HMRC and Moneyfarm Chair, Dame Jayne-Anne Gadhia, has twelve identities in Companies House. Part 2.
Gadhia fails to correctly declare active directorships of: UniCredit SPA (as Ghadia), MFM Investment and MFM Holding, Usnoop/Vanquis Bank, Jagash and Gadhiagroup. Evidence of fraud.
During my due diligence assessment of the HM Revenue and Customs senior leadership team, of those whose interests I could locate in Companies House, because their names stand out, Dame Jayne-Anne Gadhia, the Chair of the HMRC Board, has the most transgressions and is the subject of this report.
I published my findings on HMRC on 3 December 2023, available here: Due Diligence on HMRC - by Alison Wright (substack.com). Below, is the conclusion, reproduced:
Conclusion from due diligence report, 3 December 2023, regarding Dame Jayne-Anne Gadhia
Dame Jayne-Anne has established twelve identities in Companies House, one using a misspelling of her name, and she has failed to disclose all of the interests held in each of these identities [See annex A]. Multiple identities conceal interests. If the owner fails to disclose these interests this is evidence that the identities were created with the intention of concealing interests and this is evidence of fraud by false representation (Section 2 Fraud Act 2006). Failing to register her interests is evidence of fraud by failing to disclose information (Section 3 Fraud Act 2006).
Of particular concern is that she has five active directorships that she has failed to disclose MFM INVESTMENT LTD, MFM HOLDING LTD, JAGASH LTD, GADHIAGROUP LIMITED and UNICREDIT S.P.A., (the latter) was registered with the spelling “Ghadia” instead of “Gadhia”.
She incorrectly registered her company Usnoop Limited as “Snoop” in her biography, which renders the records of Usnoop difficult to locate. This is evidence of obfuscation.
I allege that there is sufficient evidence to warrant a police investigation into the conduct of Dame Jane-Anne relating to her registration of multiple identities and her failure to declare past and current interests, her obfuscation around Usnoop Limited, and any conflicts, or mutual, interests arising.
Dame Jayne-Anne Gadhia / Ghadia also requires further investigation for fraud by [registering eleven] false representation[s], [one] using a different spelling of her name, fraud by failing to disclose information in her biography, and fraud by abuse of position.
This conclusion remains valid, with the exception of Usnoop Ltd, which is declared in Dame Jayne-Anne’s Register of Interest.
I did make some “non-match errors” regarding her interests, which I will explore herein, because they are illustrative of how serious organised crime can be committed by directors. In my initial due diligence I had failed to locate Dame Jayne-Anne’s Register of Interest and had analysed her biography, only, for the purposes of due diligence. Hence, I missed her declaration of Usnoop Ltd in her register.
Dame Jayne-Anne’s Register of Interests is located on the Government website here: HMRC Register of Interests 2023 - GOV.UK. Apologies for not including this in the last report, which was based on her biography only and is located here: Dame Jayne-Anne Gadhia - GOV.UK. See images 1 and 2, for her Register of Interest and her biography.
Comparison of declaration of interests in Dame Jayne-Anne’s Register of Interests(RoI) with her Biography (Bio), see images above, with her interests registered in Companies House.
Findings:
Dame Jayne-Anne declares that she is the Chair of Moneyfarm in both her RoI and her Bio. This is a material misstatement because she is supposed to declare the registered name which is MFM Investment Ltd. She failed to declare MFM Holding Ltd.
Her Bio declares “special advisor” at UniCredit whereas her RoI declares she is a Non-Executive director of UniCredit. There is a material difference in the two roles she declares. She inaccurately declares UniCredit instead of Unicredit SPA.
Her Bio declares “special advisor” at Vanquis Bank. She does not declare her senior advisor role at Vanquis Bank in her RoI. This is a material difference.
Her Bio declares that her fintech company. “Snoop”, “was sold to Vanquis Bank in July 2023”. Her RoI declares that she is the executive chair of Usnoop Limited. There is a material difference between these two statements. A search on Snoop in Companies House does not locate the registration of Usnoop.
Her Bio declares she is Senior Independent Director at the Tate, her RoI expands on this with “Chair of Audit Committee and Finance and Operations Committee”.
Conclusion:
Moneyfarm. Dame Jayne-Anne Gadhia’s Register of Interests 2023 and her current biography both declare “Moneyfarm”. Since there is no corresponding registration in Companies House, with this name, I made a non-match error since I was not aware that “Moneyfarm” is the copyright name of MFM investment Ltd. I concluded that I couldn’t find the registration for “Moneyfarm”, and that she hadn’t declared MFM investment Ltd, when these are the same entity.
Her declaration in her biography and register of interests is misleading, it should read “Chair of MFM Investment Ltd know as “Moneyfarm””. Simply declaring “Moneyfarm” is a material misstatement and omits declaring her related interest, MFM Holding Ltd. “Moneyfarm” is explored in more detail in this report.
UniCredit. Dame Jayne-Anne’s biography declares that she is “special advisor” at UniCredit whereas her Register of Interest declares that she is a Non-Executive director of UniCredit. Dame Jayne-Anne fails to declare that she is a Non-executive director of UniCredit SPA in her biography. Her biography is misleading, as it omits her directorship and both her biography and Register of Interests fail to disclose the correct name of UniCredit SPA. These are two material misstatements. Her declaration in the Register of Interests is inaccurate since the company is called UniCredit SPA, not “UniCredit”.
Vanquis Bank. Dame Jayne-Anne’s biography declares that she is “special advisor” at Vanquis Bank. She does not declare her senior advisor role at Vanquis Bank in her Register of Interest. This requires further exploration and will be the subject of a later report.
Snoop, Usnoop. Dame Jayne-Anne’s Biography declares that her fintech company. “Snoop”, “was sold to Vanquis Bank in July 2023”. Her RoI declares that she is still the executive chair of Usnoop Limited, which is supported by the record in Companies House. Dame Jayne-Anne’s biography and Register of Interests appear to present conflicting narratives. This will be the subject of a latter report.
The Tate. Dame Jayne-Anne’s Biography declares she is Senior Independent Director at the Tate, her Register of Interest expands on this with “Chair of Audit Committee and Finance and Operations Committee”. This does not appear to be a material difference, just additional information. This will be the subject of a latter report.
This report will look further at UniCredit SPA and Moneyfarm. Later reports, time allowing, will cover the Tate, Vanquis Bank, and active interests Usnoop, Jagash and Gadhiagroup.
1. UniCredit
Concealment of directorship of UniCredit S.P.A. and fraud.
In my report dated 3 December 2023, I wrote “No appointments in Companies House are related to [Dame Jayne-Anne’s disclosure in her HMRC biography]:
Dame Jayne-Anne is the Lead Non-Executive at HM Revenue and Customs (HMRC), chairs the HMRC Board, and is Chair of Moneyfarm, Senior Independent Director at the Tate and a Senior Adviser both at UniCredit and at Vanquis Bank.”
I made the statement, above, before I had located Dame Jayne-Anne’s identity with an alternative spelling of her surname, Jayne-Anne GHADIA. The interest was concealed because she had used a different spelling of her surname. In this identity she is appointed as director of UniCredit S.P.A., since 15 April 2021, using an Italian correspondence address. Having located this identity I forgot to revisit my statement, copied above.
Since she is a Director of UniCredit, S.P.A., using the spelling of her name as Ghadia instead of Gadhia, Dame Jayne-Anne’s disclosure as a “Senior Adviser”, in her biography, is a material misstatement. She fails to disclose that she is a director of UniCredit SPA. Because she registered this interest in Companies House with a misspelling of her name, as Ghadia, this interest is concealed from her other interests, and unlikely to be located during due diligence assessments.
In her Register of Interests, however, Dame Jayne-Anne discloses that she is Non-Executive Director of UniCredit. This declaration is materially different from her biography since it includes her directorship. However, she incorrectly refers to this as UniCredit, rather than UniCredit SPA. Therefore, whilst her Register of Interests is a more accurate disclosure, because it includes her directorship of UniCredit, it is still incorrect as it uses the incomplete name of the firm, which is UniCredit SPA.
An example of why it is important that the correct name of an interest is disclosed.
A search in Companies House on “Unicredit” returns 28 companies that use, or have used, this name, see image 3.
At present, her disclosure could potentially enable an incorrect, or fraudulent transaction, relating to: any of the “Unicredit” companies that are active and, or, dissolved companies with bank accounts still active e.g. Unicredit Bank AG and Unicredit Limited. Note that Unicredit SPA was established as an overseas company and a branch on 1 May 1972, providing two company registration numbers for the same name, which represents an opportunity to run two sets of accounts. Serious organised crime is often committed by directors who switch contracts between similarly named companies to prevent accountability and avoid taxes.
The purpose of deliberately registering multiple identities in Companies House is to conceal interests. So, when a person has created multiple identities and has failed to declare all their interests correctly, this is evidence that the identity was established deliberately and with intent to conceal the interest.
To create multiple identities, all that is needed is one character difference in the name, date of birth or usual residential address. In this case Dame Jane-Anne varied her name and provided a residential address in Italy for the purposes of concealing her directorship of UniCredit SPA.
I allege that the identity, Jayne-Anne GHADIA, meets the definition of a “false representation”, since she used an incorrect spelling of her name, and that by failing to disclose that she is a director of UniCredit SPA, in her Biography and Register of Interest, she has failed to disclose information. In doing so, I allege that she has met the definitions of fraud in the Fraud Act 2006:
Fraud by false representation (Section 2)
Fraud by failing to disclose information (Section 3).
The gain of the first additional identity caused a loss of integrity of all the previous audits associated to Dame Jayne-Anne.
Further investigation is necessary
Additional searches are necessary, within the accounts, to check that they meet the minimum standards and to test whether: the correct directors are listed, that the accounts are signed by a real director and a real auditor, and, that interests are declared correctly. Additionally, within Companies House, to check whether any of the other directors of UniCredit SPA have multiple identities, and if they do, to test these interests for compliant accounts and conflicts of interest.
Time allowing, I will revisit this, to look at the accounts, the directors and the persons with significant control, and to test whether these officers have multiple identities, as this will describe which companies and directors should be included within an audit of the linked directorate of UniCredit S.P.A..
2. Moneyfarm
Referring back to my statement “No appointments in Companies House are related to [Dame Jayne-Anne’s] disclosure in her HMRC biography:
Dame Jayne-Anne is […] Chair of Moneyfarm”
From the Moneyfarm website we learn that “Moneyfarm” is the copyright name of MFM Investment Ltd
If I had visited the website of “Moneyfarm” and scrolled to the bottom of the webpage, see image 4, then, I would have realised that I’d been prompted to make a non-match error in my analysis by Dame Jayne-Anne’s disclosure of “Moneyfarm” and not the registered name of this interest, MFM Investment Ltd.
The company website displays, on the left hand side of the screen, that “Moneyfarm” is the copyright name of MFM Investment Ltd. Registered office: 90-92 Pentonville Road, London N1 9HS. Registered in England and Wales Company No. 9088155.
Using Companies House and Dame Jayne-Anne’s biography, only, I made a non-match error, between “Moneyfarm” and MFM Investment Ltd, just as a computer would. It required viewing the company website to be able to see that Dame Jayne-Anne had declared the copyright name “Moneyfarm” and not the registered name, MFM Investment Ltd. Whilst a human can deduce this, to audit software this would not be obvious. This is an example of why it is important that individuals declare the registered names of their interests, as they have a duty to do so.
“The Moneyfarm story” from the “Moneyfarm” / MFM Investment Ltd website
We are a pan-European digital wealth manager with over 125,000 active investors and more than £3.5 billion invested on our platform.
We’re backed by Allianz Global Investors, M&G, Cabot Square Capital, United Ventures, and Poste Italiane.
Mar 2011 Moneyfarm is born
Nov 2015 Series A funding with Cabot Square Capital and United Ventures
Feb 2016 We launch in the UK
Sep 2016 Allianz X invests to help us scale
Jul 2018 Moneyfarm is voted UK’s ‘Best Online Direct to Consumer Investment Platform’ in the YourMoney.co.uk awards and “Innovation of the Year” at the British Bank Awards
Aug 2019 Our private pension wins UK’s ‘Best Direct SIPP 2019’ in the YourMoney.co.uk awards
Dec 2019 We partner with Poste Italiane on a market-defining investment product Postefuturo
May 2020 We reach £1 billion of assets under management
Aug 2020 Now serving over 50,000 active investors
May 2021 Nominated “Best for Digital ISA and Customer Service” By Boring Money
Aug 2021 We launch our Socially Responsible proposition
Dec 2021 We reach £2 billion of assets under management
Jan 2022 M&G lead a £44 million funding round for Moneyfarm
Dec 2022 Moneyfarm acquires UK digital pension adviser Profile Pensions
Summary of “Moneyfarm”, sourced from the “Moneyfarm website.
