Nominee directors in Uzbekistan: people who answer with their own name for someone else’s crime

In Uzbekistan they are called “sholg‘om” (turnip): nominee directors or founders who, for a small fee, lend someone their name, passport details, signature key and signature. The real operator never appears in the documents, so investigators first find the person whose signature is on them.

According to the Prosecutor General, a cash-out ring operating in 2019 moved about UZS 1 trillion, paying people mostly from low-income families to act as front directors while its leader ran the firms from abroad. In 2020 a district tax inspectorate head was accused of informally running 22 companies registered to others. In 2025, 27 electronic keys were seized from suspects in a UZS 82bn VAT refund case.

How the scheme works

The details below are not yet in public sources; they are generalised from our practice.

Organisers know how to find nominees who cannot give them away. They look for people short of money in Telegram groups for day labourers (“mardikor” groups) and offer “easier, bigger earnings”. The organiser uses a false name and communicates only through a messenger account. Instructions come in writing and documents travel by taxi, so the two sides never meet.

A company, bank account, signature key and several SIM cards are registered to the nominee; one SIM goes to the organiser, who gets the confirmation codes. Anything can now be done in the nominee’s name: fake invoices, VAT refunds, loans, cash-outs. At the first sign of trouble the account is deleted, chats are wiped and contact is cut.

How a nominee (“sholg‘om”) scheme is built

Recruitment
A person in need of money is found and promised “easy income”. The organiser uses a false name.

Registration
A company, bank account, digital signature key and SIM card are opened in the nominee’s name. The key and the power of attorney stay with the organiser.

Operations
Fake invoices, VAT refunds, loans, cash-out schemes, all under the nominee’s signature.

Disappearance
At the first sign of trouble the messenger account is deleted, the chats are wiped and contact is cut.

Outcome
Only the nominee appears in the documents. Finding the organiser and proving their role is hard.

The diagram generalises cases reported in official sources (2019, 2020, 2025) and observations from our practice.

Some nominees promise not to name the organiser; others name him, but know only a deleted account, not his real name or phone.

Who the law holds liable

As of 28 October 2026, the Criminal Code has no specific offence of acting as a nominee or of handing over a signature key, SIM card or bank card. Both nominee and organiser are prosecuted under general provisions.

The main one is Article 179, reworded by Law ZRU-1131 from 19 July 2026: setting up a business entity without intending to carry on business, to obtain loans, avoid tax on profit or gain another property benefit. Penalties range from a fine of 100–200 base values to 3 years’ imprisonment. Offences committed through the company fall under Articles 184 (tax evasion), 168 (fraud), 228 (forgery) and 243 (money laundering).

Under the digital signature law (No. ZRU-793), a verified digital signature equals a handwritten one, and a company’s equals its seal (Article 4). The key holder must take all possible measures to protect the key and notify the issuing registration centre at once if others use it (Article 27). Someone who knowingly hands over the key may be an accomplice under Article 28 of the Criminal Code, or a co-perpetrator if they signed documents themselves.

The organiser can be reached too: under Article 28, whoever commits an offence through people who cannot be held liable is the perpetrator. Under Plenum Resolution No. 08 of 31 May 2013, staff who actually perform a manager’s functions may be liable for tax offences, and whoever directed the evasion is liable as organiser (clauses 10–11); and taking an online loan with someone else’s signature is fraud (Plenum Resolution No. 17 of 23 June 2023, clause 9).

Who is liable, and on what basis

The nominee

False entrepreneurship: Article 179 of the Criminal Code (new wording since 19 July 2026).

For offences committed through the company, as an accomplice (Article 28): tax evasion (184), fraud (168), forgery (228), money laundering (243).

If deceived, there is no intent; hardship is a mitigating circumstance (Article 55).

The organiser

Under the same articles, as organiser or perpetrator (Article 28).

Staff who actually perform the manager’s functions may be liable for tax offences, and whoever directed the evasion is liable as organiser (Plenum Resolution No. 08 of 31 May 2013, clauses 10–11).

Taking a loan with someone else’s digital signature is fraud (Plenum Resolution No. 17, clause 9).

The problem is proof, not the law: every signature is the nominee’s, and the organiser’s traces are gone.

As of 28 October 2026, the Criminal Code has no specific offence of acting as a nominee or handing over a signature key, SIM card or bank card.

The problem is proof: every signature is the nominee’s, the organiser’s traces are gone, and the easiest person to find is prosecuted. Leniency is also closed to a poor nominee in practice: under Article 184, a first-time offender is exempt only if tax, penalties and fines are paid in full.

What needs to change

A Law on Combating Offences Committed with the Use of Information Technologies passed the Legislative Chamber on 22 July 2026; press reports say it sets administrative liability for handing a personal account or SIM card to others for gain. We found no record of it being signed as of 28 October.

Two things are needed beyond tougher penalties. First, an exemption for a first-time nominee who actively helps expose the organiser (note 2 to Article 173.1 of Russia’s Criminal Code has a similar rule for the registration offence): while nominees gain nothing by giving up organisers, organisers stay protected. Second, control at registration. FATF Recommendation 24 (2022) requires nominee directors to be disclosed or restricted, and the UK has required identity verification of directors since 18 November 2025. We know of no automatic alert when one person appears in many companies, and a beneficial ownership register bill was still unadopted in mid-2024.

Practical steps

Never hand over your signature key, passport details or SIM card: a digital signature legally equals your handwritten one.
If a company has been opened in your name or your key used, revoke the certificate and file a written report with law enforcement at once. Delay makes your position worse.
If you are already a nominee, keep every trace of the organiser (chat screenshots, phone numbers, receipts, taxi orders): this is your main evidence of lack of intent or a minor role.
If summoned, see a lawyer before giving any statement: the first one often decides the case.
In vetting counterparties, watch for a director in several companies, no staff, a mass address, or a new firm with large turnover.

The scheme exploits the difficulty of proof. Until exposing the organiser pays off for nominees and registration catches them, one person will serve time for another’s crime.

How the scheme works

Who the law holds liable

What needs to change

Practical steps

Sources

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