By far the best US crime thriller series (IMHO) on Netflix has got to be Blacklist. Utterly mesmerising is the star Raymond Reddington (played by the superb James Spader). Reddington manages to be simultaneously as camp as a row of tents, and macho as the All Blacks.
The rest of the cast – both cops and robbers – are all excellent with intriguing sub-plots, endearing romances and lots of buttock-clenching suspense as the FBI race against time to catch the bad guys, recover the sniffing/folding stuff and save the victims from torture and painful deaths.
So inspired was I by taking up Blacklist binge-watching, that I decided to write an episode to submit to NBC (just in case the writers run out of ideas). My plot was hatched because every Blacklist episode contains all the ingredients that we need to tackle pension scams: the minute the crime (or intended crime) is identified, the FBI Special Agents swing into action, and SWAT teams are warmed up; the criminals’ mobiles are tracked and their computers hacked.
By the time I’ve cracked open the Snickers, Special Agents Wrestler and Mossad are on the scene and closing in fast on the bad guys. As I’m warming up my cocoa, the contraband has been uncovered; the bombs have been defused (with two seconds to spare); the bad guys are all either full of holes or in handcuffs; the full details of the dastardly criminal plot are laid bare. Most important, the lost $millions are recovered in full, and the valiant Red Reddington flies off into the sunset in his private jet with his trusty Dembe clucking at him for taking too many risks.
So here’s my humble attempt at the script for a Blacklist episode “The Pension Scam (No 69)” – script:
Arch pension criminal (and mastermind of the Capita Oak and Henley cases) XXXX XXXX – dressed in bright purple (to offset his flaming red hair) and driving a black Ferrari – struts into the offices of various QROPS trustees around the Med and meets cheery Irishman Justin Caffrey of Harbour Pensions. XXXX tells Caffrey of his plot to make millions out of scamming hundreds (or preferably thousands) of victims out of their pensions. His plan is to con hundreds of UK residents into transferring their pensions into a QROPS. And then (and this is the clever bit) XXXX, who is acting as the victims’ financial adviser, invests all their money in his own fund: the Trafalgar Multi-Asset Fund.
Being a particularly canny Irishman, Caffrey sees straight through XXXX’s dastardly plan and sends him and his (borrowed) Ferrari packing. Caffrey clocks XXXX as an outright spiv straight away. Caffrey is, anyway, already up to his ears in Phillip Nunn’s Blackmore Global investment scam, promoted by vile David Vilka, so he really can’t handle more than one scam at a time (being male, he can’t multi-task).
Way too thick-skinned, determined and greedy to be discouraged, XXXX heads across the Mediterranean to Gibraltar and the offices of STM Fidecs. There he meets CEO Alan Kentish who listens to XXXX’s offering with keen interest. Already under investigation for “tax irregularities”, Kentish is no stranger to “bending the rules” and is keen to learn more about how XXXX’s scam is going to work – and, of course, what is in it for Kentish himself.
XXXX explains that he has found an “umbrella” fund called the Nascent Fund run by Custom House Global Fund Services and a handsome but menacing-looking chap called Richard Reinert. This outwardly respectable-looking outfit allows wannabee fund “managers” (such as XXXX) to set up their own investment funds in the dodgy jurisdiction of the Cayman Islands – far from the eagle eye of the FCA.
Kentish is eager to know how much money can be made out of this plot. XXXX explains that 46% was earned out of his Capita Oak and Henley scams and that he hopes to make at least as much out of this one. With Kentish’s “help” (nudge nudge, wink wink). Of course, the proceeds could be split and plenty of brown envelopes used to disguise the handing over of the proceeds.
Things get off to a cracking start, with XXXX’s two trusted assistants: Tom Biggar and Paul Garner. But cracks start to appear early on. The success of the mission depends on the highest-risk assets being purchased with the funds – as these pay the highest “commissions”. But Biggar is a bad guy with a bit of a conscience, and he insists that some proper, prudent investments should also be made. This, of course, impacts on XXXX’s profits, so pretty soon Biggar “disappears” – never to be heard of again. Garner is seriously rattled and doesn’t want to end up the same way, so he heads off to work for the Gibraltar regulator – where he knows he’ll be safe as houses, as they’ll never take an interest in this crime. After all, STM Fidecs is one of the biggest employers in Gibraltar (after Betfred, Stan James, Paddy Power, William Hill, Bet 365 and 888 Holdings) – so there’s no risk of any of the perps doing porridge.
XXXX is now free to invest the whole fund (now well over £20 million) in whatever he pleases. So he sticks most of it in the German Dolphin (derelict property loan notes) Fund and cleans up. Trouble is, Richard Reinert of Custom House starts to get suspicious and starts sniffing around – after the worrying sudden disappearances of Biggar and Garner. He lifts the skirts of XXXX’s Trafalgar scam, and finds something rather more sinister than skid marks.
The FBI are a bit busy that day (yet another Blacklist case) so the SFO swings into action. XXXX is arrested. His office searched. The Gibraltar FSC twitches because XXXX’s third in command, Garner, is now working for them, so they turn a blind eye. Avoiding embarrassment, they get friendly local book cookers Deloittes to pop in to inspect STM Fidecs’ books. When Deloittes find out what a load of crap the STM QROPS is filled with, they wag their fingers sternly. Kentish is thoroughly upset (so much so, that he almost – but not quite – passes the fags round).
Now that the Trafalgar Multi-Asset Fund has been suspended – thanks to the hero of the hour: Reinert – Kentish decides to buy Caffrey’s QROPS firm, Harbour (which is full of Phillip Nunn’s Blackmore Global investment scam). Caffrey swans off into the sunset with £1 million burning a hole in his pocket, quietly humming “Oh Danny Boy”.
In the end, the handsome Reinert turns out to be a good guy after all, and gets some of the victims’ money back. (But only just enough to pay the liquidators’ fees!)
I submitted my carefully-typed script to NBC and waited with bated breath. A couple of weeks later their response arrived:
“Dear Miss Brooks, thank you for submitting your script for Blacklist episode “The Pension Scam (No 69)”. We have read your work with interest (and fell about laughing), but we do not feel it would be suitable for our series. Unfortunately, the plot is too far fetched and we do not consider that our viewers would find the story-line plausible. This sort of thing simply doesn’t happen in real life. However, we wish you all the best with your future writing efforts – but just suggest you try to stick to more believable plots.”
