Just When You Thought It Could Not Get Better

January 2022 Martin Woods

In a prior article we referenced the game changing approach, the Financial Conduct Authority (FCA) is applying to fraud and the game changes the regulator expects from firms. The article looked at a specific entity name published upon the FCA fraud and scam Warning List to highlight the presence of UK address upon the list. The FCA had added Fixed Rate Finder to the Warning List along with the address the 12 Constance Street, London E16 2DQ.

Research connected this address to thousands of UK incorporated entities and many more addresses, with their own connections to thousands more UK incorporated entities. Albeit, Fixed Rate Finder did not appear to be one of this UK regulated entities.

The address and the connected addresses are business accommodation addresses and are likely to be connected to regulated trust and company service providers/management agents. Thus, is there a regulated business connected to 12 Constance Street?

Better than Fixed

On 3 June 2021, the FCA added yet another name to the Warning List, being Better Rates Limited. Once again the address present upon the Warning List was 12 Constance Street, only in this instance, Better Rates Limited is a company incorporated in the UK on 30 September 2019 and there is a UK resident named as both a current director and the current person with significant control (PSC). Consequently, the FCA are able to further their enquiries and pose questions to this person, or you would hope so.

This may not be so easy as the director/PSC and former director/PSC have provided 12 Constance Street as their place of residence, which is not accurate. Fortunately, the director/PSC is shown as an active director of another corporate entity and for this entity his residential address is shown as a house in Essex. Whereas the former director/PSC is shown to be resident at another business accommodation address, 61 Bridge Street Kingston HR53DJ. This is the same address where Better Rates Limited was originally registered and it is a retail premises for a business called Ghost Mail.

The detailed risk report provided by Kompli Global confirms this entity is not registered with the Information Commissioner’s Office and evidence of registration to pay VAT was not found. These missing pieces of basic corporate data may add to both business risk and even suspicion when undertaking or contemplating business with this entity.

Ghost Mail

So, when you need to hide, who are you going to call? The answer is not ghost busters. 61 Bridge Street has previously featured in a number of money laundering investigations and allegations. There are in excess of 3000 UK incorporated entities that have been or are presently registered at this address, including a number of LLP entities with characteristics that have featured in prior money laundering investigations and allegations.

There are other entities registered at this address with, to say the least, interesting names, such as Pyramid Invest LP. This entity does not feature upon the FCA Warning List, nor is it regulated by the FCA. Perhaps this entity operates in Egypt. Another entity registered is the ironically named, Bans Financial Services Ltd. The SIC Codes present this company as being engaged in professional services, credit granting and a mortgage advice. Bans Financial is neither regulated by the FCA or featured upon the FCA Warning List. Neither is the company registered with the Information Commissioner’s Office, which begs the question as to how customers’ personal data is protected.

The director and PSC of this company has the same name as a man who is connected to a mortgage advisory business, which is regulated by the FCA, but it’s not this one. As neither Bans Financial Services Ltd or Pyramid Invest Ltd have websites, the nature of each company’s business is unknown.

Out of the Darkes

One of the LLP entities registered at 61 Bridge Street was previously registered at suite 2B 175, Darkes Lane, Potters Bar, the now infamous address referenced within the FinCEN Leaks and described by US authorities as one of the highest risk money laundering addresses in the world. Thus, those behind this entity move from the Darkes Lane to Ghost Mail. Some will ponder, was this by accident or design? There are connections as well as prior allegations of fraud and money laundering connected to these addresses, but there are many more addresses and over the coming weeks we will introduce them to you.

Better data

The rates are not better, which ever way you look at it, but the data is improving and in turn this strengthens the hand of the anti-financial crime professional. Watch this space for more data and don’t always take UK corporate data at face value.