International institutional work
The TPK Asia LLP case (Kazakhstan)
Four stages of ARGA's international work · July — September 2026
A corporate and property dispute that had exhausted domestic remedies was moved into a structured international project: asset tracing, submissions to financial regulators and financial intelligence units in more than twenty jurisdictions, publication of analytical reports with a permanent DOI, and preparation of a voluntary settlement mechanism.
Progress of the work
Project stages
The sequence of work on the case: what was examined, what each stage produced, and where the materials were sent.
- Stage IJuly 2026
International legal launch and the transatlantic circuit
The case was taken beyond the national jurisdiction of Kazakhstan. A Master Dossier was assembled, bringing together corporate, registration, property, court and administrative materials, and the principal analytical report was prepared and published on that basis. Four self-contained jurisdictional tracks were established — American, British, Swiss and pan-European — each with its own dedicated document.
In parallel, an internal working set was created: Asset Tracing Working Dossier, Financial Flow Hypothesis, PEP / Source of Wealth and Beneficial Ownership Dossier and Professional Facilitator Review.
Prepared
International Legal and Asset Recovery Memorandum; “TPK Asia LLP: United States Jurisdiction and RICO Applicability Assessment Memorandum”; UK Asset, Corporate and Beneficial Ownership Dossier; Switzerland Financial and Fiduciary Nexus Memorandum; a single pan-European memorandum; Initial Invitation to Confidential Dialogue.
Sent to
U.S. Department of Justice (Criminal Division), SEC, FinCEN, OFAC, CFTC, FTC; Serious Fraud Office, Financial Conduct Authority, OFSI, the UK parliamentary anti-corruption circuit, as well as Transparency International UK, Spotlight on Corruption, Global Witness, Chatham House, Finance Uncovered, The Bureau of Investigative Journalism, Foreign Policy Centre; Eurojust and the European Commission; the national financial, supervisory and AML/CFT authorities of the Netherlands, Germany, Austria, Luxembourg, Spain, Italy, Ireland, Cyprus, Malta, the Czech Republic, Latvia, Lithuania, Estonia and Bulgaria; Transparency International EU. Sent in the second half of July 2026.
- Stage IIJuly — August 2026
Global asset tracing: the Middle East, offshore centres, Asia and international organisations
The transatlantic circuit was expanded into a global system for examining corporate, property, investment, banking and trust connections. Separate regional tracks were established — the UAE, the rest of the Middle East, offshore and trust jurisdictions, the Asia-Pacific region, Latin America and Africa — each with its own nexus review.
A separate institutional circuit was built around UN and UNCAC mechanisms, the OECD and FATF standards. The stage concluded with the preparation of a Formal Invitation to International Mediation.
Prepared
Analytical report No. 2 “TPK Asia LLP: International Map of the Movement of Corporate Rights, Assets and Economic Value” — DOI 10.5281/zenodo.21683729; UAE Corporate, Property and Private Wealth Dossier; Middle East Corporate, Financial and Asset Nexus Review; Offshore, Trust and Foundation Structures Report; Asia-Pacific Corporate, Financial and Asset Nexus Review; Latin America Corporate, Property and Asset Nexus Review; Africa Corporate, Financial and Asset Nexus Review; UNCAC and International Asset Recovery Submission; Compliance Risk Notice; Formal Invitation to International Mediation.
Sent to
UAE Financial Intelligence Unit, the Central Bank of the UAE, DFSA, ADGM FSRA, DIFC Registrar of Companies, Dubai Land Department, DIFC Registrar of Real Property, the UAE Ministry of Economy, Securities and Commodities Authority, the judicial and prosecutorial bodies of Abu Dhabi, DMCC, the UAE Executive Office for Control & Non-Proliferation and other UAE bodies; the financial, corporate and AML/CFT authorities of Saudi Arabia, Qatar, Bahrain, Türkiye and Israel; the supervisory and registration authorities of offshore and trust jurisdictions; Singapore STRO and ACRA, Hong Kong JFIU, SFC, Companies Registry and TCSP Registry, Japan FSA, Bank Negara Malaysia, Labuan FSA, the FIU and FMA of New Zealand; the financial intelligence units of Argentina, Brazil, Paraguay, Mexico, Colombia, Uruguay and the Dominican Republic; the Financial Intelligence Centre of South Africa, the Financial Reporting Centre of Kenya, the Financial Intelligence Centre of Rwanda; the special procedures of the UN Human Rights Council and the UNODC/UNCAC system. Sent at the end of July 2026.