The “about us” page of the website states that “Moneyfarm” was “born” March 2011. In November 2015, it secured funding with Cabot Square Capital and United Venture and launched in the UK in February 2016. Allianz X helped it to scale up in September 2016. Between 2017 and 2019 it won awards at the British Bank Awards and from YourMoney.co.uk. It partnered with Poste Italiane on an investment product, Postefuturo, in December 2019. By May 2020 it reached £1 billion of assets under management, serving over 50,000 active investors in August 2020. It launched its Socially Responsible proposition in August 2021 and reached £2 billion of assets under management by December 2021. In January 2022, M&G lead a £44 million funding round for “Moneyfarm” and in December 2022 “Moneyfarm” acquired UK digital pension adviser, Profile Pensions.
Where “Moneyarm” was first registered during March 2011, is omitted from the website biography.
Next, the registration records for MFM Investment Ltd in Companies House and the Financial Services Register will be retrieved and compared to the information “Moneyfarm” provides on its website and in its accounts.
From Companies House: MFM Investment Ltd, a subsidiary of MFM Holding Ltd
Retrieving the record of MFM Investment Ltd from Companies House, returns the following information:
MFM INVESTMENT LTD Company number 09088155 Registered office address 90-92 Pentonville Road, London, United Kingdom, N1 9HS Company status Active Company type Private limited Company Incorporated on 16 June 2014 Accounts Next accounts made up to 31 December 2023 due by 30 September 2024 Last accounts made up to 31 December 2022 Confirmation statement Next statement date 3 August 2024 due by 17 August 2024 Last statement dated 3 August 2023 Nature of business (SIC) 66300 - Fund management activities
MFM INVESTMENT LTD persons with significant control
1 active person with significant control / 0 active statements
Mfm Holding Ltd ACTIVE Correspondence address 90-92, Pentonville Road, London, England, N1 9HS Notified on 6 April 2016 Registration number 09553255.
I note that the “Moneyfarm “ company website does not include any mention of the controlling party, MFM Holding Ltd. This is a material misstatement and evidence of obfuscation. The overview of this company is copied below from Companies House:
MFM HOLDING LTD overview Registered office address 90-92 Pentonville Road, London, United Kingdom, N1 9HS Company status Active Company type Private limited Company Incorporated on 21 April 2015 Nature of business (SIC) 63990 - Other information service activities not elsewhere classified
Comments on MFM Holding Ltd and its “nature of business” SIC code
MFM Holding Ltd is established with its nature of business given as Standard Industrial Classification (SIC) code 63990, “other information service activities not elsewhere classified”. It was incorporated on 21 April 2015, which is later than the incorporation of MFM Investment Ltd, which was incorporated on 16 June 2014.
The Companies House SIC code tool does not provide further detail on code 63990, with which MFM Holding Ltd registered. The classification detail is available from the United Nations Statistical Division’s (UNSD) website, the UK adds a zero to the corresponding UNSD code:
List of activities classified inside the UK SIC Code 63990:
other information service activities not elsewhere classified, such as:
telephone based information services,
information search services on a contract or fee basis,
news clipping services,
press clipping services, etc.
There are 6 codes for holding companies, see image 5, from the Companies House SIC code tool.
Referring to the Group of companies' accounts for MFM Holding Ltd, made up to 31 December 2022, accessed at MFM HOLDING LTD filing history, the Principal Activities of Moneyfarm Holding Ltd are described, see image 6.
From the accounts, the principal activity of MFM Holding Ltd is described:
Its principal activity is as a holding company with operating subsidiaries offering discretionary investment management, advisory and execution services in the United Kingdom and Italy (collectively “MFM Group” or “the Group” or “Moneyfarm”).
The Group operates in the UK via MFM Investment Ltd (MFM UK) an FCA regulated entity, in Italy via a local branch of MFM UK (the Italian branch or MFM Italy) which is authorised and supervised by the Commissione Nazionale per le Societa e la Borsa (CONSOB) and the Bank of Italy (BOI). There is additionally a registered insurance broking entity, MFM Future SRL (regulated by IVASS).
MFM Holding Ltd describes its activities as those of a financial services holding office, which also operates in Italy. The description corresponds to SIC code 64205, activities of a financial services holding company.
The SIC code that a business is registered with affects the audit protocols that are applied. Because MFM Holding Ltd has registered with SIC 63990, “other information service activities not elsewhere classified”, its business is held to a lesser degree of scrutiny than a financial service head office. MFM Holding Ltd misrepresents its business purpose. That it is held to a lesser standard than other financial services head offices’ and gives it an unfair competitive advantage. The wrong SIC code and audit protocols creates a risk that the public’s best interests are not being served.
I query whether MFM Holding Ltd has correctly registered its business purpose.
Further observations on the “principal activity” of MFM Holdings Ltd, given in the accounts.
1. MFM Italy, supervised by CONSOB and the Bank of Italy, operates in Italy via a local branch of MFM UK.
No company registration records for MFM Italy were located, neither in Companies House, nor OpenCorporates. Since it describes being “a local branch of MFM UK”, it appears that it does not provide separate accounts. This raises the question, how does CONSOB and the Bank of Italy supervise its operations?
2. MFM Future SRL, regulated by IVASS (Italy) is a registered insurance broking entity of MFM Holding Ltd.
The record for MFM Future SRL was located in IVASS and is described below.
MFM Future SRL.
IVASS is the Institute for the Supervision of Insurance, which “is the Italian insurance supervisory authority, an independent authority responsible for supervising and regulating all insurance business in Italy”, for MFM Future SRL. IVASS is located via this link. The record, translated to English, is copied below
MFM FUTURE S.R.L. Registration number : B000637784 Section: B - Broker
Name or company name : MFM FUTURE S.R.L.
Registration Date : October 1, 2019
Registered Office : VIA ANTONIO DA RECANATE N. 1-20124 MILANO (MI)
Type of brokerage activity : Insurance
Responsible for the brokerage activity: DIBENNARDO PALMILENIA Registration Number B000480456
Legal representative : DIBENNARDO PALMILENIA Registration Number B000480456
CEO: DIBENNARDO PALMILENIA Registration Number B000480456
MFM Future SRL, an insurance broker, is registered in the Italian Institute for the Supervision of Insurance. There is one person named as responsible for the brokerage activity, as legal representative and CEO, Dibennardo Palmilenia.
Clicking on the record for DIBENNARDO PALMILENIA, provides his registration details. Selecting “translate to English” provides the registration detail. However, one of the company names changes, in translation. Below is the registration detail in English, with the Italian name added, in square brackets, from the original registration:
Registration number : B000480456 Section: B - Broker
Nominative case: DIBENNARDO PALMILENIA
Registration Date : 19 October 2015
Place of Birth : PALERMO (PA)
Date of birth: June 15, 1985
Type of brokerage activity : Insurance
Operational qualification / Operation : Responsible for the brokerage activity of the soc. NICE INSURANCE BROKERS SRL / [NIZZA INSURANCE BROKERS SRL] Operational
Legal Representative of the company. NICE INSURANCE BROKERS SRL / [NIZZA INSURANCE BROKERS SRL] Operational
Chief Executive Officer of the company. NICE INSURANCE BROKERS SRL / [NIZZA INSURANCE BROKERS SRL] Operational
Responsible for the brokerage activity of the soc. MFM FUTURE S.R.L. /Operational
Legal Representative of the company. MFM FUTURE S.R.L. /Operational
Chief Executive Officer of the company. MFM FUTURE S.R.L. /Operational
Dibennardo Palmilenia is responsible for the brokerage activities, CEO and legal representative of MFM Future S.R.L., also known as Nice Insurance Brokers SRL.
Issue: The name NIZZA Insurance Brokers SRL is presented as NICE Insurance Brokers SRL, in the record that has been translated to English.
This record can be used as proof of identity for transactions in the name of NIZZA Insurance Brokers SRL and NICE Insurance Brokers SRL. Because this record supports transactions in the name Nizza and Nice, there is a risk that this company runs two sets of accounts and, for example, only declare one for tax purposes.
The record for NICE / NIZZA Insurance Brokers SRL was accessed, and translated to English:
NICE INSURANCE BROKERS LTD
Registration number : B000388894 Section: B - Broker
Name or company name : NICE INSURANCE BROKERS LTD
Registration Date : 10 August 2011
Registered Office : VIALE VITTORIO VENETO, 18 - 20124 MILANO (MI)
Type of brokerage activity : Insurance
Responsible for the brokerage activity:
DIBENNARDO PALMILENIA Registration Number B000480456
SICILIAN ALBERTA Registration Number B000533649
ALLIORI DAVIDE GIAN MARIA Registration Number B000675781
Legal representative :
DIBENNARDO PALMILENIA Registration Number B000480456
CEO: DIBENNARDO PALMILENIA Registration Number B000480456
Issue: The record for NIZZA Insurance Brokers SRL, also known as NICE Insurance Brokers SRL, publishes a third name for this company, NICE Insurance Brokers Ltd.
From my understanding of contract law, a company name is a legal name and should never be changed by translation, for auditability and accountability, just as a registration number and registered address must remain consistent.
Since NICE is, in the UK, generally known as the National Institute for Clinical Excellence, other companies with the same name pose a risk of impersonation that needs to be investigated to ‘rule out’, during each audit of this institution. NICE / NIZZA Insurance Brokers S.R.L/ Ltd needs to be added to the auditors “watch list”.
A search for company officers with names matching 'PALMILENIA DIBENNARDO' in OpenCorporates, returns no entries. The accounts were not available to assess.
Conclusion.
The “Moneyfarm” website states that in December 2019 it partnered with “Poste Italiane on a market-defining investment product Postefuturo”. The IVASS record for MFM Future S.R.L. states that it was registered on October 1 2019. I conclude that what the “Moneyfarm” biography should properly include that it established MFM Future S.R.L. and state whether this was related to its partnership with Poste Italiane, on the Postefuturo project.
Financial Conduct Authority record for MFM Investment Ltd provides a notice that “Money Farm” is a “cloned firm” and “part of a scam”.
Referring to the Financial Conduct Authority register, the record relating to MFM Investment Ltd were located in a search of the Financial Services Register. There are 14 companies returned in the search on “MFM”, one of these is MFM Investment Ltd. This record provides the following information:
MFM Investment Ltd Reference number: 629539 Address information 90-92 Pentonville Road London N1 9HS UNITED KINGDOM Website ww.moneyfarm.com Companies House number information 09088155
There is a “Notice” on the MFM Investment Ltd record in the FS Register, which warns:
Clones of this firm
Individuals are using the details of this firm to suggest they work for the genuine firm. We call this a cloned firm and it is typically part of a scam.
To contact the genuine firm you should call the switchboard number listed on the Register - and contact us if it is not provided. Find out more about the clone firm(s):
Money Farm (Clone of FCA Authorised Firm)
Added to the FS Register on 05 May 2023.
The FCA, since 5 May 2023, have published a “Notice” which warns that individuals from “Money Farm” are suggesting that they work for MFM Investment Ltd, that “Money Farm” is a “cloned firm” and “part of a scam”. To find out more information, the record for this firm is accessed by clicking on its name. This returns:
Money Farm (Clone of FCA Authorised Firm)
This is an unauthorised firm that uses the details of a genuine FCA-regulated firm when offering products and services. This makes the unauthorised firm appear as if it is regulated. We strongly suggest you do not deal with unauthorised firms.
Unauthorised
Note that this Money Farm record, on the FS Register, does not provide: a company number for “Money Farm”, details of any individuals, or a registered address.
Proposed definition of an individual with multiple identities, as a cloned person.
The Financial Conduct Authority describes a company that is impersonating another as a “cloned firm”. Since a firm is a legal person, I recommend that we adopt this terminology for an individual who has registered multiple identities in Companies House as they are purporting to be multiple people, which obfuscates their interests and prevents accountability. When they establish their second identity they become a “cloned person”.
Returning to the FS Register for MFM Investment Ltd: there are 19 people currently involved in regulated activities for MFM Investment Ltd. These will be considered in a follow up report. Dame Jayne-Anne is the first listed, her record reads:
Jayne-Anne Gadhia JXG01357 Approved by regulator
SMF9 Chair of the Governing Body
28 people were previously involved in regulated activities in this firm.
Regulated activities that this firm can offer to EEA countries: A ‘passport’ enables this authorised firm to provide financial products or services, set up a base, or carry on its permitted activities in Gibraltar.