Sadly, of course, it was real life. As more than 400 victims will attest. So no more script-writing for me. I will stick to blogs in the future.
TPR has been neither coy nor shy in its published determination against Ward and Salih – and has openly called the London Quantum pension scheme, and the risky investments which Ward made, a “scam”.
But to any reasonable person’s mind, tPR’s determination in relation to Ward and London Quantum raises more questions than it answers. In fact, I would go even further and say that HMRC’s and tPR’s incompetence – as well as Dalriada Trustees‘ own failings – should be examined in parallel with Ward’s multiple frauds.
Because, make no mistake, London Quantum was only one of many.
It all started long before the Ark Pensions scam. Ward set out his stall transferring pensions to New Zealand and liberating 100% “tax free”. He boasted in the local Costa Blanca press that he had “helped” thousands of clients liberate their pensions (legally). Of course, this may have been free of tax in New Zealand, but when the Spanish tax authorities catch up with these clients, there will be a very expensive disaster.
It is extremely worrying that IVCM – a “phoenix” of the Brooklands disaster – is also offering the same New Zealand liberation facility today. It always worries me when firms fail to learn the lessons of past scams and expose unsuspecting victims to the same catastrophes that past scammers orchestrated. Add to this the fact that IVCM is regulated out of Gibraltar – the jurisdiction of choice for scammers such as XXXX XXXX and STM Fidecs – and I think it is well worth giving IVCM a very wide berth.
Prior to 2010, Ward was a tied agent of Inter Alliance – a company based in Cyprus which had an insurance license. For Inter Alliance in Cyprus, Ward successfully created the illusion that this gave his company Premier Pension Solutions some sort of license. But, in reality, it did not – as the Cyprus license was only for Inter Alliance and not for any other entity. Plus tied agents were (and still are) illegal in Spain.
As a sideline, Ward was flogging EEA Life Settlements as he had discovered the delights of making huge commissions out of dodgy, risky, illiquid investments to his unsuspecting victims. In 2010, Ward was working closely with Concept Trustees in Guernsey – run by Roger Berry. Initially happy to see Concept Trustees’ QROPS members have 100% of their pensions invested by Ward in EEA, Berry eventually realised that Ward’s firm was not regulated as it had been dumped by Inter Alliance. Of course, even before it had been dumped, Premier Pension Solutions wasn’t regulated anyway. But Concept Trustees was too stupid to realise that.
Concept then wrote to all the members who were clients of Ward’s Premier Pension Solutions and warned them that Ward’s firm was neither regulated nor had any professional indemnity insurance cover. Berry claimed he would not be accepting any further investment instructions from Ward, but this was basically just a load of hot air (aka lying) as he continued to accept investment instructions into EEA by Ward.
In September 2010, Premier Pension Solutions was appointed as a tied agent of AES International – a firm based in London and Dubai. The agency agreement covered PPS for investment and insurance business – but not pension transfer business. Ward’s PPS letterheaded paper claimed that it was a “partner” of AES and that it was regulated by the DGS (Spanish insurance regulator) and CNMV (Spanish investment regulator). PPS also became a member of FEIFA – the Federation of European Independent Financial Advisers (although he was later dumped by them). You can understand why so many victims thought that PPS was a bona fide advisory firm.
Then came the first of Ward’s major pension scams: Ark. It is worth looking at the history of Ark because this sets the scene for how nearly 500 victims came to lose their pensions and face tax liabilities – as well as the dozens of further scams operated by Ward (including London Quantum).
A famous footballer and his mate – a football club owner – bought a plot of land in Larnaca in Cyprus with a view to turning it into a golf resort. They paid £1.1 million for the property, but then realised it wasn’t big enough for a whole golf course (neither of them was bright enough to be able to count up to 18) and so they tried to find some other investors. The chumps they tried to con into buying more land adjacent to the original plot either couldn’t come up with the money or were frightened off such a high-risk, illiquid investment.
So the sporty pair went to see the footballer’s accountant – Andrew Isles of Isles and Storer (now owned by LB Group). Isles soothed the sporty pair’s worries by telling them that securing more investors was simple: just start a pension fund! He introduced them to what he called “two leading pension experts”: Craig Tweedley and Stephen Ward. Tweedley was already operating the KJK Investments/G Loans pension liberation scam (later to be placed in the hands of Dalriada Trustees by the Pensions Regulator) and Ward was a highly-qualified pensions expert, examiner and author.
The rest is history as nearly 500 victims lost their pensions to the Ark scam. But the sporty pair did very nicely – they sold the land in Cyprus to the Ark scheme for £4 million and pocketed the profit. The footballer tried to hide the money in Dubai but got caught and turned Queens Evidence. He and the other original investor (the football club owner) fell out and they ended up in court against each other – with the footballer triumphing. Andrew Isles also did very nicely as he sold introductions to a number of his clients and earned fat commissions in doing so.
As Ark unfolded – between mid 2010 and mid 2011 – Ward initially acted as an introducer. There were various introducers – many recruited by Ward when he ran a series of seminars in various parts of the UK. But Ward himself was the biggest introducer – accounting for more than a third of the whole £27 million fund and earning approaching three quarters of a million pounds in fees (the Pensions Regulator’s report of £350k was way off the mark).
Ward and his sidekick – bent lawyer Alan Fowler of Stevens and Bolton Solicitors – acted as the controlling minds behind Ark. The scheme documentation and the “loan” contracts were drawn up and explained by Ward and Fowler. Of the 5% commission charged by Craig Tweedley, Ward got at least 2% plus a transfer fee. But Ward had his eye on a much bigger proportion of the fees. Towards the end of the life of Ark, Ward was preparing to take Ark over from Tweedley – along with an associate of his: Peter Moat (another pension crook who went on to operate the Fast Pensions scam – now also in the hands of Dalriada Trustees). In a way, it was a shame that didn’t happen, as Tweedley did at least try to help the Ark victims, whereas Ward never lifted a finger. In fact, he simply told the Ark victims to throw the tax demands away as “HMRC would never pursue them”.
In February 2011, HMRC met with Tweedley and Ward to discuss the “loans” – so HMRC knew perfectly well that Ward was the main brain behind the scam. It is, therefore, astonishing that they did nothing to stop him operating so many further pension scams.
