2/ Moncef Slaoui active director of International Aids Vaccine Initiative Inc, Vicebio Limited, Altesa Biosciences Inc and Zephyr AI Inc.
Use of "Monsif" to register past directorships of GSK PLC, Letsbeatsepsis and Galvani Bioelectronics Limited. Also, "Mouncif Slaoui" of World Franchise Associates Limited. Breaches of Section 1082.
Building on this report:
Moncef Slaoui, born July 1959, is an active director of International Aids Vaccine Initiative Inc, Vicebio Limited, Altesa Biosciences Inc and Zephyr AI Inc. He is a resigned director of DC Europa Limited, which is in liquidation with accounts overdue.
Moncef Slaoui used the spelling "Moncif" to register past directorships of GSK PLC, Letsbeatsepsis and Galvani Bioelectronics Limited. He was appointed as a director of World Franchise Associates Limited as "Mouncif Slaoui".
Companies House unique identifiers (CHID)
This section presents a comprehensive comparison of Moncef Slaoui's unique identifiers in Companies House records against the corresponding officer search records in OpenCorporates. This analysis is crucial for several reasons:
Data Integrity: OpenCorporates is widely used as a primary source for Know Your Customer (KYC) checks, due diligence processes, and audit software.
Compliance Risks: Discrepancies between official records and aggregated databases can lead to significant compliance oversights and regulatory risks.
Identity Verification Challenges: Multiple identifiers and inconsistencies complicate the task of accurately tracking an individual's corporate affiliations.
Audit Trail Concerns: Variations in recorded information can obscure the true extent of an individual's corporate involvement, potentially hindering effective audits.
Regulatory Implications: Inconsistencies across databases may indicate broader issues in corporate governance and regulatory compliance.
By examining these discrepancies, we aim to highlight the critical importance of cross-referencing multiple authoritative sources in corporate due diligence and the potential pitfalls of relying solely on aggregated databases for compliance purposes.
CHID1: Moncef SLAOUI (MONCEF SLAOUI in OpenCorporates) Born July 1959 Nationality Moroccan
Active Director at INTERNATIONAL AIDS VACCINE INITIATIVE, INC. since 5 December 2014 (not since 24 October 2007 as in OpenCorporates officer search record)
CHID2: Moncef SLAOUI (MONCEF SLAOUI in OpenCorporates) Born July 1959 Nationality American
Active Director at VICEBIO LIMITED since 7 October 2024 (OpenCorporates’ officer search record incorrectly states 14 Sept 2018)
Resigned Director at DC EUROPA LIMITED in Liquidation with Accounts overdue Appointed on 20 December 2017 Resigned on 27 March 2021, (not appointed 20 Jun 2017 without a resignation date as in OpenCorporates officer search record)
CHID3: Moncef SLAOUI (MONCEF SLAOUI in OpenCorporates) Born July 1959 Nationality Belgian
Resigned Director at JENNER VACCINE FOUNDATION Appointed on 6 February 2002 Resigned on 24 June 2003 (OpenCorporates officer search record incorrectly provides appointment on 14 Jul 1995 and no resignation date)
CHID4: Moncef SLAOUI (MONCEF SLAOUI in OpenCorporates) Born September 1960 Nationality Morrocan
Director at HEALTHCARE EXCELLENCE LTD Dissolved on 29 September 2020 No accounts submitted Appointed on 23 July 2018 Slaoui was a director until dissolution, rather than resigning. (OpenCorporates incorrectly presents a resignation date “23 Jul 2018-29 Sep 2020” in officer search record whereas he did not resign before dissolution)
CHID5: Mohamed Monsif SLAOUI (MOHAMED MONSIF SLAOUI in OpenCorporates) Born July 1959 Nationality British
Resigned Director LETSBEATSEPSIS Appointed on 19 May 2014 Resigned on 10 February 2019 (Recorded in OpenCorporates as “19 May 2014-21 May 2019” in officer search record)
CHID6: Dr Mohamed Monsif SLAOUI (MOHAMED MONSIF SLAOU in OpenCorporates) Born July 1959 Nationality Belgian
GALVANI BIOELECTRONICS LIMITED (09984862) Resigned Director Appointed on 16 November 2016 Resigned on 24 March 2021 (Appointment incorrectly given as 3 February 2016 and his resignation is excluded in OpenCorporates officer search record)
GSK PLC (03888792) Resigned Director Appointed on 17 May 2006 Resigned on 31 March 2017 (Appointment incorrectly given as 6 Dec 1999 and his resignation is excluded in OpenCorporates officer search record)
CHID7: Mouncif SLAOUI (MOUNCIF SLAOUI in OpenCorprates) Born September 1960 Nationality Moroccan
Resigned Director WORLD FRANCHISE ASSOCIATES LIMITED (06203737) Appointed on 4 April 2007 Resigned on 4 May 2007 (OpenCorporates officer search record “4 Apr 2007-”, the resignation date is omitted).