Regulated by Financial Conduct Authority Effective from 08 Jul 2015
Analysis of MFM Investment Ltd in the FS Register.
The Financial Services Register provides the correct Companies House registration number for MFM Investment Ltd. The address, however, is not the registered address in Companies House which is given as “ 90-92, Pentonville Road, London, England, N1 9HS”, rather than “ 90-92 Pentonville Road London N1 9HS UNITED KINGDOM”. The address in the FS Register omits “England” and adds “UNITED KINGDOM” after the postcode. The significance of this will become apparent, later.
MFM Investment Ltd has a “Gibraltar passport” assigned on the FS Register, whereas the company accounts refer to business in Italy, not Gibralta,. This is a material difference.
The FCA warns that a firm called Money Farm is a “cloned firm” of MFM Investment Ltd and “individuals are using the details of this firm to suggest they work for the genuine firm” as “part of a scam”. However, the FCA provides no details of the individuals involved. This is a red flag for potential money laundering and other crime and the lack of information about the clone “Money Farm” is an example of an inadequate response by the regulator.
Summary.
Dame Jayne-Anne declares that she is “chair of Moneyfarm”. From the Moneyfarm website it can be concluded that “Moneyfarm” is the copyright name of MFM Investment Ltd. The Companies House record of MFM Investment Ltd states that it is controlled by MFM Holding Ltd. MFM Holding Ltd, a holding company with financial services subsidiaries, inaccurately registers its nature of business, avoiding being held to a robust accountability framework expected for a financial services holding company.
Referring to the Financial Services Register, maintained by the Financial Conduct Authority, the MFM Investment Ltd record carries a “Notice” stating that “Money Farm” is a “cloned firm” of MSM Investment Ltd and “individuals are using the details of this firm to suggest they work for the genuine firm” as “part of a scam”. However, the FCA provides no details of the individuals involved. This is a red flag for potential money laundering and other crime.
The Financial Services Register provides an different version of the registered office address for MFM Investment Ltd. Different addresses can cause non-match errors in audit software and are a red flag for money laundering and related crime.
Dame Jayne-Anne’s declaration of “Moneyfarm” in her biography and Register of Interest is inaccurate since this relates to her directorship of two companies with registered names MFM Investment Ltd and MFM Holding Ltd. Since the relationship between “Moneyfarm” and the MFM companies is not made clear in her Register of Interests, her disclosure, obfuscates access to the records of her interest. This is why I failed to link Dame Jayne-Anne’s disclosure of “Moneyfarm” to her registrations to MFM Investment Ltd and MFM Holding Ltd in Companies House, in my first analysis, which is evidence that this method of obfuscation can work.
Risk of fraud using the name “Money Farm” and “Moneyfarm”.
As would be the case for any company in this situation, despite the copyright name being “Moneyfarm”, transactions at the MFM companies must be made in the registered name of the company i.e. as MFM Investment Ltd and MFM Holding Ltd; not as “Moneyfarm”. Therefore, there is a risk that another company called Money Farm or Moneyfarm could deceptively purport to be an MFM company, for the purposes of fraud. The FCA record draws attention to the fact that this is occurring, with respect to “Money Farm”. The risk of deception is not reduced, by MFM copyrighting the name “Moneyfarm”, since the copyright can give a false sense of security that “Moneyfarm” is protected.
On 5 May 2023 the Financial Conduct Authority flagged “Money Farm” as a “cloned firm” and “part of a scam” by purporting to be associated to MFM Investment Ltd, which is known as “Moneyfarm”.
The following section will test whether there are any companies registered in Companies House with the names Money Farm or MoneyFarm. When I refer to the copyright name of MFM Investment Ltd, I refer to it as “Moneyfarm”.
Money Farm
Money Farm in Companies House
A search for Money Farm in Companies House, which is the name referenced on the Financial Conduct Authority “clone” notice, returns four companies with these names, see image 8. Two of these firms have The Money Farm, as their previous name, in common. This is an occurrence that should not happen, since registered company names are supposed to be unique. This is a red flag for money laundering.
There are variations in each of the registered addresses of these four Money Farm companies, which all reference the same location. This would induce non-match errors in audit software resulting in them not being associated to the same address, when a human can see that they are. The address variations and duplicate use of The Money Farm are highlighted in bold, below. Additional information, from the Overview and Officers page of the company referenced, has been added:
THE MONEY FARM CORPORATE FINANCE LIMITED 10085022 - Dissolved on 29 August 2017
Heron Toweer (sic) 110 Bishopgate (sic) London, London, (sic) England, EC2R 4AY Incorporated on 24 March 2016 (No accounts produced) Nature of business (SIC) To be provided on next annual return. 1 officer / 0 resignations VOEGT, William Richard Date of birth November 1948
LIONGWEALTH LIMITED Matching previous names: THE MONEY FARM 09510460 - Dissolved on 27 November 2018 (No accounts produced)
Heron Tower, 110 Bishopsgate Bishopsgate London, England, EC2N 4AY Incorporated on 26 March 2015 Nature of business (SIC) 69203 - Tax Consultancy Previous company names
LIONGATE WEALTH LIMITED 14 Oct 2016 - 21 Mar 2017
THE MONEY FARM LIMITED 26 Mar 2015 - 14 Oct 2016
1 officer / 0 resignations VOEGT, William Richard Date of birth November 1948
THE MONEY FARM COMPANY SERVICES LIMITED 05016225 - Dissolved on 28 June 2016
Heron Tower, Bishopsgate, London, EC2N 4AY Incorporated on
15 January 2004 (Accounts overdue) Last accounts made up to 31 March 2015
Nature of business (SIC) 69201 - Accounting and auditing activities 69202 - Bookkeeping activities 69203 - Tax consultancy
7 officers / 6 resignations
VOEGT, William Richard Date of birth November 1948
LI, Min Correspondence address Blueprint Financial Services Ltd, 51 Moorgate, London, United Kingdom, EC2R 6PB Date of birth February 1970 ROBSON, John Sutherland Date of birth December 1938
WV FINANCIAL SERVICES LIMITED Matching previous names: THE MONEY FARM 07526047 - Dissolved on 9 August 2016
Heron Tower, 110 Bishopgate, (sic) London, EC2R 4AY Incorporated on
11 February 2011 (Accounts overdue) Last accounts made up to 28 February 2013 Nature of business (SIC) 66220 - Activities of insurance agents and brokers
69203 - Tax consultancy 1 officer / 0 resignations VOEGT, William Richard
Date of birth November 1948 Previous company names THE MONEY FARM LIMITED 11 Feb 2011 - 13 Mar 2015
The FCA issues a notice about “Money Farm” which warns “Clones of this firm: Individuals are using the details of this firm to suggest they work for the genuine firm. We call this a cloned firm and it is typically part of a scam.” This name is used by four companies that have the same location but have used four different versions of the same address, for their registration. These variations cause non-match errors, compromising due diligence. The companies are all dissolved without producing final accounts, which is irregular, the risk if these companies still have active bank accounts, is high. The risk that one, some, or all of these are associated to the “Money Farm” about which the FCA issues a notice, is high.
Chronological Summary of The Money Farm Limited
William Richard Voegt, date of birth November 1948, established two companies called Money Farm Limited, using different spellings of the same registered address :
WV Financial Services Limited, incorporated on 11 February 2011 at Heron Tower, 110 Bishopgate, London, EC2R 4AY. Dissolved on 9 August 2016 with accounts overdue, since the last accounts were made up to 28 February 2013, it was established for: 66220 - Activities of insurance agents and brokers and 69203 - Tax consultancy. With 1 officer and 0 resignations the sole director William Richard Voegt. The previous company name was THE MONEY FARM LIMITED from 11 Feb 2011 to 13 Mar 2015.
Liongwealth Limited incorporated on 26 March 2015 at Heron Tower, 110 Bishopsgate Bishopsgate London, England, EC2N 4AY. Dissolved on 27 November 2018, no accounts produced for 69203 - Tax Consultancy. With 1 officer and 0 resignations the sole director William Richard Voegt. The previous company names were LIONGATE WEALTH LIMITED 14 Oct 2016 - 21 Mar 2017 and THE MONEY FARM LIMITED 26 Mar 2015 - 14 Oct 2016.
Name switching
I conclude that Mr Voegt established “The Money Farm Limited” on 11 Feb 2011 and this company changed name to WV Finance Services Limited on 13 March 2015. Ten days later, on 26 March 2015, Mr Voegt registered a second company called “The Money Farm Limited”. This company changed name Liongate Wealth Limited on 14 October 2016, then to Liongwealth Limited on 14 October 2016. The first company, renamed to WV Finance Services Limited was dissolved on 9 August 2016 with its accounts overdue, since the last accounts were made up to 28 February 2013; it was established for: 66220 - Activities of insurance agents and brokers and 69203 - Tax consultancy. The second company, renamed Liongwealth Limited, was dissolved on 27 November 2018, no accounts were produced, it was established for 69203 - Tax Consultancy.
The name “The Money Farm Limited” was switched from the company that became known as WV Financial Services, providing insurance agent and broking as tax consultancy, on 13 March 2015, to the company that later became known at Liongwealth Limited, on 26 March 2015, providing tax consultancy only. Name switching between companies is illegal and is a red flag for money laundering and other criminal activity. Both these companies were dissolved with their annual accounts not provided. These irregularities are a further red flag. There is a risk that bank accounts for these companies are still in use.
William Richard Voegt
Referring to Mr Voegt’s record of personal appointments in Companies House:
William Richard VOEGT personal appointments:
1 active appointment Total number of appointments 24
ASSOCIATED TRADING LIMITED (11412293) Company status Active Correspondence address 105 Old Brompton Road, London, United Kingdom, SW7 3LE Role ACTIVE Director Appointed on 13 June 2018. Incorporated on 13 June 2018 Accounts Next accounts made up to 30 June 2023 due by 31 March 2024 Last accounts made up to 30 June 2022 Nature of business (SIC) 66220 - Activities of insurance agents and brokers 69203 - Tax consultancy
Description.
Mr Voegt has only one active appointment out of a total of 24, this is to Associated Trading Limited. He was appointed at incorporation on 13 June 2018. The company provides activities of insurance agents and brokers and tax consultancy, the accounts are up to date. There are other officers who were appointed to Associated Trading Limited and these need to be included in this analysis, as well as his 23 other interests. This analysis, presently, is only focussing on his interests that include the name Money Farm. Consideration his other past interests, held in the same identity, will follow shortly.
Since Mr Voegt has been a director of two companies called The Money Farm Limited, this will be the subject of the next search.
“The Money Farm Limited” in the Financial Services Register.
A search in the Financial Services Register for The Money Farm Limited, returns one company with this name, the record contains the following information:
The Money Farm Limited Reference number: 313365
This firm can no longer provide regulated activities and products, but previously was authorised by the FCA and/or PRA. No longer authorised.
Address information 1 Groom Crescent London SW18 3JB UNITED KINGDOM Phone +4402076316505 +44020-763-16505 Email william@themoneyfarm.co.uk Website www.themoneyfarm.co.uk Firm reference number 313365 Registered company number 04030304
Individuals previously involved in regulated activities at this company: 1
William Voegt WRV00001
CF1 Director
CF8 Apportionment and Oversight
Responsible for Insurance Mediation
Former regulator of this firm
Financial Services Authority from 31 Oct 2004 to 23 Jun 2008
The Financial Services register holds a record for The Money Farm Limited, reference number 313365, a firm previously authorised by the Financial Conduct Authority from 31 Oct 2004 to 23 Jun 2008.
These dates, 31 Oct 2004 to 23 Jun 2008, precedes the establishment of “Moneyfarm” also known as MFM Investment Ltd, which was registered 16 June 2014, the establishment of “The Money Farm Limited” on 11 Feb 2011 (which was dissolved on 9 August 2016) and the second company called “The Money Farm Limited”, which was incorporated ten days later, on 26 March 2015 and dissolved on 27 November 2018.
Irregularities with The Money Farm Limited registration in the Financial Services register.
Issue 1. The FS registration for The Money Farm Limited incorrectly links to the “Moneyfarm” website of MFM Investment Ltd.
Clicking on the website address provided in the Financial Services Register for The Money Farm Limited, “www.themoneyfarm.co.uk”, automatically links through to www.moneyfarm.com/uk/, the website for “Moneyfarm”, registered as MFM Investment Ltd.
This is irregular as the FCA record provides a website link that incorrectly associates The Money Farm Limited (FCA reference number: 313365, Companies House registration number 04030304) to “Moneyfarm”, registered as MFM Investment Ltd (registration number 09088155).
