Cyrus Ahsani and his wife Sany The UAE is one destination that appears to have been favoured by Unaoil's owners to conduct suspect transactions without detection. The Gulf state is now considered a hot spot for money laundering by law enforcement agencies due to its role as a major international centre for finance, money remittance and hosting businesses in low-tax free-trade zones. UAE authorities recently shut down a money-moving business run by suspected major international money launderer Altaf Khanani, after his arrest by US authorities. It is understood the FBI is closely examining Unaoil's offshore accounts in connection to suspected money laundering. On May 11, 2011 Unaoil used its UAE business, Zenith Industrial Machinery, to move $1 million to a bank account belonging to another UAE businessman, Mahesh Khemka. Paperwork created by Zenith shows the payment was labelled as being for a "market survey" service in India that Khemka's firm was meant to provide. The service was a fiction. On the very same day Zenith sent the "market survey" contract to Khemka, a second Unaoil subsidiary, Unacomm, sent a second contract to Khemka for a separate "market survey" in India.

For the two allegedly separate services, Khemka was to receive a total of $5.6 million. But the leaked Unaoil files reveal that the "market survey" contracts were created to justify the movement of funds. Khemka (who did not respond to emails about the payments) was merely a buffer whose task was to move the $5.6 million to others. The identity of the final beneficiaries of the funds is unknown, but leaked Unaoil files and confidential sources have confirmed the money was intended to influence corrupt Iraq officials in return for giving the offshore arm of Australian company Leighton Holdings a multi-million dollar oil pipeline contract extension. Among the possible beneficiaries is one of Unaoil's most corrupt government contacts, Iraq oil official Oday al-Quraish, the project manager overseeing Leighton's contracts in Iraq. He is understood to have fled to the UAE fearing arrest. He also did not respond to correspondence sent to his personal email address.

It's not the only time Unaoil has sought to use offshore companies and "market survey" invoices to move money around the world. Unaoil's accounts show its owners, the wealthy Ahsani family, have formed companies in the Marshall Islands, Liechtenstein, the British Virgin Islands, the Jersey Islands, Liberia and other offshore destinations. They have moved funds to shelf companies in Panama, Hong Kong, Singapore, Switzerland and other countries seen as tax havens. Unaoil has refused to answer questions about its conduct, preferring to rely on a blanket denial of involvement in any corruption, and the threat of law suits. Unaoil records show that in 2008, it offered a $2 million "consultancy" to a Singapore shelf company, Excelsior Universal, ostensibly to conduct a "market survey" in Asia. A subsequent invoice suggests at least $1 million was paid. Excelsior was one of the shelf companies identified in the Panama Papers, for a project that revealed a huge number of offshore shelf companies in tax havens. On the January 25, 2009, seven months after Unaoil sent Excelsior a market survey contract, Excelsior prepared its own "market research" contract to be sent to a UAE firm called Gulf Development Marine Services. This contract was for $1.5 million. On the same day in January, an offshore company controlled by Unaoil created a separate contract destined for Gulf Development Marine Services, also for "market research" in Iraq. The value of this contract was worth $500,000.

As with the Khemka transactions, these contracts appear designed by figures associated with Unaoil to contrive a legitimate reason to move large sums to offshore bank accounts around the world. A consultant of Gulf Development Marine Services told Fairfax Media he had no knowledge of the contracts, but declined to answer questions. The use of shelf companies and offshore accounts creates a major challenge for policing agencies investigating Unaoil. It is notoriously hard in some jurisdictions (including, until at least recently, the UAE) to get information from banks and authorities about the owners of accounts and businesses. The fact that some of the company's most suspicious transactions have also involved New York or London banks looms as a major problem for the Ahsanis. It places them firmly in the jurisdiction of the US Justice Department, the FBI and the UK's Serious Fraud Office. In the US and UK, penalties for money laundering - if proved - can include lengthy jail terms.