Ark came to a shuddering halt on 31st May 2011, when tPR appointed Dalriada Trustees and the scheme was suspended. Dalriada went up to Yorkshire to confront Crag Tweedley and relieve him of all the evidence and files relating to the scam. Tweedley told Dalriada that all the records were held down at Ward’s Manchester office at 31, Memorial Road and he drove down to collect them from Anthony Salih. He arrived to find Salih removing all the Premier Pension Solutions fee agreements on the instructions of Ward (he managed to shred most of them – but did missed a few which I now have).
After Ark, Ward went on to run the Evergreen Retirement Benefits QROPS scam with accompanying 50% “loans” and a further 300 victims lost £10 million worth of pensions. HMRC removed Evergreen from the QROPS list when they realised it was a liberation scam and Ward fell back on two more UK-based, bogus occupational schemes: Southlands and Headforte. Plus, he registered a number of new schemes – including Capita Oak.
The Capita Oak scheme was another bogus occupational scheme registered by Ward with a fictitious sponsoring employer: RP Medplant (Cyprus). There is, however, a firm called RP Med Plant in Cyprus. The Capita Oak trust deed was written by Ward’s bent lawyer Alan Fowler. Ward took responsibility for the transfer administration – transferring valuable personal and final salary occupational pensions into this scam – in the full knowledge that he was condemning hundreds of victims to certain financial ruin and poverty in retirement. Capita Oak is now also in the hands of Dalriada Trustees.
Other pension scams that Ward was operating – in addition to Southlands and Headforte – from 2012 onwards included Feldspar, Hammerley, Meribel, Halkin, Randwick, Bollington Wood and Westminster. And, of course, Dorrixo Alliance which was the trustee for many of these scams. Capita Oak and Westminster are both under investigation by the Serious Fraud Office.
How much more evidence do they need?
In May 2014, HMRC was given evidence of all of Ward’s various scams – including Dorrixo Alliance. They were also given detailed testimony by me and a number of victims of what Ward had been up to in the pension liberation fraud industry since Ark. It would have been very easy for HMRC to look up to see what other pension schemes Dorrixo was trustee to. Had they done this, they would have seen that Dorrixo was the trustee for the London Quantum scheme. If HMRC had taken any action, they could have prevented Mr. N – a serving police officer – and 96 other victims from losing their pensions to Ward and his various dodgy, inappropriate investments (including loans to Dolphin Trust).
If we add to the above catalogue of scams the Continental Wealth Management scam – 1,000 victims facing the loss of £100 million worth of life savings – Ward has been responsible for the destruction of thousands of people’s pensions this past eight years. Plus several suicides and deaths from stress-related medical conditions.
SERIOUS QUESTIONS ARISING FROM THE PENSIONS REGULATOR’S DETERMINATION RE:
Mr Stephen Alexander Ward – The Pensions Regulator case ref: C46205159
Ward was a director of Dorrixo from 13 October 2011 to 28 April 2015. A company called Quantum Investment Management Solutions LLP (“QIMS”) has at all material times been the sole sponsoring employer of the Scheme. Dorrixo became the sole trustee of the Scheme on 19 April 2014. Dorrixo is also recorded as being the Scheme administrator.
HMRC AND TPR WERE GIVEN EVIDENCE OF WARD’S COMPANY, DORRIXO, IN MAY 2014. THEY WERE ALSO GIVEN EVIDENCE OF A LARGE NUMBER OF SCAMS WARD OPERATED AFTER ARK – ALL INVOLVING LIBERATION FRAUD. WHY WASN’T ACTION TAKEN TO PREVENT LONDON QUANTUM? ALL 97 VICTIMS – INCLUDING A SERVING POLICE OFFICER – COULD HAVE BEEN PREVENTED.
On 18 June 2015 the Regulator appointed Dalriada Trustees Limited (“Dalriada”) as an independent trustee to the Scheme, with exclusive powers.
HAS ONE SINGLE PENNY EVER BEEN RETURNED TO ANY OF THE PENSION SCAMS PLACED IN THE HANDS OF DALRIADA TRUSTEES? THERE ARE DOZENS OF THEM, AND FEW – IF ANY – OTHER INDEPENDENT TRUSTEES ARE EVER APPOINTED BY TPR. BUT THERE SEEMS TO BE NO RECORD OF ONE SINGLE MEMBER EVER GETTING ANY RETURN FROM ANY OF THE SCHEMES IN THE PAST EIGHT YEARS – DESPITE THE MANY MILLIONS DALRIADA HAVE PAID THEMSELVES FROM THESE SCHEMES.
Following its appointment Dalriada discovered that there were approximately 609 files on record relating to potential new members, each at various stages of progression towards becoming a new member.
AS THIS EVIDENCES THAT THIS SCAM COULD EASILY HAVE DWARFED ARK IN A VERY SHORT SPACE OF TIME, DON’T HMRC AND TPR RECOGNISE THAT THEIR LAZINESS AND NEGLIGENCE NEED TO BE ADDRESSED? THEY LEARNED NOTHING FROM ARK – AND WHILE THERE ARE VALID CRITICISMS OF WARD FOR HAVING LEARNED NOTHING, HE IS JUST A COMMON SPIV WHILE HMRC AND TPR ARE SUPPOSED TO BE GOVERNMENT DEPARTMENTS WITH A RESPONSIBILITY TO PROTECT THE PUBLIC. THE SCALE OF THIS SCAM SHOWS THESE TWO ORGANISATIONS ARE NOTHING BUT HOPELESSLY INEPT AND AMATEURISH IN THEIR APPROACH TO DILIGENCE AND PUBLIC RESPONSIBILITY.
The Scheme was promoted to potential new members by introducers. These included the following entities: GoBMV; Baird Dunbar; What Partnership; the Resort Group PLC; Friendly Investments; Premier Mark Consultants and Quantum Wealth Management Solutions Limited.
THE DANGERS OF THE SCOURGE OF “INTRODUCERS” SHOULD HAVE BEEN LEARNED FROM THE ARK SCAM IN 2011. WARD RECRUITED DOZENS OF THEM ALL OVER THE COUNTRY. AND YET NONE OF THEM HAS EVER BEEN BROUGHT TO JUSTICE FOR THEIR PART IN ARK, AND HAVE GONE ON TO OPERATE AS INTRODUCERS AND EVEN HOLD KEY CENTRAL ROLES IN LATER SCAMS. THIS INCLUDES FRIENDLY INVESTMENTS AND JULIAN HANSON – WHOSE SCHEMES ARE NOW ALSO IN THE HANDS OF DALRIADA TRUSTEES.