This association breaches Anti-Money Laundering and Counter-Terrorism financing legislation and is additionally concerning. This could give someone, or audit software, doing a due diligence check, today, on a transaction in the name Moneyfarm, Money Farm, The Money Farm or The Moneyfarm, with or without Limited or Ltd, some evidence to support that Mr Voegt is associated to MFM Investment Ltd, with copyright name “Moneyfarm”, when this is not borne out by the records in Companies House.
Issue 2. The FS registration for The Money Farm Limited gives its Companies House registration number as 04030304. This is the registration number of The Moneyfarm Limited. To be correct, the FS registration should be for The Moneyfarm Limited and not The Money Farm Limited.
The Moneyfarm Limited
A search in Companies House for the registration number, quoted in the Financial Services register, for The Money Farm Limited, which is “04030304”, returns:
THE MONEYFARM LIMITED (04030304) Registered office address The Money Farm 1st Floor, 1 Warwick Row, London, SW1E 5ER Company status Dissolved Dissolved on 17 August 2010 Company type Private limited Company Incorporated on 10 July 2000 Accounts (Overdue) Last accounts made up to 30 April 2008 Nature of business (SIC) 6523 - Other financial intermediation
THE MONEY FARM COMPANY SERVICES LIMITED Correspondence address 1st Floor, 1 Warwick Row, London, SW1E 5ER Role Secretary Appointed on 10 August 2006 Total number of appointments 7 All dissolved:
OLYVIA ORIENTAL LTD (05582917)
THE MONEYFARM LIMITED (04030304)
ADRIAN DALBY DESIGN + ARCHITECTURE LIMITED (05890339)
IT'S A KIDS THING LIMITED (04918135)
BATH SPA EXPERIENCE LIMITED (04658074)
MANIC MONKEY LIMITED (06375629)
GIGBUTT LIMITED (05661220)
VOEGT, Jashree Correspondence address 1 Groom Crescent, Wandsworth, London, SW18 3JB Role Director Date of birth August 1966 Appointed on 30 April 2007 Nationality British Occupation Director Total number of appointments 1
VOEGT, Jayshree Correspondence address 1 Groom Crescent, London, SW18 3JB Role RESIGNED Secretary Appointed on 11 July 2000 Resigned on 10 August 2006 Nationality British Occupation Secretary Total number of appointments 3. THE MAYFAIR MORTGAGE CENTRE LIMITED (03797839)
Company status Active Correspondence address 1 Groom Crescent, London, SW18 3JB Role RESIGNED Secretary RESIGNED director Appointed on 27 March 2000 Resigned on 5 June 2000
QA REGISTRARS LIMITED Correspondence address The Studio, St Nicholas Close, Elstree, Hertfordshire, WD6 3EW Role RESIGNED Nominee Secretary Appointed on 10 July 2000 Resigned on 10 July 2000
[N.B. This identity links to corporate identity QA NOMINEES LIMITED]
Total number of appointments 12403 Current appointments 5:
WONDERFUL PICTURES LIMITED (05936685)
BUBBLEGUM LIMITED (05109711)
INVEST SKI LIMITED (04951075)
OMNIA ASSET MANAGEMENT LIMITED (02975738)
E-CORP LIMITED (04441049)
VOEGT, William Richard, Dr Correspondence address 1 Groom Crescent, London, SW18 3JB Role RESIGNED Director Date of birth November 1948 Appointed on 11 July 2000 Resigned on 30 April 2007 Occupation Financial Consultant Total number of appointments 24 Current Appointment 1: ASSOCIATED TRADING LIMITED (11412293) Appointed on 13 June 2018
[Other interests are dissolved, unless stated active, or resigned directorships]:
WRV CONSULTANCY LIMITED (13804875) Appointed on 16 December 2021
THE CREDIT GURU LIMITED (12697362) Appointed on 25 June 2020
COMPANYWILL L LIMITED (12037056) Appointed on 6 June 2019
FAMILY INHERITANCE LTD. (11807369) Appointed on 5 February 2019
LIONGATE WEALTH LIMITED (10782888) Appointed on 22 May 2017
THE MONEY FARM CORPORATE FINANCE LIMITED (10085022) Appointed on 24 March 2016
PRB BROMPTON LIMITED (09804490) Appointed on 1 October 2015
ADRIAN DALBY ARCHITECTS LTD (09616222) Appointed on 1 June 2015
LIONGWEALTH LIMITED (09510460) Appointed on 26 March 2015
WV FINANCIAL SERVICES LIMITED (07526047) Appointed on 11 Feb 2011
THE MONEY FARM COMPANY SERVICES LIMITED (05016225) Appointed on 7 November 2008
OPENWORK PARTNERSHIP LLP (OC312300) Active Appointed on 1 January 2006 Resigned on 1 February 2020
HARLEQUIN BRICKWORK LIMITED (07534951) Active Appointed on 10 May 2016 Resigned on 8 August 2017
DENNARD THEATRE ARTS LIMITED (06564090) Appointed on 14 April 2008
Resigned on 18 May 2011
GETWAY GLOBAL LIMITED (07488857) Appointed on 11 January 2011 Resigned on 1 March 2011
RMS - RESEARCH & MARKETING SERVICES LIMITED (01986772) Active
Appointed on 1 February 2008 Resigned on 30 September 2010
SILVER FERN LIMITED (01869249) Active Appointed on 1 July 2004 Resigned on 1 August 2009
MANIC MONKEY LIMITED (06375629) Appointed on 19 September 2007 Resigned on 21 December 2007
THE MONEY FARM COMPANY SERVICES LIMITED (05016225) Appointed on 15 January 2004 Resigned on 14 July 2007
THE MONEYFARM LIMITED (04030304) Appointed on 11 July 2000 Resigned on 30 April 2007
BSA CLOTHING LIMITED (05832572) Appointed on 31 May 2006 Resigned on
8 February 2007
THE MAYFAIR MORTGAGE CENTRE LIMITED (03797839) Active RESIGNED Secretary Appointed on 13 January 2000 Resigned on 27 March 2000
QA NOMINEES LIMITED Correspondence address The Studio, St Nicholas Close, Elstree, Hertfordshire, WD6 3EW Role RESIGNED Nominee Director Appointed on 10 July 2000 Resigned on 10 July 2000 Total number of appointments 12154 Current appointments 0.
The Moneyfarm Limited is absent the space between “Money” and “farm”, even though this is the record that corresponds with the Companies House registration number for The Money Farm Limited, as given in the Financial Services register. It was incorporated on 10 July 2000 for financial mediation and was dissolved on 17 August 2010, with its accounts overdue since 30 Aril 2008.
The Moneyfarm Limited was active during the period that The Money Farm Limited was regulated by the Financial Services Authority, from 31 Oct 2004 to 23 Jun 2008. Mr Voegt was a director from the 11 July 2000, the day after this company was established, until 30 April 2007. He was also a director of: The Money Farm Company Services Limited, appointed on 15 January 2004, resigned on 14 July 2007, and appointed again on 7 November 2008, it was dissolved on 28 June 2016; and, The Money Farm Corporate Finance Limited, appointed director on 24 March 2016 and he was active when it dissolved on 29 August 2017. This is in addition to his appointments already discussed, to two companies called The Money Farm Limited, which switched names.
Issue 3. Registered address anomalies: The Money Farm Limited record in the FS register gives its address as “1 Groom Crescent London SW18 3JB”, whereas the company with the same registration number in Companies House, The Moneyfarm Limited, gives the registered address as “The Money Farm 1st Floor, 1 Warwick Row, London, SW1E 5ER”.
A search in Companies House, based on the address “1 Groom Crescent London SW18 3JB” returns three companies registered there, see image 9.
The address provided for The Money Farm Limited, in the FS register, is the registered address of three companies only; Associated Trading Limited, which is the active, and The Credit Guru Limited and WRV Consultancy Limited, which are dissolved. William Voegt is the only active director of Associated Trading Limited and he was the sole director of the two dissolved companies.
To visualise these three issues with the record for The Money Farm Limited, in the FS register, a screen shot of the record is annotated with these findings can be seen in image 10.
“Moneyfarm” impersonation.
The FS register record for The Money Farm Limited provides a website link to MFM Investment Limited’s “Moneyfarm”; the use of the registered address of Associated Trading Limited, which ensures that any correspondence, such as an invoice or payment, would be sent to Mr Voegt; and, any check on the company registration number in Companies House which will confirm that Mr Voegt was a director of The Moneyfarm Limited, relying on any reviewer to dismiss the fact that the names don’t match. This record, even though The Money Farm Limited is flagged as “No longer authorised”, could be used in “know your customer” checks to support a transaction, today, in the name of William Voegt at The Money Farm Limited or The Moneyfarm Limited, that was intended for MFM Investment Ltd’s “Moneyfarm”. With or without the complicity of a director of MFM Investment Ltd, contracts intended for “Moneyfarm” could be diverted to The Moneyfarm Limited, using the Financial Services record, as proof of identity. This record holds the components that can enable Mr Voegt to impersonate that he is a director of “Moneyfarm”.
Chronology of Mr Voegt’s associations with the names Money Farm and Moneyfarm.
The Moneyfarm Limited. Incorporated on 10 July 2000 for financial mediation, was dissolved on 17 August 2010, with its accounts overdue since 30 Aril 2008. Mr Voegt was appointed director on 11 July 2000 to 30 April 2007. Moneyfarm Limited is recorded as “The Money Farm Limited” in the FS register, which provides the same Companies House registration number, 04030304, however the website link redirects to the website of MFM Investment Ltd, also known as “Moneyfarm”;
The Money Farm Company Services Limited Incorporated on 15 January 2004 for: Accounting and auditing activities, Bookkeeping activities and Tax consultancy, was dissolved on 28 June 2016, with its accounts overdue since 31 March 2015. Mr Voegt was appointed director from 15 January 2004 to 14 July 2007 and appointed again on 7 November 2008;
Two companies called The Money Farm Limited involved in name switching.
The first “The Money Farm Limited” was established on 11 Feb 2011 and this company changed name to WV Finance Services Limited on 13 March 2015. Thirteen days later, on 26 March 2015, Mr Voegt registered a second company called “The Money Farm Limited”. This company changed name to Liongate Wealth Limited on 14 October 2016, then to Liongwealth Limited on 14 October 2016. The first company, renamed to WV Finance Services Limited, was dissolved on 9 August 2016 with its accounts overdue, since the last accounts were made up to 28 February 2013; it was established for: 66220 - Activities of insurance agents and brokers and 69203 - Tax consultancy. The second company, renamed Liongwealth Limited, was dissolved on 27 November 2018, no accounts were produced, it was established for 69203 - Tax Consultancy.
The name “The Money Farm Limited” was switched from the company that became known as WV Financial Services, providing insurance agent and broking as tax consultancy, on 13 March 2015, to the company that later became known at Liongwealth Limited, on 26 March 2015, providing tax consultancy only.
The Money Farm Corporate Finance Limited Incorporated on 24 March 2016 for Nature of business (SIC) “To be provided on next annual return”, was dissolved on 29 August 2017. Mr Voegt was appointed director on 24 March 2016.
Before I continue, with Mr Voegt, note that the co-director and secretary at The Moneyfarm Limited, Jashree Voegt has used two spellings of her name. She registered as secretary, in a separate identity, as Jayshree Voegt. Under this second identity she is also registered as secretary and director, resigned in 2000, of THE MAYFAIR MORTGAGE CENTRE LIMITED (03797839) a company which is active today. Multiple identities conceal interests. In this case, audit software looking for Jashree Voegt’s interests would only find The Moneyfarm Limited, since this is the only interest held in this identity, and the software would not realise that she has registered with two names; to software these are two entirely separate people. Whether The Mayfair Mortgage Centre Limited is complicit with “Moneyfarm” fraud, requires further investigation, which is not undertaken here.
The record for QA Registrars Limited, accessed by clicking on this name, links to the personal appointments for “QA Nominees Limited”. This is an additional occurrence of name switching, which causes errors in associated audits. I’ve requested Companies House to take action on this anomaly and explain how it occurred.
Query whether there has been collusion between “Moneyfarm”, The Moneyfarm Limited and the regulator, the Financial Conduct Authority?
The record for The Money Farm Limited in the Financial Services Register is materially incorrect:
the company provides a Companies House registration number of The Moneyfarm Limited, without a space between Money and Farm;
the link to the company website routes to the website of MFM Investment Ltd website, also known as “Moneyfarm”;
the address provided, is that of Mr Voegt’s only active interests, Associated Trading Limited; and,
it fails to link the warning notice, about “Money Farm” being a clone firm of MFM Investment Ltd, to the entry for The Money Farm Limited.
