German-British Chamber of Industry & Commerce - GBCIC.
Compliance Assessment
German-British Chamber of Industry & Commerce - GBCIC: Assessment: Accounts and directors’ multiple identities.
The easiest way to notify Companies House of an issue with a record in Companies House, is to click the "Is there anything wrong with this page?" which is available to all screen of records in Companies House. Whilst reviewing the records for German-British Chamber of Industry & Commerce (GBCIC) I made the following complaints, in this order (I have included the communication reference number that was provided in the acknowledgement from Companies House):
1) "Ref: COH956339X
CHS page: https://find-and-update.company-information.service.gov.uk/company/01016261/filing-history
Issue:
The audit report in the Accounts for a small company made up to 31 December 2023 for German-British Chamber of Commerce is not signed by the auditor, Haysmacintyre LLP. This breaches the Companies Act, invalidating the audit and raising concerns about the reliability and compliance." (See image below: Unsigned Audit report in the Accounts made up to 31 December 2023 presented by German-British Chamber of Commerce & Industry.)
2) "Ref: COH956408X
CHS page: https://find-and-update.company-information.service.gov.uk/search?q=Christopher Howard Putt
Issue:
Christopher Howard Putt, director of German -British Chamber of Industry and Commerce, has three unique identifiers. This is a breach of the intention of s1082, compromising audits and KYC. GBCIC recent accounts are not signed by Auditor Haysmacintyre LLP."
3) "Ref: COH957223X
CHS page: https://find-and-update.company-information.service.gov.uk/officers/ZYtxqVYRxSrAS8DGFxYIjUUzqbw/appointments
Issue:
This is the fourth unique identifier for Christopher Howard Putt of German-British Chamber of Industry and Commerce (GBCIC) of which the most recent audit report is unsigned. Anomalies in his other IDs indicate high risk for money laundering and terrorism financing. Third S1082 breach."
4) "Ref: COH956483X
CHS page: https://find-and-update.company-information.service.gov.uk/search?q=Elliott Singer
Issue:
Elliott Singer has 2 unique identities (first 2 search results). His interests in the 2nd ID is concealed. Why? He is director of E4 Healthcare which is associated to 1/5 IDs of Christopher Howard Putt of German-British CIC, whose accounts are invalid as not signed by auditor Haysmacintyre LLP. MLTF"
5) “Ref: COH956421X
CHS page: https://find-and-update.company-information.service.gov.uk/company/07248898
Issue:
This company associated to Mr Putt, who has 3 unique identities one associated to German-Brit CIC (unsigned audit statement) is dissolved without submitting final accounts. High risk bank accounts are still operating."
6) "Ref: COH957280X
CHS page: https://find-and-update.company-information.service.gov.uk/search?q=Mary Denise Conroy
Issue:
Mart Conroy has 2 Unique IDs breaching section 1082 and compromising audits and KYC checks. She is director of E4 Healthcare which is associated via Christopher Putt to German-British CIC, whose most recent accounts are unsigned by auditor in breach CA2006. High risk MLTF. Recommend forensic audit."
7) "Ref: COH957288X
CHS page: https://find-and-update.company-information.service.gov.uk/search?q=Shahid Dadabhoy
Issue:
Shahid Dadabhoy has 3 unique IDs, breach section 1082. He is director of E4 Healthcare which is associated to German-British CIC. I am highlighting an interlocked directorate which is normally concealed by use of multiple IDs and compromised audits by Haysmacintyre who did not sign GBCIC audit report"
8) Ref: COH957311X
CHS page: https://find-and-update.company-information.service.gov.uk/search?q=Heiner Boehmer
Issue:
Heiner BOEHMER, another director of German-British chamber of Industry and Commerce (GBCIC), had 2 unique identities. Breaches S1082 concealing interests from audits and KYC. His other ID is to a company that dissolved with 4yrs accounts overdue. Risk that bank accounts operating for ML/TF"
Response from Companies House to my complaint 2).
“Dear Alison Wright,
GERMAN-BRITISH CHAMBER OF INDUSTRY & COMMERCE – 01016261
Thank you for your email regarding the above-named company.
I note your comments regarding the accounts submitted for the period ending 31 December 2023. The auditor’s signature is not required on the auditor’s report on the financial statements filed with Companies House. We only require the senior auditor’s name and the firm to be printed clearly on the report.
Your email has been passed to another team to answer your statement regarding Mr Christopher Howard Putt having three unique identifiers.
Yours sincerely,
Technical Complaints Team
Companies House | Crown Way | Cardiff | CF14 3UZ”.
9) My response:
“Subject: Re: RE: Your Communication with Companies House, Ref: COH956408X
Date: 11/09/24 15:09
Dear Technical complaints team, please will you provide me with evidence that "The auditor’s signature is not required on the auditor’s report on the financial statements filed with Companies House". I have never seen this exception. Indeed the Companies Act requires that the accounts are signed by a real person who can be held accountable. Sincerely, Alison Wright.”