Gerard was responsible for producing template risk letters, member application forms, pro forma declarations stating that the person signing them was a self-certified sophisticated investor, member booklets and the statement of investment principles (of which there were four versions). Gerard sent these documents to members once they had been introduced to the Scheme by an introducer.
GERARD ASSOCIATES, RUN BY GARY BARLOW, HAD ACTED AS AN INTRODUCER TO WARD IN THE ARK SCAM. AND YET HE WAS LEFT FREE TO OPERATE IN THE SAME CAPACITY IN THE LONDON QUANTUM SCAM – AND EVEN TAKE ON A MORE CENTRAL ROLE. GERARD ASSOCIATES WAS AT THE TIME AN FCA-REGULATED FIRM – AND REMAINS SO TO THIS DAY. THE FCA HAS TAKEN NO ACTION TO REMOVE THIS FIRM OR TAKE ANY ACTION AGAINST GARY BARLOW.
GERARD ASSOCIATES’ GARY BARLOW WAS PAID £253,000 FROM THE LONDON QUANTUM SCHEME FOR DEFRAUDING VICTIMS INTO SIGNING AGREEMENTS THAT THEY WERE “SOPHISTICATED” INVESTORS. SO WHY HASN’T BARLOW BEEN PROSECUTED AND JAILED – AND MADE TO PAY THIS MONEY BACK TO THE VICTIMS?
A material number of the new members had a low or medium appetite for investment risk and, in any event, were unaware that the Scheme’s investments were high-risk investments. The Panel was troubled by the apparent disconnect between members’ appetite for risk and the high risk nature of the investments made by Dorrixo. Mr Ward accepted that the Scheme’s investments were high risk, but claimed this was made clear to new members in the Member Booklet.
I DON’T KNOW WHAT SORT OF DRUNKEN DUMMIES MADE UP TPR’S “PANEL”, BUT DID THEY SERIOUSLY THINK THAT ANY PENSION FUNDS SHOULD EVER INVEST IN HIGH-RISK CRAP? INDIVIDUAL MEMBERS’ APPETITE FOR INVESTMENT RISK IS IRRELEVANT – THIS WAS A PENSION FUND, NOT A CASINO.
The case against Ward was based on failures of competence and capability, and also a lack of honesty and integrity as well as Ward’s involvement with “pension liberation” as an introducer of members to the “Ark” schemes.
BUT TPR AND HMRC KNEW ALL ABOUT THIS BACK IN 2010 AND 2011. WHY DID THEY DO NOTHING TO PREVENT WARD FROM SCAMMING MORE VICTIMS OUT OF MORE MILLIONS OF POUNDS. THEY STOOD BACK AND WATCHED – DESPITE HAVING HARD EVIDENCE THAT HE WAS STILL UP TO HIS CRIMINAL MISCHIEF.
Mr Ward did not dispute that a company of his (Premier Pensions Solutions SL) was involved in introducing members to the Ark Schemes, but states that the relevant activity pre-dated any finding by the courts of pensions liberation and that Mr Ward had no knowledge that the schemes were being used for such activity.
BUT HMRC, TPR AND DALRIADA ALL KNOW THIS ISN’T TRUE. THEY HAVE ALL SEEN EVIDENCE THAT WARD AND HIS BENT LAWYER ALAN FOWLER ACTUALLY PRODUCED THE “LOAN” (MPVA) DOCUMENTATION AND EXPLAINED THE LOANS IN SOME CONSIDERABLE DETAIL TO THE VICTIMS. THE MPVA CONTRACTS WERE DRAWN UP BY FOWLER. IS IT REALLY CREDIBLE THAT NEITHER HMRC NOR TPR WOULD HAVE OBJECTED TO THIS STATEMENT?
The Panel did not consider there was sufficient evidence of Ward having actual knowledge of, or turning a blind eye to, the illegal nature of the activity of the Ark Schemes when carrying out his role as introducer before.
SERIOUSLY? I HAVE GIVEN EVIDENCE OF THIS TO BOTH HMRC AND TPR ON MANY OCCASIONS. THIS HAS BEEN DISCUSSED AT MEETINGS WITH DALRIADA TRUSTEES ON MANY OCCASIONS. EVIDENCE OF THIS HAS BEEN GIVEN TO THE SERIOUS FRAUD OFFICE ON MANY OCCASIONS BY VARIOUS VICTIMS AND ME. WHAT FURTHER EVIDENCE DID THE PANEL WANT? EVERY ARK MEMBER’S FILE WAS FULL OF SUCH EVIDENCE. EITHER TPR IS LYING OR IT IS INCOMPETENT. OR BOTH.
The Case Team also relied on certain alleged failures in relation to other pension schemes (called Headforte and Halkin), of which Mr Ward was a trustee. These are denied by him (e.g. an allegation of failure to appoint an auditor to those schemes) and the Panel did not consider it necessary to make findings in respect of them.
SO WHAT ACTION HAS TPR TAKEN IN RELATION TO HEADFORTE AND HALKIN? BOTH WERE BEING USED FOR PENSION LIBERATION FRAUD BY WARD – AND YET THE VICTIMS PROBABLY STILL HAVE NO IDEA WHAT HAS HAPPENED TO THEIR MONEY. IT IS ABSOLUTELY ASTONISHING THAT NO ACTION HAS BEEN TAKEN IN RELATION TO THESE TWO SCHEMES, PLUS ALL THE OTHERS WARD HAS BEEN OPERATING OVER THE YEARS.
Stephen Alexander Ward (date of birth 11 July 1955) is hereby prohibited from being a trustee of trust schemes in general. This order has the effect of removing the above-named individual from all or any schemes of which he is a trustee. By section 6 of the Pensions Act 1995, any person who purports to act as a trustee of a trust scheme whilst prohibited under section 3 is guilty of an offence and liable (a) on summary conviction to a fine not exceeding the statutory maximum, and (b) on conviction on indictment to a fine or imprisonment or both.
SO, WARD CAN STILL OPERATE AS A PENSIONS ADMINISTRATOR? CAN STILL DO PENSION TRANSFERS? HE IS BASICALLY FREE TO CARRY ON AS BEFORE. THIS MAKES HMRC AND TPR COMPLICIT IN WARD’S MANY CRIMES.