The likelihood of both MFM Investment Ltd and the Financial Conduct Authority both missing these obvious anomalies, with the record for The Money Farm Limited, whilst being aware that “Money Farm” are impersonating “Moneyfarm”, hence the scam “Notice”, is vanishingly small. The only explanations I can think of are:
Either, the anomalies in the Financial Services register for The Money Farm Limited are unknown by the directors of MFM Investment Ltd. Which means that MFM Investment Ltd’s vigilance, to ensure that records that might be associated to them are correct, is very weak, which brings their assurance processes and auditor into question;
Or, it is with the knowledge of a director, or directors, of MFM Investment Ltd. Mr Voegt has been associated with The Moneyfarm Limited since the day following its incorporation on 10 July 2000. This precedes the emergence of “Moneyfarm", which it describes on its website: “Mar 2011 Moneyfarm is born […] Feb 2016 We launch in the UK”. This shared history with the same name could mean that there is collusion between MFM Investment Ltd and Mr Voegt. It is possible that Mr Voegt is an undeclared “shadow director” of MFM Investment Limited, which, if so, means that he should have been registered as a director in Companies House.
Referring back to the Financial Services Register for MFM Investment Ltd, it flags that “Money Farm” is a “cloned firm” and “part of a scam” by purporting to be associated to MFM Investment Ltd, “Moneyfarm”. The FS record for The Money Farm Limited provides evidence that it is this company that purports to be MFM Investment Ltd (Moneyfarm), by providing a weblink in its official website and the registration number of The Moneyfarm Limited.
Therefore, the Notice within the FS record for MFM Investment Ltd, that warns that Money Farm is a clone firm and part of a scam, should refer to its record for The Money Farm Limited, rather than being an isolated record for “Money Farm”, about which no information is provided.
Considering how the FCA regulator has failed to make this simple connection presents two options:
either, the regulator is failing to do its job, which is to ensure that the ‘Clone Scam Notice’ properly identifies the correct company;
or, the regulator has turned a blind eye.
This is a red flag for potential collusion between the regulator, The Money Farm Limited (registered as The Moneyfarm Limited) and “Moneyfarm”.
That Dame Jayne-Anne, the chair of HMRC, has disclosed in her register of interest “Moneyfarm” rather than the correct names of her directorships, MFM Investment Ltd and MFM Holding Ltd, provides some evidence that she may be part of a scam to defraud “Moneyfarm”. As a director of “Moneyfarm” she is in a position to authorise transactions, these should be in the name of MFM Investment Ltd and MFM Holding Ltd only. A company purporting to be “Moneyfarm”, by using the name The Moneyfarm Limited, could cite authorisation from Dame Jayne-Anne, the “know your customer” checks that then follow could refer to her Register of Interest and finding “Moneyfarm” declared, the transaction would be approved, when it should not have been.
FS registration of Mr William Voegt.
The FS registration of Mr William Voegt was accessed by clicking on his name in The Money Farm Limited record, under “individuals previously involved in regulated activities at this firm”. Excepts from the record:
William Voegt (Reference number: WRV00001
Certified / assessed by firm
This individual has been certified and/or assessed by an authorised firm that is regulated for certain activities. This firm accepts responsibility for the certified/assessed individual and the information on this record. The FCA does not directly approve these individuals.
No FCA or PRA disciplinary or regulatory action Known as William Previous names Mr William Richard Voegt
William Voegt is connected to: The Right Mortgage Limited
The individual’s information has been confirmed as correct by their firm within the last 12 months Firms are required to confirm that the information shown is correct at least annually. Appointed representative dealing with clients for which they require qualification From 09 Dec 2019
About this role This individual has been certified and/or assessed by an authorised firm that is regulated for certain activities. This firm accepts responsibility for the certified/assessed individual and the information on this record.
Additionally, this individual performs 1 activity that requires qualifications. Mortgage activities 20. Advising or arranging (bringing about) regulated mortgage contracts for a non-business purpose
This firm trades under 11 names Reference number: 649443.
Insure Right Trading 06 Feb 2023
TRM Direct Trading 25 Jan 2022
The Right PMI & Healthcare Trading 07 Oct 2019
The Right PMI Network Trading 07 Oct 2019
The Later Life Lending & Equity Release Network Trading 23 Apr 2019
The Right Loan Trading 19 Sept 2018
Equity Release Adviser Trading 28 Jun 2018
The Later Life Lending Network Trading 14 Feb 2018
The Right Mortgage & Protection Network Trading 23 Feb 2015
The Right Protection Trading 23 Feb 2015
The Right Mortgage Limited Registered 02 Feb 2015
Previous company names:
The Right DA Club Trading 18 Feb 2021 08 Dec 2022
TRM Direct Trading 05 Apr 2019 17 Jun 2019
Financial Advice Zone Trading 28 Jun 2018 19 Aug 2022
The Right Mortgage Club Trading 03 Oct 2016 08 Dec 2022
Ascot Mortgages Trading 04 Dec 2015 12 Feb 2016
DHH Mortgages Trading 30 Nov 2015 07 Feb 2017
Impartial FS Trading 16 Oct 2015 07 Feb 2017
Monument Financial Solutions Trading 16 Oct 2015 07 Feb 2017
Mortgage and Protection Solutions Trading 18 Sept 2015 07 Feb 2017
Millbank Mortgage Advisers Trading 04 Sept 2015 07 Dec 2015
Valiant FS Trading 13 Jul 2015 18 Sept 2015
Meridian Financial Planning Trading 12 Jun 2015 18 Sept 2015
U-Tax fs Trading 26 Mar 2015 07 Dec 2015
Mortgage Force Trading 10 Mar 2015 07 Feb 2017
Finley Jacobs; The Right Life Cover Trading 10 Oct 2014 12 Aug 2021
Meridian FP; The Right Mortgage Trading 10 Oct 2014 12 Jun 2015
Stretton Financial Solutions; Woodshires Financial Trading10 Oct 2014 07 Feb 2017
The Right Home Insurance Trading 10 Oct 2014 07 Feb 2017
William Voegt was connected to:
Openwork Limited
The Money Farm Limited
Zurich Advice Network Limited
William Richard Christopher Voegt (Appointed Representative)
William Richard Christopher Voegt (Appointed Representative)
Blueprint Financial Services Ltd (Appointed Representative)
Since Mr Voegt is currently authorised by The Right Mortgage Limited, its records were accessed in Companies House:
THE RIGHT MORTGAGE LIMITED overview
Registered office address 70 St. Johns Close, Knowle, Solihull, West Midlands, B93 0NH Company status Active Company type Private limited Company Incorporated on 4 July 2012 Accounts Next accounts made up to 31 December 2022 due by 31 December 2023 Nature of business (SIC) 66220 - Activities of insurance agents and brokers
THE RIGHT MORTGAGE LIMITED people 9 officers / 2 resignations
Looking at the “people” page (not reproduced here) Mr Voegt is not a director of The Right Mortgage Limited. The first director of this company, , Ben Allen, born December 1980, was searched , also searching on Benjamin Allen, to see if he has multiple identities registered, with the same date of birth, in Companies House.
Ben Allen, an active director of The Right Mortgage Limited, has a minimum of three identities. These are:
Identity 1 Ben ALLEN Total number of appointments 2 Date of birth December 1980
TRM DIRECT LIMITED (12046164) Dissolved 70 St. Johns Close, Knowle, Solihull, United Kingdom, B93 0NH Appointed on 5 July 2019 Resigned on 26 April 2022
THE LATER LIFE LENDING NETWORK LIMITED (09832887)Active Appointed on 7 December 2021 Resigned on 25 April 2022
Identity 2 Ben ALLEN Total number of appointments 3 Date of birth December 1980
THE RIGHT MORTGAGE LIMITED (08130498) Active 70 St. Johns Close, Knowle, Solihull, West Midlands, B93 0NH ACTIVE Director Appointed on 1 June 2018
PINK GUAVA LIMITED (10874056) Dissolved 154 Thatcham Avenue, Kingsway, Quedgeley, Gloucester, Gloucestershire, England Director Appointed 19 July 2017
TRN ADVISER LIMITED (09863667) Active 70 St. Johns Close, Knowle, Solihull, England, B93 0NH Director Appointed on 17 May 2017 Resigned on 24 April 2022
Identity 3 Benjamin ALLEN
Total number of appointments 2 Date of birth December 1980
BEECHWOOD GROUP LIMITED (12141442) Dissolved 3 Southmead Gardens,, (sic) Alcester Road, Studley, Warwickshire, United Kingdom, B80 7NW Director Appointed on 6 August 2019
THE RIGHT RETIREMENT PLAN LIMITED (13502665) Active 70 St. Johns Close, Knowle, Solihull, England, B93 0NHAppointed on 1 August 2021 Resigned on 26 April 2022
Identity 4? Adrian James Benjamin ALLEN
Total number of appointments 1 Date of birth December 1980
GREY STANDARD LTD (07285797) Company status Dissolved Correspondence address Unit L, 3rd Floor West, 100 Greenfield Road, London, England, E1 1EJ Role Director Appointed on 16 June 2010 Nationality British Country of residence England Occupation Manufacturing
Ben Allen, date of birth December 1980, director of The Right Mortgage, certainly has three identities registered in Companies House because each identity refers to the same address 70 St. Johns Close, Knowle, Solihull, England, B93 0NH. There is an identity for Adrian James Benjamin ALLEN and I query whether this is also the same person. Ben Allen established his second identity, identity 1, above, on 5 July 2019 and since this date, he has compromised audits and committed identity fraud, and requires further investigation for fraud by abuse of position.
Compilation of summaries about Moneyfarm, so far.
Dame Jayne-Anne, is the chair of “Moneyfarm”, which is a copyright name of MFM Investment Ltd, and she is a director of its holding company, MFM Holding Ltd. Reviewing the record for MFM Holding Ltd, in Companies House, shows that it is not registered with the SIC code for a financial services holding company, which would be an accurate description of its nature of business. It is registered for nature of business of “other information service activities not elsewhere classified, such as: news and press clipping services”, in my opinion, the incorrect SIC code does not provide the robust accountability framework that the public expect for a financial services holding company. An inaccurate version of the registered address of MFM Investment Ltd is recorded on the FS register, which represents a risk for causing non-match errors in audits and audit software.
The Financial Conduct Authority has posted a Notice on the MFM Investment Ltd record stating that “Money Farm” is a “cloned firm”, impersonating MFM Investment Ltd (“Moneyfarm”). The FCA provides no details of the individuals involved. This is a red flag for potential money laundering and other crime.
Dame Jayne-Anne’s declaration of “Moneyfarm” in her biography and Register of Interests is inaccurate since this relates to her directorship of two companies with registered names MFM Investment Ltd and MFM Holding Ltd. Since the relationship between “Moneyfarm” and the MFM companies is not made clear in her Register of Interests, her disclosure, obfuscates access to the records of her interest. This is why I failed to link Dame Jayne-Anne’s disclosure of “Moneyfarm” to her registrations to MFM Investment Ltd and MFM Holding Ltd in Companies House, in my first analysis.
Since the Financial Services record for MFM Investment Ltd flags that “Money Farm” is impersonating MFM Investment Ltd, a search was made, in Companies House for Money Farm. This led to Mr Voegt who was a director of two companies called The Money Farm Limited, in addition to The Moneyfarm Company Services Limited and Moneyfarm Corporate Finance Limited.
Searching on the registration number given in the FS register for The Money Farm Limited, 04030304, led to The Moneyfarm Limited in Companies House. This was the first company established using Moneyfarm in the name, of which Mr Voegt became a director the day after it was established on 10 July 2000.
Chronology of Mr Voegt’s associations with the names Money Farm and Moneyfarm.
The Moneyfarm Limited. Incorporated on 10 July 2000 for financial mediation, was dissolved on 17 August 2010, with its accounts overdue since 30 Aril 2008. Mr Voegt was appointed director on 11 July 2000 and resigned in 30 April 2007. The Moneyfarm Limited is recorded as “The Money Farm Limited” in the FS register, which provides the same Companies House registration number, 04030304. The company website link, provided in the FS register, redirects to the website of MFM Investment Ltd, also known as “Moneyfarm”. This weblink enables misrepresentation and is a serious breach that requires investigation.
The Money Farm Company Services Limited Incorporated on 15 January 2004 for: Accounting and auditing activities, Bookkeeping activities and Tax consultancy, was dissolved on 28 June 2016, with its accounts overdue since 31 March 2015. Mr Voegt was appointed director from 15 January 2004 to 14 July 2007 and appointed again on 7 November 2008, he was active when the company dissolved.
Two companies called The Money Farm Limited, involved in name switching.
