Rivara Advisory Ltd has been a client since March 2023. It provides commercial and marketing advisory services, and we act as company secretary and registered office and keep its books. This is the firm's quarterly transaction review, covering the period to 30 June 2026.
- Ownership: Paul Z., Maltese, resident in Malta, holds 100% and is the sole director. Unchanged since incorporation; screening remains clear.
- Accepted profile (Mar 2023): advisory work for Maltese and Italian SMEs; projected turnover €300,000; fees billed hourly against timesheets; one account with a Maltese credit institution
- Substance: an office in Sliema on a five-year lease, two employees — an analyst and an administrator — and a website carrying named case studies from 2023 and 2024
- The second stream: since October 2025, thirteen invoices to four counterparties — two Italian companies, a Bulgarian company incorporated in August 2025 and a Cypriot company incorporated in September 2025 — totalling €630,000. The original advisory work billed €280,000 over the same nine months.
- The invoices: six at €60,000, four at €45,000, three at €30,000, each described as “strategic advisory — project support”. No scope, deliverable, hours or rate is stated on any of them.
- The outflow: between two and six days after each receipt, 88–92% is paid on to one of three delivery partners — an Estonian company, a UAE company and a second Cypriot company — against invoices in similarly round amounts. The share Rivara keeps sits between 8% and 12% on every project regardless of size.
- The record: no engagement letters, correspondence, drafts, presentations or travel for any of the thirteen projects. Timesheets are still kept, but both employees’ time is recorded entirely against the original advisory clients.
- What Paul Z. said: asked in passing at the May bookkeeping meeting, he said the delivery partners are “people I’ve worked with for years” and that the fees are “fixed price — that’s how this market works”. The Estonian company was incorporated in July 2025.
- Banking: everything runs through the single Maltese account. We receive the statements monthly because we do the bookkeeping.
- Compliance: VAT returns filed and up to date; FY2024 accounts audited without qualification; annual return filed on time; screening on Paul Z., on the four counterparties and on the three delivery partners returns no hits.