THIS IS NOT JUST THE DEATH OF TRUST, BUT OF ANY CONFIDENCE IN THE GOVERNMENT, REGULATORS AND CRIME PREVENTION AGENCIES TO PREVENT OR DEAL WITH PENSION SCAMS AND SCAMMERS.
Articles like New Model Adviser’s report on some of the scammers behind the Capita Oak/Henley/Store First scam getting banned always makes me smile. Knowing that a few pension scammers (four in this case), are being named and shamed – as well as banned from being directors – motivates me to share information about these evil scams with the public.
“An investigation led by the Insolvency Service revealed the directors were connected with Transeuro Worldwide Holdings, which helped fund two introducer firms Sycamore Crown and Jackson Francis. The firms were involved in the transfer of £57 million of pension savings.
Sycamore Crown director Stuart Greehan agreed to a nine-year voluntary ban as a result of false and misleading statements to encourage investors to transfer their pensions.
Karl Dunlop, director of Imperial Trustee Services, and Ian Dunsford, director of Omni Trustees, agreed to bans of nine and seven years, respectively, for failing to act in the best interests of members and ‘failing to ensure investments were adequately diverse’.
While not a formally appointed director of Transeuro Worldwide Holdings, Mike Talbot (AKA Stephen Talbot) accepted a nine-year disqualification undertaking for failing to disclose what happened to the millions of pounds of pension assets.”
BUT, IN ADDITION TO THESE EVIL SCAMMERS, THERE WERE OTHER PLAYERS IN THIS APPALLING TRAGEDY AND THEY WERE NOT MENTIONED. SO HERE ARE THE OTHER PEOPLE WHO PLAYED LEADING PARTS IN THIS FOUL PLAY:
Stephen Ward of Premier Pension Solutions SL and Premier Pension Transfers Ltd – he handled the transfer administration from the original (ceding) pension providers. He was, apparently, paid £300 per Capita Oak transfer – and would have known that he was condemning each member to certain loss of his or her pension.
XXXX XXXX of Nationwide Benefit Consultants, The Pension Reporter, Victory Asset Management and Tourbillon, was clearly the “controlling mind” behind Capita Oak. He also ran the Thurlstone loan scheme which paid 5% in cash to the Capita Oak victims as a “bonus” or “thank you”. HMRC is now taxing these payments at 55% as they qualify as unauthorised payments. XXXX XXXX then went on to launch the successful Trafalgar Multi Asset Fund scam which saw over 400 victims lose their pensions to high-risk toxic loans to Dolphin Trust in an STM Fidecs Gibraltar QROPS. XXXX – as with most pension scammers – subsequently ignores the plight of the victims when the schemes eventually and inevitably collapse. XXXX is under investigation by the Serious Fraud Office and was also responsible for the Westminster pension scam.
Mark Manley of Manleys Solicitors – acting for XXXX XXXX.
Stuart Chapman-Clarke, Christopher Payne, Ben Fox, Bill Perkins, Alan Fowler, Karen Burton, Tom Biggar, Sarah Duffell, Jason Holmes, Metis Law Solicitors, Roger Chant, Brian Downs, Phillip Nunn and Patrick McCreesh all played further prominent roles in this series of scams and profited to a greater or lesser degree.
It is believed that cold calling techniques were used to lure unsuspecting victims into this series of unregulated investment scams. Victims’ pension savings were transferred into bogus occupational pension schemes whose trustees/administrators were Omni Trustees and Imperial Trustee Services. The schemes were Henley Retirement Benefit Scheme (HRBS) and Capita Oak Pension Scheme (COPS). But the scammers also used a variety of SIPPS which included Berkeley Burke, Careys Pensions, Rowanmoor, London and Colonial and Stadia Trustees.
As is often the case in scams like these, the victims were lured in with promises of so-called guaranteed high returns by spivs masquerading as advisers, who were also unqualified and unregulated to give financial advice.
The unqualified advisers were able to transfer millions of pounds’ worth of pension savings into these schemes which included investments in unregulated storage units and over £10 million into COPS (Capita Oak) and over £8 million into HRBS (Henley). The promised high returns were never paid to the investors – but handed over to the scammers instead. The pension funds are now suspended with the funds trapped in these illiquid investments.
The company directors have received a total ban of 34 years collectively. Here at Pension Life we would have liked to have seen lifetime bans all round.
The Serious Fraud Office (SFO) is now moving forward with their investigations against Omni and Imperial. They urge people who are members of HRBS (Henley) and COPS (Capita Oak) to contribute to criminal evidence against the scammers via a questionnaire.
As always, the team at Pension Life urges pension holders to be wary of pension scammers. Never accept a cold call offer, be aware that scammers lurk everywhere and if it seems to good to be true it probably is!
I have read the report about what happened to the scammers at STM Fidecs in the wake of the Gibraltar FSC’s investigation and Deloitte’s so-called “expert report”.
Frankly, I am stunned. I have members who are victims of the Trafalgar Multi-Asset Fund and STM Fidecs and they are, understandably, stunned as well. I have met the people at the Gibraltar FSC and they had seemed decent guys |(but WTF do I know?!). Maybe they’ve all left, because the people I met appeared enthusiastic and conscientious. But perhaps they’ve been replaced by a bunch of malfunctioning robots, or ex-scammers or – much worse – ex STM Fidecs employees.
Serious Fraud Office investigating XXXX XXXX
The bottom line is that STM Fidecs scammed hundreds of victims out of their pensions. STM Fidecs took business from unlicensed scammer XXXX XXXX of Global Partners Limited (only had an insurance license with Marcus Groombridge’s firm Joseph Oliver) and then invested 100% of the victims’ funds into an illegal UCIS fund – run by XXXX XXXX (now under investigation by the Serious Fraud Office – although I really don’t know what they are playing at because XXXX still isn’t behind bars).
The rest is history. The Trafalgar Multi-Asset Fund is being wound up, and after paying the liquidation costs to Stephen Doran, of Doran + Minehane, there is unlikely to be much – if anything – left. Deloittes spent weeks supposedly investigating STM Fidecs’ books. I reckon the chumps at Deloittes probably spent most of that time on the golf course with Alan Kentish having a chuckle and a side bet about how feeble the Gibraltar FSC was likely to be. And, of course, they were right.
Now, of course, Deloittes and STM Fidecs are celebrating, as the GFSC has done nothing to stop this iniquitous, dishonest, incompetent and negligent firm from trading. Whether STM Fidecs bribed the Gibraltar FSC, or merely got them drunk on the golf course, we will never know. And it makes no difference. But certainly the matter has been brusquely brushed under the carpet and the hundreds of ruined lives have been conveniently ignored and forgotten.