The first “The Money Farm Limited” was established on 11 Feb 2011 and this company changed name to WV Finance Services Limited on 13 March 2015. Thirteen days later, on 26 March 2015, Mr Voegt registered a second company called “The Money Farm Limited”. This company changed name to Liongate Wealth Limited on 14 October 2016, then to Liongwealth Limited on 14 October 2016. The first company, renamed to WV Finance Services Limited, was dissolved on 9 August 2016 with its accounts overdue, since the last accounts were made up to 28 February 2013; The second company, renamed Liongwealth Limited, was dissolved on 27 November 2018, no accounts were produced.
The name “The Money Farm Limited” was switched from the company that became known as WV Financial Services, providing insurance agent and broking as tax consultancy, on 13 March 2015, to the company that later became known at Liongwealth Limited, on 26 March 2015, providing tax consultancy only.
The Money Farm Corporate Finance Limited Incorporated on 24 March 2016 for Nature of business (SIC) “To be provided on next annual return”, was dissolved on 29 August 2017. Mr Voegt was appointed director on 24 March 2016.
Mr Voegt has only one active appointment in Companies House, out of a total of 24, this is to Associated Trading Limited. He was appointed at incorporation on 13 June 2018. The company provides activities of insurance agents and brokers and tax consultancy, the accounts are up to date. There are other officers who were appointed to Associated Trading Limited and these need to be included in this analysis, as well as his other interests, not yet considered. This analysis has not been undertaken here and remains outstanding.
Presently William Voegt is “certified and/or assessed”, by The Right Mortgage Limited, and qualified for Mortgage activities “Advising or arranging (bringing about) regulated mortgage contracts for a non-business purpose.” One director of The Right Mortgage Limited, Ben Allen, date of birth December 1980, was tested to see if he meets the standard for accountability by having only one identity in Companies House. Ben Allen failed this test because he has at least three identities registered in Companies House which has compromised all audits and due diligence associated to him since, at least, 5 July 2019, when he established his second identity. Earlier, if he has other identities not yet located or confirmed.
Testing for other “Moneyfarm” registrations in Companies House.
A search for Moneyfarm returned the following results, see image 11.
A search in Companies House on “Moneyfarm” returns three companies: one active company, Moneyfarm Limited; and two dissolved companies, Moneyfarm Ltd and The Moneyfarm Limited. The latter, has been described earlier, related to Mr Voegt. The variation in these three company names, by the use of “The” and “Ltd”, are insufficient to qualify these names as being different from one another. Company names are supposed to be unique to prevent, for example, contract switching between companies with the same name. The existence of three company numbers for the same company name is a red flag for potential money laundering.
The active company, Moneyfarm Limited, is described below (a), followed by a description of (b) Moneyfarm Ltd.
a. Moneyfarm Limited
MONEYFARM LIMITED 15057020 - Incorporated on 8 August 2023
Registered office address 4 Winsley Street, Fitzrovia, London, United Kingdom, W1W 8HF Company status Active Company type Private limited Company First accounts made up to 31 August 2024 due by 8 May 2025 Confirmation statement First statement date 7 August 2024 due by 21 August 2024
Nature of business (SIC):
64205 - Activities of financial services holding companies
64303 - Activities of venture and development capital companies
64304 - Activities of open-ended investment companies
66110 - Administration of financial markets
Moneyfarm Limited holds the business profile of a financial services holding company, unlike MFM Holding Ltd. Moneyfarm Limited was recently established, on 8 August 2023 and will not produce accounts until 8 May 2025. So, there is no means to hold them to account until then.
Turning to the directorship of Moneyfarm Limited:
MONEYFARM LIMITED people Company number 15057020
Officers:1 officer / 0 resignations
DONALD, Lucero Correspondence address 4 Winsley Street, Fitzrovia, London, United Kingdom, W1W 8HF Role ACTIVE Director Date of birth October 1995 Appointed on 8 August 2023 Nationality Armenian Country of residence United States Occupation Director
Clicking on the director, Lucero Donald’s name gives his other appointments, in this identity:
Lucero DONALD Total number of appointments 1 Date of birth October 1995
MONEYFARM LIMITED (15057020) Appointed on 8 August 2023 Nationality Armenian Country of residence United States Occupation Director
Moneyfarm Limited appears to be the only interest that Lucero Donald holds and there appear to be no associated parties.
However, a search on the name “Lucero Donald”, in Companies House, returns four identities with the same name and date of birth, see image 12.
Lucero Donald purports to be four people in Companies House, adapting the Financial Services definition, we can say he is a cloned person. This means that his interests are not audited as one, and this compromises all audits and due diligence associated to him, since he established his second identity. To see when that was, we need to look at the detail of his other three identities and their appointments.
Lucero Donald identity 1
Lucero Donald identity 1 Total number of appointments 1 Date of birth October 1995
CFTAI LIMITED (14866010) Company status Active Correspondence address 7 Copperfield Road, Coventry, West Midlands, England, United Kingdom, CV2 4AQ Role ACTIVE Director Appointed on 12 May 2023 Nationality American Country of residence United States Occupation Director
64303 - Activities of venture and development capital companies
66110 - Administration of financial markets
66300 - Fund management activities
70221 - Financial management
CFTAI LIMITED people 2 officers / 0 resignations
WINKIE CORPORATE SERVICES(UK) LIMITED Correspondence address 7 Copperfield Road, Coventry, West Midlands, England, United Kingdom, CV2 4AQ Role ACTIVE Secretary Appointed on 12 May 2023 Registration number 14410280
DONALD, Lucero Correspondence address 7 Copperfield Road, Coventry, West Midlands, England, United Kingdom, CV2 4AQ Role ACTIVE Director Date of birth October 1995 Appointed on 12 May 2023 Nationality American Country of residence United States Occupation Director
Winkie Corporate Services(UK) Limited is a corporate identity acting as secretary. By clicking on the name its appointments are listed (these are too numerous to list here):
WINKIE CORPORATE SERVICES(UK) LIMITED personal appointment
Current appointments 1261
Total number of appointments 1269
A company secretary is responsible for the statutory compliance obligations of a corporate entity. Because one corporate body, Winkie Corporate Services(UK) Limited, is providing this service to 1261 companies, which is a substantial number, the risk that there are conflicts of interest or mutual interests, between some or all of these companies, that are unmanaged, is very high. Secretarial control of so many companies raises the risk that Winkie Corporate Services(UK) Limited part of a control infrastructure that could be coordinating a cartel. This is the main risk associated with third party secretarial services and it is a weakness in current law.
CFTAI Limited and the Financial Conduct Authority
This business is set up with SIC codes; 64303 - Activities of venture and development capital companies, 66110 - Administration of financial markets, 66300 - Fund management activities, 70221 - Financial management. These are activities that are regulated and require registering with the Financial Conduct Authority, which publishes the Financial Services Register. A search in this register for CFTAI Limited and for Lucero Donald returns no listings.
Therefore, CFTAI Limited, a company registered in Companies House for financial services is not registered with the Financial Conduct Authority, when they should be. This is a red flag for potential fraud by CFTAI Limited.
Test to see if Winkie Corporate Services(UK) Limited holds multiple identities in Companies House
A search for Winkie Corporate returns 26 corporate identities with this name. Some have a space between “Services” and “(UK)”. Holding multiple identities breaches accountability principles, as it means that all of Winkie Corporate Services’ interests are unable to be considered together. Winkie Corporate Services(UK) Limited has 26 corporate identities and this breaches transparency and accountability requirements.
A registration number is provided for Winkie Corporate(UK) Limited, 14410280. Accessing the records for this company:
WINKIE CORPORATE SERVICES(UK) LIMITED Company number 14410280
Registered office address 7 Copperfield Road, Coventry, England, CV2 4AQ Company status Active Company type Private limited Company Incorporated on 11 October 2022 Accounts First accounts made up to 31 October 2023 due by 11 July 2024 Confirmation statement Next statement date 10 October 2024 due by 24 October 2024 Last statement dated 10 October 2023
Nature of business (SIC)
64209 - Activities of other holding companies not elsewhere classified
69203 - Tax consultancy
70229 - Management consultancy activities other than financial management
82990 - Other business support service activities not elsewhere classified
WINKIE CORPORATE SERVICES(UK) LIMITED people 2 officers / 0 resignations
ONESTEP CS (UK) LIMITED Correspondence address Unit 1804, South Bank Tower, 55 Upper Ground, London, England, SE1 9EY Role ACTIVE Secretary Appointed on 11 October 2022 Registration number 14345101
LEE, Che Kwan Correspondence address 7 Copperfield Road, Coventry, England, CV2 4AQ Role ACTIVE Director Date of birth July 1968 Appointed on 11 October 2022 Nationality Hong Konger Country of residence China Occupation Company Director
WINKIE CORPORATE SERVICES(UK) LIMITED persons with significant control 1 active person with significant control / 0 active statements Mr Che Kwan Lee.
Che Kwan Lee has just one appointment and one identity.
A quick look at Onestep CS (UK) Limited shows that this corporate body has two appointments:
Total number of appointments 2
WINKIE CORPORATE SERVICES(UK) LIMITED (14410280) Company status Active Correspondence address Unit 1804, South Bank Tower, 55 Upper Ground, London, England, SE1 9EY Role ACTIVE Secretary Appointed on 11 October 2022 Registration number14345101
TIMQONG LTD (14412124) Company status Active Correspondence address Unit 1804,,(sic) South Bank Tower,, (sic) 55 Upper Ground,, (sic)London (sic) England, United Kingdom, SE1 9EY Role ACTIVE Secretary Appointed on 11 October 2022 Registration number 14345101
Note the double comas, used for the registration of Timqong Ltd. If you were to describe the variance from the normal, this occurs in rows 1, 2 and 3 and row 4 has no coma between London and England. From my Systems Engineering experience I’m aware that in trafficking supply chains, this address carries codes of, for example, of 12340, which is understood by complicit secretaries, directors, delivery agents and customs officers. The double comas also induce non-match errors, and are a technique for concealing an interest to enable money-laundering, tax evasion and trafficking crime.
The mistakes in the correspondence address of Timqong Ltd are a red flag for money-laundering, tax evasion and trafficking crime.
Clicking on Timqong Ltd officers page, shows there is one director:
HONG, Tianqiang, Correspondence address 18 Edgington Close, Cotgrave, Nottingham, England, NG12 3NW Role ACTIVE Director Date of birth November 1974 Appointed on 11 October 2022 Nationality Chinese Country of residence China.
Tianqiang Hong has no other appointments and this is, correctly, the only identity registered with this name.
Recap of Lucero Donald identity 1
Lucero Donald identity 1 holds an active directorship to CFTAI Limited (14866010) appointed on 12 May 2023, established with four financial services codes 64303 - Activities of venture and development capital companies 66110 - Administration of financial markets 66300 - Fund management activities, 70221 - Financial management. The secretary of this company is Winkie Corporate Services(UK) Limited which is active in 1261 companies. The risk that there are conflicts of interest or mutual interests that are unmanaged is very high and it is possible that Winkie is coordinating a cartel. This is more likely given that Winkie Corporate Services(UK) Ltd holds over 20 corporate identities in Companies House. Holding multiple identities breaches accountability principles, as it means that all of Winkie Corporates’ interests are unable to be considered together.
The company associated to this corporate identity, Winkie Corporate(UK) Limited, was incorporated on 11 October 2022 and its first accounts are not due until 11 July 2024. It gives it nature of business as “Activities of other holding companies not elsewhere classified, tax consultancy, management consultancy activities other than financial management and other business support service activities not elsewhere classified”. Winkie Corporate Services(UK)Limited has 2 officers, a secretary, Onestep CS (UK) Limited and a resident of China, nationality “Hong Konger”, Che Kwan Lee whose date of birth is July 1968. He’s the person with significant control, this is his only interest and identity registered in Companies House.
The secretary of Winkie Corporate Services(UK)Limited, Onestep CS (UK) Limited, holds a second appointment, to Timquong Ltd, which is registered with an irregular address, using and omitting commas, a modification that causes non-match errors, which compromise. Deliberate errors, such as these, are a technique for concealing an interest to enable money-laundering, tax evasion and associated crime.
Timqong Ltd has one director Tianqiang HONG, whose nationality is Chinese and is resident in China. Tianqiang Hong has no other appointments and this is the only identity registered with this name.
