judgments at the High Court in London, as well a 22 month prison sentence for contempt of court. These were passed for ‘failing to disclose assets, lying in cross-examination and dealing with assets in breach of the Freezing Order’. Ablyazov fled the UK before the sentences could start. Two years later the UK government revoked his political asylum.

The oligarch doesn’t deny having taken billions of dollars (claiming it was to keep it out of the hands of the ‘thieving’ Kazakh government). So is it conceivable that a man this rich would not contribute to a not-for-profit organisation which runs multiple high-profile campaigns on his behalf? The only link so far uncovered – by Polish journalists at the Sieci weekly magazine – is a $20,000 donation made by Leila Khrapunova, the mother of Ilyas Khrapunov, Ablyazov’s son in law and co-conspirator in the fraud case.

Other billionaires to have benefited from ODF lobbying without making an appearance in the list of donors include two Moldovan oligarchs, Veaceaslav Platon and Renato Usatii. In a case similar to Ablyazov’s, Platon has been convicted of stealing over ten per cent of Moldova’s gross domestic product in a banking fraud. However, Usatii has an even more serious allegation hanging over him – that he was involved in the attempted assassination in the UK of a Russian banker. Gherman Gorbuntsov was hit by six rounds from a silenced pistol outside his east London apartment in 2012. He lapsed into a coma and spent months in hospital. Gorbuntsov himself is in no doubt as to who is responsible: ‘I am absolutely convinced… that it is the order of Usatii and his partners’.

The man Scotland Yard believes pulled the trigger that day is Moldovan hit-man Vitalie Proca. Shortly after the shooting, Proca surfaced in Moscow, where he was shielded for some time by the authorities. Eventually however he was extradited to Romania to stand trial for an unrelated assassination attempt in Bucharest. There are claims that substantial payments from Usatii have been received by the hit-man’s family, and in his last press interview he took the opportunity to vehemently defend the politician and businessman.

Incredibly, a website owned by Usatii – – briefly hosted a story about his involvement in the assassination attempt. Dorina Blandescu, the journalist responsible, was quickly sacked, with the editor, Victoria Borodin, explaining that the article had been posted without the approval of the management. Renato Usatii is currently living in exile in Russia.

There are also many interesting companies which have previously been linked to the ODF’s funding but no longer appear in their accounts. Majak for example, owned by Ukrainian-Russian Petro Kozlovskiy. This is a company which supplies resources to the Russian military in illegally-annexed Crimea. Kozlovskiy is in fact Lyudmyla Kozlovska’s brother.

Then there are two internet-only businesses, Igoria Trade, which runs a currency exchange site, and Banerco, a significant player in the world of off-shore casinos and bookmakers. The shadowy world of online gambling has often been implicated in using currency exchange websites to engage in large-scale money laundering. To add to the intrigue, buried in paragraph 14, clause 31 of the organisation’s statute is the admission that the so-called think-tank may carry out ‘gambling and betting’.

We are still some way from unravelling all the mysteries of this self-funding NGO. However, one thing we can say for sure is that for a think-tank dedicated to ‘the rule of law’ and ‘human rights’, the Open Dialog Foundation keeps some decidedly dubious friends.

European Union Anti-Corruption , November 20, 2018