Neither STM Fidecs nor the Gibraltar FSC has said a word about redress for the Trafalgar Multi-Asset Fund victims.
The only words spoken are that the Gibraltar Regulator has told STM Fidecs to “improve its compliance”. Improve?? How can you improve something that doesn’t even exist at all? We know that one victim (of scammers Holborn Assets) was bullied by STM Fidecs for trying to improve compliance and harassed for trying to stop obviously non-compliant transactions when she was employed by them. She was subsequently “paid off” and threatened with a gagging order.
“STM is now expected to engage with the Gibraltar FSC in order to discuss the Recommendations of the report, and agree a plan of action to implement them.” (according to the report by FT Adviser). Recommendations? Where are the sanctions? Where are the appropriate fines? Where are the bans to stop Alan Kentish and David Easton from ever practising in financial services again? Where is the cancellation of STM Fidecs‘ license?
With this in mind, here are some idiots’ guides as to how to become a pension trustee, and how to become a regulator. Both are equally easypeasylemonsqueasy – any old idiot or scammer could do it.
HOW TO BE A PENSION TRUSTEE IN EASY STEPS
Think of a catchy name: obviously inspired by the acronym STD, Alan Kentish came up with the name STM. FIDEC is an acronym for “Fighting Infectious Diseases in Emerging Countries”. Here’s my suggestion: Trussed4U – wadya fink?
Think of a jurisdiction with the most ineffective, pathetic and corrupt regulation – such as Gibraltar
Find an unlicensed scammer like XXXX XXXX who will transfer lots of UK-resident victims into an offshore QROPS and invest their life savings in whatever crap will pay him the highest commissions
Sit back and rake in the profits
Forget fiduciary obligations or anything with the word “trust” in it – only concentrate on the word “trussed“
Play golf with the regulator
HOW TO BE A REGULATOR
Join a golf club (that isn’t too picky about who it lets in)
Give licenses to as many scammers as possible – the more the merrier
Buy lots of blindfolds (to help turn a blind eye to scams and scammers)
Play lots of golf with the scammers and bent pension trustees who facilitate financial crime
When an advisory firm or a trustee firm gets caught scamming, slap a few people on the wrist with a wet fish
Write meaningless reports about robust compliance
HOW TO BE A SCAMMER
Find yourself a bent jurisdiction (such as Gibraltar)
Find a bent trustee who will accept business from any old unlicensed scammer (such as STD FIDEC)
Find a bent “umbrella” fund which will facilitate financial crime – such as Richard Reinert’s Nascent Fund
Find a Ponzi scheme such as Dolphin Trust which will issue “loan notes” at 10% interest per annum (and up to 25% in introduction commission)
Transfer hundreds of UK residents to a Gibraltar QROPS scam
Get the trustee to agree to invest 100% of 100% of the victims’ retirement savings in … your own fund!
See how easy it is to be either a trustee, a regulator or a scammer? But, equally, remember how easy it is to be a victim!
Quite frankly, Gibraltar should be towed out to sea and sunk. It is a disgrace to the British nation. Just give it back to the Spanish and let them clean it up – they would soon kick the likes of STM Fidecs out and stop any further scams and scammers from operating on Spanish soil. Soil being the operating word.
Rather than going on about how utterly disgusted I am with the Gibraltar regulator, I will leave it to the eloquent words of one of the STM Fidecs/Trafalgar Multi-Asset victims to put this sickening disgrace into perspective.
Firstly, do Gibraltar FSC actually realise over 1,000 individuals and their families are affected by the Trafalgar fiasco, who will potentially all suffer negatively in many different ways during their retirement years? On a personal level, I should haveknown better but was caught out by cleverness at a weak moment in my life, but many others I have spoken to had no understanding at all of financial affairs and put all of their trust in the hands of STM and all connected parties due to their apparent convincing knowledge and lies – shocking!!!!!
Due to my own personal research, I know of several other financial institutions who were offered and were involved in discussions regarding Trafalgar. But due to having correct procedures in place (unlike STM), they clearly ”smelled a rat”, and were far more ”ROBUST” in their approach. The only rat STM smelled was some form of hopeful ”Magic Money Tree” with no concern for its clients’ wellbeing – apart from its own pound note signs.
As you already know I have previously discussed this matter with my local MP and with your permission would like to highlight again the manner in which Gibraltar FSC have dealt with and inadequately reacted to STM’s performance. STM’s website highlights their glowing history and expertise, but at no point mentions their clearly poor basic audit and compliance mechanisms.
Hopefully, at some point in the future all the evil parties – including STM – in this matter are dragged through the courts, eventually embarrassed and humiliated by the press, and made to pay both financially and personally for their hideous crimes – I can only dream.
Still angry and in despair.
STM Fidecs/Trafalgar Multi Asset Fund Victim
That victim may well have lost her entire life savings thanks to XXXX XXXX and STM Fidecs. I am sickened and disgusted with our own onshore regulator’s pathetic failings: the FCA. But, quite frankly, the Gibraltar FSC makes the FCA look like Superman with TWO pairs of pants on outside their tights!
Interestingly, Justin Caffrey – who used to run Harbour Pensions in Malta – told me a year or so ago that he had been approached by XXXX XXXX who wanted to flog his toxic Trafalgar Multi Asset crap.
Caffrey claimed to have sent XXXX packing with a flea in his ear because he twigged straight away that XXXX was a no-good spiv. However, he had no such ethics when he invested victims’ pensions in Phillip Nunn’s Blackmore Global crap.
But now STD FIDEC has bought Harbour and Caffrey has been given the heave-ho. You couldn’t make it up!
STM Fidecs, the Gibraltar-based trustee firm used for the Trafalgar Multi Asset Scam, is now the subject of large numbers of complaints to the Gibraltar authorities. Hundreds of victims of XXXX XXXX’s unlicensed “advice” transferred safe UK pensions to a Gibraltar STM Fidecs QROPS and then he invested 100% of their funds into his own fund – Trafalgar Multi Asset (now under investigation by the Serious Fraud Office). These victims have now submitted evidence and testimony. These reports and complaints are against both XXXX XXXX and STM Fidecs for their part in this scam.