Summary of identity 1
Lucero Donald identity 1 holds one directorship of CFTAI Limited, appointed on 12 May 2023, a company set up for financial services. Scam Detectors flag this company app as “very suspicious”. The secretary, Winkie Corporate Services(UK) Limited spans 1261 companies with this identity and has more than 20 identities which hold appointments concealed from audit software. Winkie Corporate Services(UK) Limited has one director, Che Kwan Lee, date of birth July 1968, who is resident in China with nationality as Hong Konger. Onestep CS (UK) Limited is secretary to Winkie Corporate Services(UK) Limited and Timquong Ltd which is directed by Tianqiang HONG who is Chinese and resident in China.
Lucero DONALD identity 2
Active director Correspondence address Floor 1, Office 25, 22 Market Square, London, United Kingdom, E14 6BU Nationality American Country of residence United States Occupation Director
PTS.NM LTD (14567627) Appointed on 3 January 2023 Incorporated on 3 January 2023 Nature of business (SIC)
64301 - Activities of investment trusts
64303 - Activities of venture and development capital companies
64304 - Activities of open-ended investment companies
PTS.NM LTD people 1 officer / 0 resignations Lucero Donald PTS.NM LTD persons with significant control 1 active Mr Lucero Donald
SMART WIND TURBINES NEW ENERGY LTD (14526259) Appointed on 7 December 2022 Incorporated on 7 December 2022 Nature of business (SIC)
35110 - Production of electricity
35140 - Trade of electricity
42220 - Construction of utility projects for electricity and telecommunications
SMART WIND TURBINES NEW ENERGY LTD people 1 officer / 0 resignations Lucero Donald SMART WIND TURBINES NEW ENERGY LTD persons with significant control 1 active Mr Lucero Donald
FUTURE AI INTELLIGENT TECHNOLOGY CO., LTD. (14497906) Appointed on 22 November 2022 Incorporated on 22 November 2022 Confirmation statement overdue Nature of business (SIC)
64205 - Activities of financial services holding companies
66110 - Administration of financial markets
FUTURE AI INTELLIGENT TECHNOLOGY CO., LTD. people 1 officer / 0 resignations Lucero Donald FUTURE AI INTELLIGENT TECHNOLOGY CO., LTD. persons with significant control 1 active Mr Lucero Donald
BE INDUSTRIAL CO., LTD (14453881) Appointed on 31 October 2022. Incorporated on 31 October 2022
Nature of business (SIC)
24520 - Casting of steel
25110 - Manufacture of metal structures and parts of structures
25620 - Machining
29320 - Manufacture of other parts and accessories for motor vehicles
BE INDUSTRIAL CO., LTD people 1 officer / 0 resignations Lucero Donald BE INDUSTRIAL CO., LTD persons with significant control 1 active Mr Lucero Donald.
Summary of identity 2
Donald Lucero identity 2 gives his nationality as American and country of residence United States and holds four active appointments to four companies. He is the sole director and person with significant control. Chronologically, these are:
Be Industrial Co., Ltd, incorporated on 31 October 2022, nature of business (SIC); Casting of steel, Manufacture of metal structures and parts of structures, Machining and Manufacture of other parts and accessories for motor vehicles.
Future AI Intelligent Technology Co., Ltd, incorporated on 22 November 2022, its confirmation statement is overdue. Nature of business (SIC) Activities of financial services holding companies; Administration of financial markets.
Smart Wind Turbines New Energy Ltd, incorporated on 7 December 2022. Nature of business (SIC) Production of electricity, Trade of electricity and Construction of utility projects for electricity and telecommunications.
PTS.NM LTD, incorporated on 3 January 2023. Nature of business (SIC)Activities of investment trusts, Activities of venture and development capital companies, Activities of open-ended investment companies.
Donald Lucero identity 3
Total number of appointments 1 Date of birth October 1995
VENUS FINANCIAL MANAGEMENT LTD (14852147) Appointed on 8 May 2023 Nationality American Country of residence United States 8 May 2023
Nature of business (SIC)
64303 - Activities of venture and development capital companies
66110 - Administration of financial markets
66300 - Fund management activities
70221 - Financial management
2 officers / 0 resignations
WINKIE CORPORATE SERVICES (UK) LIMITED Role ACTIVE Secretary Appointed on 8 May 2023
Current appointments 377 Total number of appointments 380
(One example expanded upon)
MORGAN FINANCIAL GLOBAL LIMITED people
2 officers / 0 resignations
WINKIE CORPORATE SERVICES (UK) LIMITED Secretary Appointed on 30 June 2023 Registration number14410280
FAN, Jun Director Date of birth March 1997 Appointed on 30 June 2023 Nationality Chinese Country of residence China Occupation Director
A search on “Morgan Financial Global” returns several companies using the name “Morgan Financial” with which this company could be confused with, for the purposes of deception, eg MORGAN FINANCIAL GROUP LTD or MORGAN FINANCIAL SOLUTIONS LIMITED.
Summary of identity 3.
Lucero Donald’s identity 3 holds one directorship to Venus Financial Management Ltd appointed at incorporation on 8 May 2023. Nature of business (SIC): Activities of venture and development capital companies, Administration of financial markets, Fund management activities and Financial management. The Secretary is a second identity WINKIE CORPORATE SERVICES (UK) LIMITED with a space between Services and (UK). This identity has 377 current appointments out of a total number of appointments of 380. One example of these interests was selected at random Morgan Financial Global Limited, the director of this company is Jun FAN, date of birth March 199, appointed on 30 June 2023, nationality Chinese and country of residence China.
A search on “Morgan Financial Global” returns several companies using the name “Morgan Financial” with which this company could be confused with, for the purposes of deception, eg MORGAN FINANCIAL GROUP LTD or MORGAN FINANCIAL SOLUTIONS LIMITED.
Observations
Lucero Donald’s company Moneyfarm Limited was incorporated on 8 August 2023, the accounts aren’t due until by 8 May 2025, so it will not be held to account for another 18 months (written December 2023). Moneyfarm Limited is established with the SIC codes that are usual for a financial services holding company with additional powers enabling activities of venture and development capital companies, open-ended investment companies and administration of funds. These are the SIC codes that I had anticipated that MFM Holding Ltd would have, rather than the administrative activities SIC code that it has.
There is only one director of Moneyfarm Limited and that is Lucero Donald. He states that he is Armenian, resident in the States and holds no other appointments. However, a search on the name “Lucero Donald”, in Companies House, returns four identities with the same name and date of birth, which means that all audits associated to him are compromised. His nationality in the other three identities is given as American. His other identities hold active directorships of recently established businesses with a range of business SIC codes.
Lucero Donald identity 1 holds one directorship of CFTAI Limited, for financial services. The secretary, Winkie Corporate Services (UK) Limited spans 1261 companies with this identity and has more than 20 identities. Winkie Corporate Services(UK) Limited has one director, Che Kwan Lee, date of birth July 1968, who is resident in China with nationality as Hong Konger. Onestep CS (UK) Limited is the secretary of Winkie Corporate Services(UK) Limited and Timquong Ltd which is directed by Tianqiang HONG who is Chinese and resident in China.
Donald Lucero identity 2 gives his nationality as American and country of residence United States and holds four active appointments. These are, chronologically:
Be Industrial Co., Ltd, incorporated on 31 October 2022, nature of business (SIC); Casting of steel, Manufacture of metal structures and parts of structures, Machining and Manufacture of other parts and accessories for motor vehicles.
Future AI Intelligent Technology Co., Ltd, incorporated on 22 November 2022, its confirmation statement is overdue. Nature of business (SIC) Activities of financial services holding companies; Administration of financial markets.
Smart Wind Turbines New Energy Ltd, incorporated on 7 December 2022. Nature of business (SIC) Production of electricity, Trade of electricity and Construction of utility projects for electricity and telecommunications.
PTS.NM LTD, incorporated on 3 January 2023. Nature of business (SIC)Activities of investment trusts, Activities of venture and development capital companies, Activities of open-ended investment companies.
Lucero Donald’s identity 3 holds one directorship to Venus Financial Management Ltd appointed at incorporation on 8 May 2023. Nature of business (SIC): Activities of venture and development capital companies, Administration of financial markets, Fund management activities and Financial management. The Secretary is a second identity Winkie Corporate Services (UK) Limited. This identity has 377 current appointments out of a total number of appointments of 380. One example of these interests was selected at random Morgan Financial Global Limited, the director of this company is Jun FAN, date of birth March 199, appointed on 30 June 2023, nationality Chinese and country of residence China.
A search on “Morgan Financial Global” returns several companies using the name “Morgan Financial” with which this company could be confused with, for the purposes of deception, eg Morgan Financial Group Ltd.
Conclusion
Moneyfarm Limited has one director, Lucero Donald, who has no other appointments associated to this identity. However, a search in Companies House revealed that he has three more identities (named identities 1-3). Concealed in the other three identities are active directorships of six companies registered with a range of powers.
Lucero Donald identity 2 was the first to be established in Companies House for appointments to:
Be Industrial Co., Ltd, incorporated on 31 October 2022 (steel manufacturing)
Future AI Intelligent Technology Co., Ltd, incorporated on 22 November 2022 (financial services)
Smart Wind Turbines New Energy Ltd, incorporated on 7 December 2022 (electricity production and telecommunication construction)
PTS.NM LTD, incorporated on 3 January 2023. (venture capital)
Lucero Donald identity 3 was established second, for an appointment to Venus Financial Management Ltd, incorporation on 8 May 2023 (venture capital fund management). The result of the creation of this second identity is that all audits, due diligence, contracts and transactions associated with Lucero Donald and his companies are compromised since 8 May 2023.
Lucero Donald identity 1 was established third, to CFTAI Limited, incorporated on 12 May 2023 (financial services).
Lucero Donald identity 4 was the most recent identity to be established for the appointment to Moneyfarm Limited, incorporated on 8 August 2023 (financial services holding company).
The Secretary is a second identity Winkie Corporate Services (UK) Limited. This identity has 377 current appointments out of a total number of appointments of 380. One example of these interests was selected at random Morgan Financial Global Limited, the director of this company is Jun FAN, date of birth March 199, appointed on 30 June 2023, nationality Chinese and country of residence China.
A search on “Morgan Financial Global” returns several companies using the name “Morgan Financial” with which this company could be confused with, for the purposes of deception, eg Morgan Financial Group Ltd.
The secretary of CFTAI Limited, Winkie Corporate Services(UK) Limited spans 1261 companies with this identity and has more than 20 identities. Winkie Corporate Services(UK) Limited has one director, Che Kwan Lee, date of birth July 1968, who is resident in China with nationality as Hong Konger. Onestep CS (UK) Limited is the secretary of the companies Winkie Corporate Services(UK) Limited and Timquong Ltd, which is directed by Tianqiang HONG who is Chinese and resident in China.
There is a high risk that Lucero Donald’s interests conflict with the public’s best interest. This is amplified by the risk of impersonation of “Moneyfarm” that his company Moneyfarm Limited presents.
Moneyfarm Limited is also a contender for impersonating “Moneyfarm”.
b. Moneyfarm Ltd
MONEYFARM LTD 10640757 - Dissolved on 14 November 2017 11 Holmesdale Avenue 11 Holmesdale Avenue,, (sic) Redhill, Surrey, United Kingdom, RH1 2PB
Company Overview for MONEYFARM LTD (10640757) Registered office address 11 Holmesdale Avenue 11 Holmesdale Avenue, Redhill, Surrey, United Kingdom, RH1 2PB Company status Dissolved Dissolved on 14 November 2017 Company type Private limited Company Incorporated on 27 February 2017 Nature of business (SIC) 70229 - Management consultancy activities other than financial management
People for MONEYFARM LTD (10640757) 1 officer / 0 resignations
SABRI, Hasan Souat Hilmi Correspondence address 11 Holmesdale Avenue, 11 Holmesdale Avenue,, (sic) Redhill, Surrey, United Kingdom, RH1 2PB Role Director Date of birth March 1963 Appointed on 27 February 2017 Occupation Management Consultant. Sole persons with significant control.