- Stage IIIAugust 2026
Concentration of evidence, international engagement and mediation
Scattered corporate, property, court and compliance materials were brought together into a single evidentiary and negotiating architecture. The principle of an unbroken transaction bridge was introduced: the chain “original asset → disposal → acquirer → subsequent transfers → present owner → consideration given” is treated as incomplete if even one material transfer or payment document is missing.
The principal public report was prepared, published with a permanent DOI and sent through eight international channels. In parallel, a closed negotiating framework and a draft notice with an invitation to mediation were drawn up.
Prepared
“TPK Asia: Corporate Control, Movement of Assets, Politically Exposed Persons and the Victims’ Right to Reparation” — DOI 10.5281/zenodo.21996358, final version of 18 August 2026; a draft Notice of International Proceedings and Invitation to Mediation.
Sent to
OHCHR; the Office of the Attorney General of Switzerland; the UN Working Group on Business and Human Rights; International Partnership for Human Rights; FIDH; Business & Human Rights Resource Centre; the compliance units of HSBC and Deutsche Bank.
- Stage IVAugust — September 2026Current
New official evidence and the U.S. financial episode
The stage began after documents unavailable during stages I–III were obtained, including the official reply of the National Bank of the Republic of Kazakhstan dated 21 August 2026. The task was not to run the dossier through again, but to revisit earlier conclusions in the light of new primary evidence.
The National Bank officially confirmed the conclusion in 2003 of a cross-border loan agreement with a U.S. company for USD 1,000,000, its registration, the actual receipt of the full amount, and the subsequent transfer of the obligation to another Kazakhstani resident in 2004. One of the financial episodes in the case has moved from the category of a historical assertion to that of a documented cross-border transaction.
At the same time, the limits of that conclusion were recorded: the presence of a U.S. counterparty, a dollar payment and correspondent banking details does not in itself create U.S. federal criminal jurisdiction — that requires the actual banking route, which remains to be established.
Prepared
“TPK ASIA — Stage IV: The M SAAG U.S. Investment and the 2003–2004 Assignment of Liability. Consolidated International Financial, Federal Crime, Civil RICO and Investor–Victim Assessment”, including a Preliminary U.S. Federal Crime and RICO Referral Memorandum and an assessment of civil RICO prospects; a draft follow-up request to the National Bank of the Republic of Kazakhstan.
Sent to
Federal Bureau of Investigation — through the official electronic channel under Financial / Economic Crimes and Fraud — Investment Fraud, as an evidentiary referral and request for investigative assessment; and to all addressees of stages I–III as supplemental evidence, with a request to add the materials to the submissions already opened and to consider them under the reference numbers already assigned.
Sending materials to a government authority, regulator or financial intelligence unit is an entry point and does not mean that the addressee has confirmed the circumstances set out, opened an inquiry or recognised the claims. The international circuit was built to test hypotheses; information on the movement of assets and on the route of funds remains to be established through the appropriate procedures.
Publications
Reports with a permanent DOI
The analytical reports on the case are published in open access with a permanent DOI: the version of the document is fixed and available for independent verification.
Stage I
Principal analytical report of stage I
DOI to be confirmedStage II
Analytical report No. 2 “TPK Asia LLP: International Map of the Movement of Corporate Rights, Assets and Economic Value”
DOI 10.5281/zenodo.21683729Stage III
“TPK Asia: Corporate Control, Movement of Assets, Politically Exposed Persons and the Victims’ Right to Reparation”
DOI 10.5281/zenodo.21996358
What stands behind this case
Behind the four stages lie the collection and systematisation of corporate, property and financial materials, a separate document prepared to the requirements of each jurisdiction, and reports published with a permanent DOI. A submission to a competent authority is an entry point: it replaces neither an inquiry nor court proceedings, and does not prejudge their outcome.
Asset tracing
Examination of corporate, property, banking and trust connections region by region, with a separate document for each track.
International submissions
Targeted engagement with financial regulators, financial intelligence units, corporate registries and UN bodies.
Open publication
The key reports are published with a permanent DOI and available for independent verification.