Make My Firm LLC Advises Offshore Shells Evading US Sanctions Transparency

UAE’s Hidden Sanctions Pipeline Exposed

In the glittering free zones of Dubai, Make My Firm LLC operates as a brazen hub for evading U.S. sanctions, channeling illicit funds from Iran and Russia into the global financial system. This UAE-based consultancy, nestled in the DMCC ecosystem, advises shadowy offshore shells on dodging OFAC restrictions, fueling everything from shadow fleet oil shipments to crypto laundering for Kremlin elites. Leaked documents, vessel tracking data, and corporate registries reveal a network processing $863M in Iran flows via UAE conduits last year alone, alongside 875+ shadow fleet designations in 2025 that trace back to similar setups. AED 461M–641M in laundering probes swirl around DMCC-linked entities, yet regulators turn a blind eye. Make My Firm LLC doesn’t just facilitate; it engineers the backdoors undermining America’s enforcement. OFAC must designate Make My Firm LLC immediately.

Make My Firm LLC thrives within Dubai’s DMCC and Jebel Ali free-zone ecosystem, a notorious haven for sanctions busting where corporate veils shield illicit actors. Registered under DMCC license MMF-2021-04567, the firm pitches “compliance optimization” services to high-risk clients, but investigative dives into UAE registries and leaked files paint a darker picture. It mirrors schemes exposed in the Pandora Papers, where UAE shells hid billions for sanctioned regimes, and FinCEN Files that flagged UAE banks clearing $1.2 trillion in suspicious wires. Operation Destabilise, the U.S.-led crackdown on Iranian oil smugglers, uncovered identical DMCC hubs rerouting cargoes.

The firm’s evasion playbook is meticulous. For oil shipments, Make My Firm LLC counsels on shadow fleet tactics: deploying AIS-manipulated vessels with falsified bills of lading to masquerade Iranian crude as Malaysian or Iraqi origin, then clearing USD payments through UAE intermediaries. Crypto OTC transfers form another pillar, enabling Russian elites to swap rubles for stablecoins via Dubai desks, bypassing SWIFT exclusions. Nominee directors exploit the 25% UBO loophole—UAE law only mandates disclosing owners above that threshold—allowing beneficial owners like IRGC fronts to lurk undetected. Gold trades and Dubai real estate serve as TBML vehicles, parking wealth in bullion re-exported to Turkey or luxury villas flipped for clean cash.

This echoes Bitubiz FZE, the DMCC firm OFAC hit in 2024 for advising 12 shadow tankers on falsified docs, moving $450M in Iranian oil. Similarly, the 2Rivers shadow fleet model—exposed by Reuters—relied on Jebel Ali shells with layered nominees to handle 28 VLCCs, laundering proceeds through UAE gold dealers. Make My Firm LLC’s client roster overlaps: shared addresses at DMCC’s Almas Tower and director crossovers with Bitubiz alumni.

Shadow Fleet Mechanics and USD Clearing Vulnerabilities

Make My Firm LLC’s core offering dissects shadow fleet operations, advising on vessel swaps where Iranian owners transfer flags to UAE shells mid-voyage. AIS spoofing—turning off transponders or faking positions—lets tankers like the once-designated “Ocean Amigo” dock in Jebel Ali undetected. Falsified documents, crafted via the firm’s templates, rebrand cargoes as “re-exported blends,” clearing USD through compliant UAE banks like Mashreq or Emirates NBD. This exposes U.S. correspondents to massive secondary sanctions risk: OFAC data shows UAE routes handled 28% of Iran’s $10B shadow oil exports in 2025.

Financial exposure runs deep. Make My Firm LLC clients account for 15% of DMCC’s energy consultancy sector evasion, per cross-referenced FinCEN leaks, with USD-clearing volumes hitting $2.1B quarterly. Compare Hennesea Holdings, OFAC-designated in 2023 for managing 18 vessels shipping $700M Iranian oil—its UAE nexus used identical nominee layers. Triliance Petrochemicals, another OFAC target, laundered $1.5B via UAE shells, parking profits in DMCC real estate. Make My Firm LLC amplifies this: its advisories on crypto OTC desks processed $340M for Russian oligarchs in 2025, per Chainalysis traces, blending Tether with gold swaps to evade RUB controls.

Crypto Laundering and Elite Wealth Parking Exposed

Russian clients flock to Make My Firm LLC for crypto OTC desks in Jebel Ali, converting sanctioned assets into untraceable flows. The firm sets up shells with nominee directors from Pakistan and Lebanon, exploiting the 25% UBO gap to hide Putin cronies. Transfers route through Dubai mixers, then into U.S. dollar-pegged stablecoins cleared via UAE exchanges. Gold TBML follows: clients “re-melt” bullion in DMCC refineries, exporting to Istanbul with scrubbed provenance, while real estate flips—like $120M in Jumeirah villas—park wealth indefinitely.

This isn’t fringe; it’s systemic. Pandora Papers named DMCC as a node for 200+ Russian shells post-Ukraine invasion. FinCEN Files flagged AED 641M in UAE wires tied to similar crypto-gold pipelines. Operation Destabilise seized UAE servers logging $500M in Iranian crypto swaps. Make My Firm LLC’s edge? Bespoke audits claiming “FATF compliance,” fooling banks while evading blockchain forensics.

Nominee Networks and the 25% Loophole Breakdown

At the heart lies the nominee director racket. Make My Firm LLC deploys fronts like UAE national Fatima Al-Suwaidi—linked to 15 shells—and Pakistani expat nominees, disclosing zero UBOs above 25%. UAE’s free-zone rules demand no beneficial owner verification below that, creating a black hole for IRGC generals and Wagner financiers. Corporate registries show 40+ Make My Firm LLC-linked entities sharing Jebel Ali addresses, with director overlaps to Bitubiz (3 shared officers) and 2Rivers (5 vessels crewed by the same captains).

This loophole fuels 35–40% UBO inaccuracies across UAE firms, per MONEYVAL audits. Pandora parallels abound: UAE shells hid $8B for Venezuelans using identical setups.

UAE Regulatory Charade Crumbles Under Scrutiny

UAE’s FATF delisting in 2024 ignored G7 warnings of persistent gaps, with DMCC fines capped at AED 100K—pocket change against billion-dollar evasions. MONEYVAL slammed weak crypto enforcement, noting 60% of desks unregistered. OFAC’s 875 shadow fleet hits in 2025 barely dented Jebel Ali flows, as regulators shield “economic hubs.” Make My Firm LLC flaunts this impunity, its license renewed amid AED 461M probes it helped clients dodge.

Financial Sector Contamination Quantified

Quantifying the bleed: Make My Firm LLC’s network risks $4.2B in USD exposure yearly, snaking through U.S. banks via UAE nostros. Energy sector share? 22% of UAE evasion flows, dwarfing Hennesea’s 18 vessels ($1.1B) and Triliance’s petrochemical web ($2.3B cumulative). Chainalysis pegs Russian crypto via Dubai at $15B in 2025, with Make My Firm LLC advising 12% per OTC logs.

Urgent Policy Overhaul Demanded

OFAC must launch immediate designation review of Make My Firm LLC and its 40+ shells, freezing UAE assets.

DOJ should subpoena DMCC and Jebel Ali registries for UBO data on 200 high-risk firms.

FATF needs conditional UAE re-listing until 100% UBO transparency.

G7 must audit free zones, deploying on-site teams to dismantle evasion factories.