Data Discrepancy and Potential Intermediate Records:
A systematic difference is observed between the OpenCorporates records and the original Companies House data for Moncef Slaoui's appointments. OpenCorporates consistently presents the name in all capital letters (e.g., "MONCEF SLAOUI" instead of "Moncef SLAOUI"), which differs from the Companies House format. This capitalization discrepancy, coupled with the numerous incorrect appointment and resignation dates in the OpenCorporates records, strongly suggests the existence of an intermediate data processing step or database.
This intermediate stage appears to be introducing errors and inconsistencies, particularly in the crucial dates of appointments and resignations. The uniformity of these discrepancies across multiple records indicates a systemic issue rather than random errors. This raises significant concerns about the data integrity and the reliability of information presented by OpenCorporates, especially for compliance and due diligence purposes.
The presence of these apparent 'replacement records' in OpenCorporates, with their consistent formatting changes and date inaccuracies, warrants further investigation. It suggests a potential risk of data obfuscation, whether intentional or due to flawed data management processes. This situation underscores the critical importance of cross-referencing corporate data with primary sources and highlights the risks of relying solely on aggregated databases for critical compliance and legal purposes.
United States registrations
USID1: DR MONCEF SLAOUI Active Director at Altesa BioSciences, Inc. (Virginia, since 14 June 2023)
USID2: DR. MONCEF MDr. SLAOUI Active Director at Altesa BioSciences, Inc. (Florida, since 13 September 2023)
USID3: Moncef Slaoui Active Director at Altesa BioSciences, Inc. (Texas, since 13 Jun 2023)
USID4: Moncef Slaoui Active Director at Zephyr AI, Inc. (Virginia, since 9 August 2023)
USID5: Slaoui, Moncef Active Governor at Zephyr AI, Inc. (District of Columbia, since 8 August 2023)
USID6: Slaoui, Moncef Active ExecutingOfficer (sic) at Zephyr AI, Inc. (District of Columbia, since 8 August 2023)
USID7: DR. MONCEF M SLAOUI Director at ALTESA BIOSCIENCES, INC. (Florida, 13 September 2023)
USID 8: DR. MONCEF SLAOUI Director at ALTESA BIOSCIENCES, INC. (Florida, 13 September 2023 )
Based on the information provided about Moncef Slaoui's corporate identities and appointments, several potential breaches of UK and US legislation can be identified:
Companies Act 2006:
a) Applying Section 1082 of the Companies Act 2006 to Moncef Slaoui's case:
Fundamental Breach of Unique Identifier Principle:
Section 1082(1) provides for the use of unique identifiers to identify each person who is a director of a company. Slaoui's multiple identities (at least seven distinct identifiers) fundamentally violate this principle.Circumvention of Regulatory Intent:
By using multiple identifiers, Slaoui has effectively circumvented the intent of Section 1082, which aims to ensure clear, unambiguous identification of individuals in corporate records.Compromise of Register Integrity:
Section 1082(2)(d) empowers the registrar to address cases where a person appears to have more than one unique identifier. The existence of multiple identifiers for Slaoui compromises the integrity of the register and hinders the registrar's ability to maintain accurate records.Obstruction of Due Diligence:
The multiple identities severely impede the ability to conduct proper due diligence, KYC checks, and audit processes, which rely on the assumption of a single unique identifier per individual.Potential for Concealment:
The use of various name spellings, birth dates, and nationalities across different identifiers suggests a deliberate attempt to obscure a comprehensive view of Slaoui's corporate involvements.Undermining of Anti-Money Laundering Efforts:
By maintaining multiple identities, Slaoui has potentially created a mechanism to evade detection in anti-money laundering, counter-terrorism financing, and anti-trafficking checks, which rely on clear, singular identities.Violation of Zero Trust Principles:
The multiple identities directly contravene zero trust principles in cybersecurity and corporate governance, which require users to have unique, verifiable identities.Compromise of Audit Integrity:
The existence of multiple identifiers undermines the fundamental basis of audit protocols, which assume a one-to-one relationship between individuals and their corporate identities.Evasion of Regulatory Oversight:
By using different identifiers across various appointments, Slaoui has potentially evaded proper regulatory oversight that would typically be triggered by a single, comprehensive corporate profile.Failure of Corporate Responsibility:
As a high-profile corporate figure, Slaoui's actions represent a significant failure in corporate responsibility and transparency, directly contradicting the spirit and letter of Section 1082.