STM Fidecs are also being reported to the Gibraltar Financial Services Commission for the attention of:
Annette Perales, Head of Financial Crime
and
Zoe Westwood, Head of Enforcement, Legal, Enforcement and Policy
The Serious Fraud Office has been investigating this scam – in which STM Fidecs played an integral and crucial part – for some months. XXXX XXXX and one of the STM Fidecs directors have been arrested. XXXX’s office was searched and no doubt STM Fidecs’ offices were also searched. Obviously, the victims all want those responsible for this scam to serve maximum prison sentences.
The STM Fidecs website makes the following grand-sounding claim:
“The backbone of STM is its staff. We have people who have worked for us for 20 years who are the heart and soul of our business. If we didn’t have outstanding staff, we wouldn’t be able to do what we do.”
The only thing “outstanding” would be an immediate admission of their guilt and negligence, as well as an undertaking by STM Fidecs to compensate their victims for the £ millions of losses they are facing due to STM Fidecs’ complicity with this scam. Let’s examine some of these staff and see how much backbone they really have.
Alan Roy Kentish ACA ACII AIRM Role: Chief Executive Officer
Alan Kentish, CEO, claims to be a qualified chartered accountant specialising in the financial services industry. So you would have thought he would have known not to accept business from an unlicensed firm – XXXX XXXX’s Global Partners Limited (now Tourbillon). He ought to have known that UK residents should not be transferred to a QROPS at all. He would have known that members’ funds should not be 100% invested in one UCIS fund (illegal to be promoted to UK residents). And he should have recognised that it is a clear conflict of interest for members to be invested in a fund for which their adviser was also the investment manager.
What has Alan Kentish done to put this right? How much compensation has he offered to the hundreds of distressed investors? Has he engaged with the victims and assured them that STM Fidecs acknowledges their responsibility, liability and culpability? No – Alan Kentish has done nothing except pull up the drawbridge-like a spineless coward.
David Easton, Head of Pensions at STM Group PLC
“David Easton, Head of Pensions for STM Group PLC joined STM in October 2014 as Managing Director of the Gibraltar pensions business and is also a board member of the pensions businesses in Malta and the UK. Since 1990 David has worked in the financial services arena specialising in pensions administration. David is responsible for driving the expansion of STM Group’s international pensions division as well as personal and occupational pension schemes in Gibraltar and personal pensions in the UK.”
So, responsible for driving the expansion of STM’s pension business into an investment scam run by a known serial scammer? Well done David. Your “primary focus” was very clear: put UK residents into a QROPS and then allow all of them to be 100% invested into an illegal UCIS. And to what extent has he engaged with the hundreds of distressed victims of this scam? Zero. Another spineless coward who refuses to speak to these people. He will neither explain nor apologise.
A former employee of STM Fidecs sent me the following statement:
“We were told not to go to the Pension Life website so as not to give her any traffic and SEO rankings. I believed them. More fool me. This is why I am now checking it out and am amazed at what’s on there.
I was asked to dig the dirt on Angela Brooks and I did, believing STM had not been aware of the Trafalgar stuff but had instead been duped. It’s more than apparent now that they fully knew what they were doing. They have sent Angela lawyers letters insisting she cease from mentioning them on her website or will take legal action against her.
Glynis Broadfoot (a victim of Holborn Assets and Gower Pensions) who also used to work for STM Fidecs, was marched out. We had no anti-bullying policy in place at the time and Glynis was being bullied. They marched her out on trumped up charges.
If I had known this at the time I would have objected. Glynis won’t speak though. They must have frightened her to death.
Outstanding staff? I think not. The only thing the STM Fidecs staff excel at is bullying. And bullies are, of course, the biggest cowards of all.
Dolphin Trust – a UCIS which was illegal to be sold to UK residents
The Trafalgar Multi Asset Fund liquidators say this is the most obvious scam they have ever seen. Purely designed through ‘layering’ to misappropriate funds, the liquidators are just glad the administrators pulled the plug at £21m and not later. At the height of the success of this scam, STM Fidecs was accepting more than £1 million a month from UK residents (none of whom should have transferred into a QROPS at all) and allowing it all to be invested in XXXX XXXX’s illegal UCIS.
Apparently, Dolphin Trust (the German fund which borrows money to refurbish derelict government and listed buildings) has “cooperated” and the liquidators have found some other assets as well, although getting them may prove tricky since they will have been vigorously hidden. Dolphin Trust is typically found alongside car parking spaces, store pods, eucalyptus plantations, truffle trees and other toxic crap peddled by the scammers.
The liquidators reckon the victims might get 50% back less costs, so after the liquidators’ costs that would be nearer 30% net. But STM Fidecs know all this, but have deliberately hidden it from the victims.
It is human to err, and STM Fidecs is staffed by humans (albeit spineless ones). But what is not forgivable is to fail to come to the table and assure the victims they will be compensated for their losses and profound distress. STM Group has been bragging that it has plenty of money and will be buying up other trust companies to make their business bigger and more profitable.
None so blind….
STM Fidecs’ victims feel they shouldn’t be in the pension trustee business at all since they are clearly incompetent, dishonest and dishonorable. This belief is clearly correct since STM Fidecs also accepted transfers from Continental Wealth Management (unlicensed “chiringuitos”) and then allowed the victims’ pensions to be 100% invested in high-risk, professional-investor-only structured notes. As a result, the STM members are facing heavy losses.
Hundreds of victims have reported both XXXX XXXX and STM Fidecs to the SFO and the GFSC for fraud
The Gibraltar authorities must now show how “highly regulated and transparent” Gibraltar is. As things stand, the evidence is that Gibraltar is full of thieves, scammers and scoundrels. The chiringuitos love being there because the regulation is widely accepted as being as spineless as the staff and directors at STM Fidecs.
**********************************
As always, Pension Life would like to remind you that if you are planning to transfer any pension funds, make sure that you are transferring into a legitimate scheme. To find out how to avoid being scammed, please see our blog:
Regulators have got to do some effective regulating
Regulators and scammers; cops and robbers; cowboys and indians. Each has their role: cowboys fire their six shooters and dodge the injuns’ arrows valiantly; cops drive their police cars at breakneck speed to corner the robbers in a dark alley; regulators waggle their flaccid willies and watch the scammers walk all over them.
In the week my great friend had his appendix out (somewhat hurriedly as it happens) I thought I would write a slight variation on the Three Sausages poem:
Regulation, regulation, regulation, Three scammers went to the station, One got crushed, one got killed, And one got a huge operation.
