So, a British Virgin Islands company headquartered in Cyprus Another thing that popped into my mind when you said that: https://www.theguardian.com/business/2016/nov/15/mossack-fonseca-fined-british-virgin-islands-panama-papers https://publicintegrity.org/accountability/bvi-hits-mossack-fonseca-with-biggest-ever-fine-after-panama-papers-investigation/ Things got a lot tougher in BVI after that bust 2 YEARS AGO. Just thinking out loud here....