In conclusion, Moncef Slaoui's use of multiple identifiers represents a severe and systemic breach of Section 1082. This situation goes beyond mere administrative oversight and suggests a deliberate circumvention of regulatory mechanisms designed to ensure corporate transparency and accountability. The implications of these multiple identities are far-reaching, potentially compromising the integrity of corporate registers, audit processes, and anti-financial crime measures. This case underscores the critical importance of enforcing single, unique identifiers for corporate officers and highlights the need for more robust systems to detect and prevent such circumventions of regulatory intent.
b) Section 441 - Duty to file accounts with the registrar:
Failure to submit accounts for HEALTHCARE EXCELLENCE LTD before dissolution.
c) Section 167 - Duty to notify registrar of changes in director's details:
Inconsistent personal information (nationality, country of residence) across appointments may breach this requirement. Egregious, as it's not just a matter of failing to update details but potentially deliberately providing conflicting information
d) Section 162 - Register of directors:
The use of multiple identities may lead to incomplete or inaccurate director registers in companies.
e) Section 170 - Scope and nature of general duties:
The multiple appointments and potential conflicts of interest may breach the general duties of directors.
f) Section 172 - Duty to promote the success of the company:
Holding multiple directorships with potentially conflicting interests could violate this duty.
Fraud Act 2006:
a) Section 2 - Fraud by false representation:
Providing false or misleading information about personal details or qualifications could potentially fall under this section. The use of multiple identities with varying personal details could be seen as a systematic attempt to deceive.
b) Section 3 - Fraud by failing to disclose information:
Not disclosing all relevant directorships or potential conflicts of interest might constitute fraud by omission.
Financial Services and Markets Act 2000:
a) Section 19 - The general prohibition:
If any of the companies involved are engaged in regulated activities, the use of multiple identities could potentially violate regulations regarding approved persons.
Proceeds of Crime Act 2002:
a) Section 327-329 - Money laundering offences:
The complex web of appointments and identities could potentially be used to conceal the source of funds or assets.
Bribery Act 2010:
a) Section 7 - Failure of commercial organisations to prevent bribery:
The multiple roles across different companies and jurisdictions could potentially create opportunities for bribery that companies failed to prevent. the multiple identities might also make it more difficult for companies to perform adequate due diligence, potentially exposing them to liability under the Act.
Modern Slavery Act 2015:
a) Section 54 - Transparency in supply chains:
For larger companies, the use of multiple identities could potentially obscure true control and responsibility for ensuring transparency in supply chains.
It's important to note that these are potential breaches based on the information provided. A thorough investigation would be required to determine if actual violations have occurred. The complexity of Slaoui's corporate involvements and the inconsistencies in his reported personal information raise significant compliance concerns across multiple areas of UK legislation.
Action plan
Given the significant compliance issues and potential legal violations identified in Moncef Slaoui's corporate appointments, several steps should be taken to report these findings:
Report to Companies House:
Submit a detailed report to Companies House, highlighting the multiple identities and inconsistencies in Slaoui's records.
Request an investigation under Section 1082 of the Companies Act 2006 regarding the use of multiple unique identifiers.
Financial Conduct Authority (FCA):
Report the findings to the FCA, especially given Slaoui's involvement in regulated industries.
Highlight potential violations of the Financial Services and Markets Act 2000.
National Crime Agency (NCA):
Submit a Suspicious Activity Report (SAR) to the NCA's UK Financial Intelligence Unit.
Emphasize potential money laundering concerns under the Proceeds of Crime Act 2002.
Serious Fraud Office (SFO):
Report the case to the SFO, focusing on potential violations of the Fraud Act 2006 and Bribery Act 2010.
HM Revenue & Customs (HMRC):
Notify HMRC of the multiple identities and inconsistent residency claims, which may have tax implications.
Information Commissioner's Office (ICO):
Report potential data protection violations due to inconsistent personal information across registrations.
Board of Directors:
Inform the boards of companies where Slaoui currently holds positions about these findings.
Professional Bodies:
If Slaoui is a member of any professional bodies (e.g., medical, scientific), report the findings to them.
US Securities and Exchange Commission (SEC):
Given Slaoui's involvement in US companies, report findings to the SEC, especially if any of these companies are publicly traded.
Legal Counsel:
Consult with a corporate law specialist to ensure all legal obligations for reporting are met.
Whistleblowing Channels:
If you're an employee of any involved companies, consider using internal whistleblowing procedures.
Media and Investigative Journalists:
Consider sharing findings with reputable investigative journalism outlets, especially those specialising in corporate governance and financial crime.
Remember, the goal is to alert the appropriate authorities to potential legal and regulatory violations, allowing them to conduct thorough investigations and take appropriate action.
If you are able to assist with this action plan, please contact me.
Responding to my initial findings, Hedley Rees prepared this note providing an overview of some of the companies involved:
Time allowing, I will check each of the company websites’ for meeting Trading Disclosure Standards and whether interests are properly disclosed.
Stunning work!