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No, usually the shell companies have zero or minimal number of employees.

sure, but unless money moves through them, what's the harm?

The could have done it so any one person can only have "shell" companies up to the point when x million is moved through them in any one given period.

They do move money but, because it's so easy and relatively cheap to open them, they can split the flows into tens of hundreds of them. So you have fractions of a million moving at once, not a big lump sum.

tens of hundreds of them....but if the total is more than $x a year you must declare.

Anyway, the decided this way and so it is.

There is nothing to declare because the beneficiary wasn't needed. Now it is.

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