Companies House response:
“RE: Your Communication with Companies House, Ref: COH956408X
11/09/2024 16:23
Dear Alison Wright,
GERMAN-BRITISH CHAMBER OF INDUSTRY & COMMERCE – 01016261
Thank you for your email.
Section 414 of the Companies Act 2006 states, ‘A company's annual accounts must be approved by the board of directors and signed on behalf of the board by a director of the company.’ The accounts for the above-named company have been signed and approved by the board of directors by Ms P E Godfrey and Dr U Hoppe.
As the company filed small company accounts, the auditors report only needs the printed name of the registered auditor. This information can be found in parts 15 and 16 of the Companies Act 2006, however, here is our link to the Companies House website which also includes the information: Companies House accounts guidance - GOV.UK (www.gov.uk). The information you require is under 9.5 Contents of small company accounts.
I hope this information is of some help to you.
Yours sincerely,
Technical Complaints Team
Companies House | Crown Way | Cardiff | CF14 3UZ”
My response:
“Dear Companies House Technical Complaints Team,
Thank you for your responses regarding the German-British Chamber of Industry & Commerce (GBCIC) and related matters. I must strongly disagree with several of your assertions and highlight critical issues that require immediate attention:
i) Audit Report Signatures:
Your statement that "the auditors report only needs the printed name of the registered auditor" for small company accounts is incorrect and constitutes misinformation. This is not merely a potential breach, but a certain breach of the Companies Act 2006. When an audit has been conducted, the Companies Act 2006 and auditing standards unequivocally require that the audit report be signed by the auditor, regardless of the company's size. An unsigned audit report for a company that has undergone an audit is a clear violation of both professional standards and the Companies Act 2006.
Your attempt to justify the lack of a signature on the audit report is deeply concerning and may be evidence of collusion or a serious misunderstanding of the law. This misinformation from Companies House is itself a breach of the Economic Crime and Corporate Transparency Act 2023, which emphasizes the importance of accurate information in corporate filings.
ii) Multiple Unique Identifiers:
The situation with Christopher Howard Putt and other individuals holding multiple unique identifiers in Companies House records directly contravenes Section 1082 of the Companies Act 2006. This section mandates the use of unique identifiers to ensure consistent identification across all company records and dealings with the registrar. The term "unique identifier" inherently implies that each individual should have only one identifier.
Multiple identities for a single individual:
a) Conceal interests held under other identities, obstructing proper audit and Know Your Customer (KYC) checks.
b) Breach Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 by hindering due diligence.
c) Present a significant cybersecurity risk, undermining the Zero-trust principles of modern cybersecurity.
Interconnected
Issues:
The combination of unsigned audit reports and multiple unique identifiers for directors raises grave concerns about the integrity of corporate records and the potential for financial misconduct. This situation affects not only GBCIC but also other connected companies like E4 Healthcare.
I urge Companies House to take immediate action:
1. Rectify the misinformation provided about audit report signatures and ensure all audit reports, including that of GBCIC, are properly signed when audits have been conducted.
2. Consolidate multiple identifiers for individuals into single unique identifiers, as mandated by Section 1082.
3. Review and strengthen procedures to prevent the creation of multiple identifiers for individuals in the future.
4. Investigate the potential risks associated with the interconnected directorships and companies identified in my previous communications.
5. Conduct an internal review to determine how such misinformation was disseminated and take steps to prevent future occurrences.
6. Introduce a new field in company records referencing previous arrangements when deduplication occurs. This is crucial for transparency and potential future fraud investigations, as currently there is no warning on a record that has been deduplicated to alert viewers that an individual previously held multiple identities.
7. Recommend updates to International Standards for Auditing guidance to highlight the potential for multiple identities. Emphasize that it is the duty of the auditor to take reasonable steps to detect these for the individual and their related parties, and include them in their reports as they are part of the individual's linked directorate.
8. Broadcast a public warning across all media, targeting accountants, auditors, those who undertake KYC checks, and cybersecurity systems, about the common problem of multiple unique identifiers. Emphasize the need to take steps to mitigate this issue, as it facilitates fraud, money laundering, terrorism financing, and human trafficking by compromising the systems established to prevent these crimes.
9. Implement a system to track and report on deduplication efforts, providing transparency on the scale of the issue and progress in addressing it.
These recommendations aim to address the immediate issues, improve transparency, enhance auditing standards, and raise public awareness of the serious risks associated with multiple unique identifiers in corporate records.
These issues demand urgent attention to maintain the integrity of corporate records, ensure compliance with relevant legislation, and mitigate risks of money laundering, terrorism financing and human trafficking. The provision of misinformation by Companies House is particularly alarming and requires a thorough investigation.
Sincerely,
Alison Wright”
Brilliant as ever Alison.