The sizzling scammers need to be put behind bars – and the keys need to be thrown away.
Now, I am not suggesting I want the scammers crushed or killed – nor even that they suffer the same pain and discomfort that my mate has gone through in hospital this past week. But I do want them stopped from harming more victims and destroying more life savings. And, of course, put behind bars where the only thing they can scam is the soap on a rope.
WHAT DO REGULATORS NEED TO DO AS A MATTER OF URGENCY?
All regulators in all jurisdictions where has been a history of scamming and mis-selling need to work closely with governments, tax authorities, financial crime units, ombudsmen and the press. There has to be a “zero tolerance” attitude to scams and scammers – and all those responsible have to be brought to justice. And publicly so. It is clear that most regulators – including the FCA – are limp, lazy and useless and this has to change. Here are some examples of regulators’ failures in each jurisdiction:
Allowing unregulated firms to provide financial, pension and investment advice freely and without sanction in the UK. Sometimes these firms have an insurance license – sometimes none at all
Not sanctioning regulated firms for clear breaches and/or fraud – such as Gerard Associates which was introducing Ark victims to Stephen Ward of Premier Pension Solutions as far back as 2010, and was then providing “advice” to Ward’s London Quantum victims
Ignoring firms such as Fast Pensions who have defied 37 Pensions Ombudsmen’s determinations
Failing to coordinate criminal prosecutions against the scammers behind numerous scams who ruined thousands of lives and cost hundreds of millions of pounds’ worth of life savings
Failing to use existing legislation provided by FSMA 2000 to prosecute advisors (regulated and/or unregulated) overtly contravening the ban on communicating invitations to retail clients to invest in Unregulated Collective Investment Schemes
Announcing ineffective crack-down plans by newly-appointed government minsters who have failed to grasp the enormity of the pension scamming industry and the desperate plight of thousands of pension scam victims
Failing to police and sanction negligent pension trustees such as STM Fidecs for accepting members introduced by an unlicensed adviser: XXXX XXXX of Global Partners Ltd/The Pension Reporter – who was also the fund manager for the UCIS that all the victims had their pensions invested in and which is now being wound up
Refusing to communicate with members on the progress of the winding up of the Trafalgar Multi Asset Fund which had been run by XXXX XXXX
Omitting to take action against STM Fidecs for its role in the Cornerstone Friendly Society investment scam
Taking no action against Trustees, Integrated Capabilities Malta Ltd (ICML) for accepting retail members from an unlicensed firm in the Czech Republic and knowingly permitting investments in Nunn McCreesh’s UCIS: Blackmore Global, as well as Malta-licensed fund Symphony – a sub-fund of the Nascent Platform that is licensed only for professional investors
Not sanctioning Customs House Global, that runs the Nascent Platform, for inadequate due diligence and accepting unscrupulous sub-fund managers (such as XXXX XXXX, investment manager of failed TMAF and later, the recently wound up Symphony Fund) that exploit the platform for the sole purpose of pension scamming
Allowing an unlicensed firm – Square Mile Financial Services – to operate freely in the EU, providing pension and investment advice with only an insurance mediation license
Ignoring insurance companies which accept investments in UCIS funds and professional-investor-only instruments for retail investors
Failing to recognise those registered Closed-Ended Investment Companies whose true nature is as a Collective Investment irrespective of their form, such as Blackmore Global (registered number 010221V), that intentionally circumvent the stricter regulations imposed on collective investments, specifically to hide their financial accounts and the sub-funds which invariably include unsigned loan notes and high-risk hare-brained projects
Failing to act against a pension liberation scam – Evergreen Retirement Benefits Scheme – run by Simon Swallow who was working with Stephen Ward of Premier Pension Solutions and operating Marazion “loans”
Ignoring Concept Trustees (Guernsey) who offered retail investors the EEA Life Settlements UCIS and then accepted investment instructions from unlicensed, un-insured Stephen Ward of Premier Pension Solutions
As always, Pension Life would like to remind you that if you are planning to transfer any pension funds, make sure that you are transferring into a legitimate scheme. To find out how to avoid being scammed, please see our blog:
Blacklist – “The Pension Scam (No 69)”
than one scam at a time (being male, he can’t multi-task).
Kentish is eager to know how much money can be made out of this plot. XXXX explains that 46% was earned out of his Capita Oak and Henley scams and that he hopes to make at least as much out of this one. With Kentish’s “help” (nudge nudge, wink wink). Of course, the proceeds could be split and plenty of brown envelopes used to disguise the handing over of the proceeds.
Now that the Trafalgar Multi-Asset Fund has been suspended – thanks to the hero of the hour: Reinert – Kentish decides to buy Caffrey’s QROPS firm, Harbour (which is full of Phillip Nunn’s Blackmore Global investment scam). Caffrey swans off into the sunset with £1 million burning a hole in his pocket, quietly humming “Oh Danny Boy”.
Sadly, of course, it was real life. As more than 400 victims will attest. So no more script-writing for me. I will stick to blogs in the future.
Then came the first of Ward’s 
After Ark, Ward went on to run the 
Following its appointment Dalriada discovered that there were approximately 609 files on record relating to potential new members, each at various stages of progression towards becoming a new member.
SO, WARD CAN STILL OPERATE AS A PENSIONS ADMINISTRATOR? CAN STILL DO PENSION TRANSFERS? HE IS BASICALLY FREE TO CARRY ON AS BEFORE. THIS MAKES HMRC AND TPR COMPLICIT IN WARD’S MANY CRIMES.
Stephen Ward of Premier Pension Solutions SL and Premier Pension Transfers Ltd
Mark Manley of Manleys Solicitors – acting for XXXX XXXX.
It is believed that cold calling techniques were used to lure unsuspecting victims into this series of unregulated investment scams. Victims’ pension savings were transferred into bogus occupational pension schemes whose trustees/administrators were Omni Trustees and Imperial Trustee Services. The schemes were 
Now, of course, Deloittes and STM Fidecs are celebrating, as the GFSC has done nothing to stop this iniquitous, dishonest, incompetent and negligent firm from trading. Whether STM Fidecs bribed the Gibraltar FSC, or merely got them drunk on the golf course, we will never know. And it makes no difference. But certainly the matter has been brusquely brushed under the carpet and the hundreds of ruined lives have been conveniently ignored and forgotten.