Hasan Souat Hilmi SABRI personal appointments:
Total number of appointments 6 Date of birth March 1963
MONEYFARM LTD (10640757) Company status Dissolved Correspondence address 11 Holmesdale Avenue, 11 Holmesdale Avenue,, (sic) Redhill, Surrey, United Kingdom, RH1 2PB Role Director Appointed on 27 February 2017 Nationality British Country of residence United Kingdom Occupation Management Consultant Incorporated on 27 February 2017 Dissolved on 14 November 2017
GKAM LLP (OC386311) Company status Dissolved Correspondence address Gkfx Bevis Marks House, Second Floor, 24 Bevis Marks, London, United Kingdom, EC3A 7JB Role RESIGNED LLP Designated Member Appointed on 1 February 2016 Resigned on 10 October 2016 Country of residence United Kingdom
MFM INVESTMENT LTD (09088155) Company status Active Correspondence address Techhub, 4 - 5 Bonhill Street, London, England, ECA 4BX Role RESIGNED Director Appointed on 16 June 2014 Resigned on 22 January 2016 Nationality British Country of residence United Kingdom Occupation Coo
KNIGHT ASSETS & CO. LLP (OC362713) Company status Dissolved Correspondence address 100 Pall Mall, St James, London, Greater London, SW1Y 5NQ Role RESIGNED LLP Designated Member Appointed on 14 March 2011 Resigned on 20 June 2014 Country of residence United Kingdom
EQUAL PROPERTY PORTFOLIO LIMITED (08532845) Company status Dissolved Correspondence address 11 Holmesdale Avenue, Redhill, Surrey, United Kingdom, RH1 2PB Role RESIGNED Director Appointed on 16 May 2013 Resigned on 16 May 2013 Nationality British Country of residence United Kingdom Occupation Investment Banker
EQUAL CONSULTING LIMITED (06967753) Company status Dissolved Correspondence address 11 Holmesdale Avenue, Redhill, Surrey, United Kingdom, RH1 2PB Role RESIGNED Director Appointed on 21 July 2009 Resigned on 28 October 2009 Nationality British Country of residence United Kingdom Occupation Director
If I had started this due diligence with the interests of the directors of MFM Investment Ltd, then I would have come across Moneyfarm Ltd earlier.
Hasan Souat Hilmi SABRI was appointed as a director of MFM Investment Ltd on 16 June 2014 and he resigned on 22 January 2016. He gives his occupation as Coo, which typically stands for Chief Operating Officer. He established Moneyfarm Ltd as a sole director on 27 February 2017 for 70229 - Management consultancy activities other than financial management and it was dissolved on 14 November 2017. If there are still active accounts in this company’s name, then this could be another route for impersonation of MFM Investment Ltd, also known as “Moneyfarm”.
Testing for multiple identities for Hasan SABRI in Companies House, a search was made on this name. Five identities are returned, three with his date of birth, March 1963 and two, that use the same address with date of birth June 2006. Since these are the only instances of these names there is a high degree of probability that these are familiarly related and should be considered as a related party. The summary of these five identities is below, followed by the detail.
Hasan SABRI (Identity 1)
Total number of appointments 1 - Born March 1963 10 Norwich Street London, United Kingdom, EC4A 1BD
Hasan SABRI (Identity 2)
Total number of appointments 1 - Born March 1963 12 Rockfield Close, Oxted, RH8 0DN
Hasan Souat Hilmi SABRI (Identity 3)
Total number of appointments 5 - Born March 1963 11 Holmesdale Avenue, 11 Holmesdale Avenue,, (sic) Redhill, Surrey, United Kingdom, RH1 2PB
Hasan Sabri COREKCIOGLU (Related? Identity1)
Total number of appointments 1 - Born June 2006 71-75, Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Hasan Sabri COREKCIOGLU (Related? Identity 2)
Total number of appointments 1 71-75, Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
This list of of identities are reproduced below with the detail of the appointments added:
Hasan SABRI identity 1
Total number of appointments 1 - Born March 1963
TABULA INVESTMENT MANAGEMENT LIMITED (11286661) Company status Active Correspondence address 10 Norwich Street, London, United Kingdom, EC4A 1BD Role RESIGNED Director Appointed on 3 April 2018 Resigned on 19 December 2018 Nationality British Country of residence United Kingdom Occupation Director Company type Private limited Company Incorporated on 3 April 2018 Accounts Next accounts made up to 31 December 2022 due by 31 December 2023 Last accounts made up to 31 December 2021 Nature of business (SIC) 66300 - Fund management activities
Hasan SABRI identity 2
Total number of appointments 1 - Born March 1963
NOVUS CAPITAL MARKETS LIMITED (05473481) Company status Liquidation Correspondence address 12 Rockfield Close, Oxted, RH8 0DN
Role RESIGNED Director Appointed on 19 September 2005 Resigned on 19 December 2005 Nationality British Occupation Chief Operating Officer Company type Private limited Company Incorporated on 7 June 2005 Accounts overdue Next accounts made up to 31 March 2018 due by 31 December 2018 Last accounts made up to 31 March 2017 Confirmation statement overdue Next statement date 7 June 2019 due by 21 June 2019 Last statement dated 7 June 2018 Nature of business (SIC) 66120 - Security and commodity contracts dealing activities 1 Insolvency case Case number 1 — Creditors voluntary liquidation Commencement of winding up 3 September 2018 Due to be dissolved on 24 January 2024 Practitioner Hugh Francis Jesseman 3 Field Court, Grays Inn, London, WC1R 5EF Appointed on 3 September 2018. Hugh Francis Jesseman - has 2 identities registered in Companies House which corrupts all audits and due diligence associated to him. Hugh Jesseman requires investigation also.
Hasan Souat Hilmi SABRI identity 3
Total number of appointments 5 - Born March 1963
11 Holmesdale Avenue, 11 Holmesdale Avenue,, Redhill, Surrey, United Kingdom, RH1 2PB. (Summarised from the detail given above. This was the first identity we encountered)
MONEYFARM LTD (10640757) Company status Dissolved Correspondence address 11 Holmesdale Avenue, 11 Holmesdale Avenue,, (sic) Redhill, Surrey, United Kingdom, RH1 2PB Role Director Appointed on 27 February 2017 Occupation Management Consultant Incorporated on 27 February 2017 Dissolved on 14 November 2017
GKAM LLP (OC386311) Company status Dissolved Correspondence address Gkfx Bevis Marks House, Second Floor, 24 Bevis Marks, London, United Kingdom, EC3A 7JB Role RESIGNED LLP Designated Member Appointed on 1 February 2016 Resigned on 10 October 2016
MFM INVESTMENT LTD (09088155) Company status Active Correspondence address Techhub, 4 - 5 Bonhill Street, London, England, ECA 4BX Role RESIGNED Director Appointed on 16 June 2014 Resigned on 22 January 2016 Occupation Coo
KNIGHT ASSETS & CO. LLP (OC362713) Company status Dissolved Correspondence address 100 Pall Mall, St James, London, Greater London, SW1Y 5NQ Role RESIGNED LLP Designated Member Appointed on 14 March 2011 Resigned on 20 June 2014
EQUAL PROPERTY PORTFOLIO LIMITED (08532845) Company status Dissolved Correspondence address 11 Holmesdale Avenue, Redhill, Surrey, United Kingdom, RH1 2PB Role RESIGNED Director Appointed on 16 May 2013 Resigned on 16 May 2013 Occupation Investment Banker
EQUAL CONSULTING LIMITED (06967753) Company status Dissolved Correspondence address 11 Holmesdale Avenue, Redhill, Surrey, United Kingdom, RH1 2PB Role RESIGNED Director Appointed on 21 July 2009 Resigned on 28 October 2009
Hasan Sabri COREKCIOGLU related? Identity 1
Total number of appointments 1 - Born June 2006
HASANBELIKE LTD (15128874) Company status Active Correspondence address 71-75, Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ Role ACTIVE Director Appointed on 11 September 2023 Nationality Turkish Country of residence Turkey Occupation Marketing Private limited Company Incorporated on 11 September 2023 Accounts First accounts made up to 30 September 2024 due by 11 June 2025 Confirmation statement First statement date 10 September 2024 due by 24 September 2024 Nature of business (SIC) 47910 - Retail sale via mail order houses or via Internet
Hasan Sabri COREKCIOGLU related? Identity 2
Total number of appointments 1
71-75, Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
HASANBELIKE LTD (15128874) Company status Active Correspondence address 71-75, Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ Role ACTIVE Secretary Appointed on 11 September 2023
Chronology of Hasan Sabri, born March 1963; three identities in Companies House
Mr Sabri registered his first identity Hasan SABRI (called identity 2, above) for his appointment to NOVUS CAPITAL MARKETS LIMITED (05473481), a company which is in liquidation. He was appointed on 19 September 2005 and resigned on 19 December 2005. Novus Capital Markets Limited was incorporated on 7 June 2005 and is due to be dissolved on 24 January 2024. The accounts are overdue, the last accounts presented were made up to 31 March 2017. The Confirmation statement has been overdue since 21 June 2019. Nature of business (SIC) 66120 - Security and commodity contracts dealing activities
Novus Capital Markets Limited commenced winding up 3 September 2018 due to Creditors voluntary liquidation. The Practitioner, Hugh Francis Jesseman 3 Field Court, Grays Inn, London, WC1R 5EF was appointed on 3 September 2018. Hugh Francis Jesseman - has 2 identities registered in Companies House which corrupts all audits and due diligence associated to him. Hugh Jesseman requires investigation also.
The second identity he established, Hasan Souat Hilmi SABRI, born March 1963 (identity 3, above) holds five appointments and uses a correspondence address with two errors, “11 Holmesdale Avenue, 11 Holmesdale Avenue,, (sic, sic)”, repetition of the first line with an additional comma. This is a red flag for money laundering enabled by non-match errors caused by these errors and for being a code enabling trafficking. In chronological order this identity was used for the following appointments:
EQUAL CONSULTING LIMITED (06967753) Company status Dissolved Appointed on 21 July 2009 Resigned on 28 October 2009
EQUAL PROPERTY PORTFOLIO LIMITED (08532845) Company status Dissolved RESIGNED Director Appointed on 16 May 2013 Resigned on 16 May 2013 Occupation Investment Banker
KNIGHT ASSETS & CO. LLP (OC362713) Company status Dissolved RESIGNED LLP Designated Member Appointed on 14 March 2011 Resigned on 20 June 2014
MFM INVESTMENT LTD (09088155) Company status Active Role RESIGNED Director Appointed on 16 June 2014 Resigned on 22 January 2016 Occupation Coo GKAM LLP (OC386311) Company status Dissolved Appointed on 1 February 2016 Resigned on 10 October 2016
MONEYFARM LTD (10640757) Company status Dissolved Correspondence address 11 Holmesdale Avenue, 11 Holmesdale Avenue,, (sic, sic) Redhill, Surrey, United Kingdom, RH1 2PB Role Director Appointed on 27 February 2017 Occupation Management Consultant Incorporated on 27 February 2017 Dissolved on 14 November 2017
Mr Sabri established his third identity Hasan SABRI (called identity 1 above) for one appointment to TABULA INVESTMENT MANAGEMENT LIMITED (11286661) which is an active company. He was appointed on 3 April 2018 and resigned on 19 December 2018. The next accounts made up to 31 December 2022 are due by 31 December 2023. Tabula Investment Management was established with nature of business (SIC) 66300 - Fund management activities.
Comments on Hasan Sabri
Mr Sabri registered his first identity Hasan SABRI (called identity 2, above) for his appointment to NOVUS CAPITAL MARKETS LIMITED (05473481). He was a director for three months, only, in 2005, the year it was established for Security and commodity contracts dealing activities. Novus Capital Markets Limited is due to be dissolved on 24 January 2024. The accounts are overdue, the last accounts presented were made up to 31 March 2017. Novus Capital Markets Limited commenced winding up 3 September 2018 due to creditors’ voluntary liquidation. The Practitioner, Hugh Francis Jesseman - has 2 identities registered in Companies House which corrupts all audits and due diligence associated to him. Hugh Jesseman requires investigation.
The second identity Hasan Souat Hilmi SABRI established was for his 3 month appointment to Equal Consulting Limited, from 21 July 2009 to 28 October 2009. By establishing this second identity Mr Sabri has compromised audits associated to his since 21 July 2009. Mr Sabri uses a correspondence address with two errors that are a red flag for money laundering enabled by non-match errors, caused by these differences, and for being a code, enabling signalling to traffickers along the supply chain. In chronological order this identity was used for the following appointments:
EQUAL CONSULTING LIMITED Dissolved Appointed on 21 July 2009 Resigned on 28 October 2009 (3 months)
EQUAL PROPERTY PORTFOLIO LIMITED Dissolved Director Appointed on 16 May 2013 Resigned on 16 May 2013 Investment Banker (1 day)
KNIGHT ASSETS & CO. LLP Dissolved RESIGNED LLP Designated Member Appointed on 14 March 2011 Resigned on 20 June 2014 (3 months)
MFM INVESTMENT LTD Active Role RESIGNED Director Appointed on 16 June 2014 Resigned on 22 January 2016 Occupation Coo (1 year 7 months)
GKAM LLP Dissolved Appointed on 1 February 2016 Resigned on 10 October 2016 (8 months)
MONEYFARM LTD (10640757) Dissolved Director Appointed on 27 February 2017 Occupation Management Consultant Incorporated on 27 February 2017 Dissolved on 14 November 2017 (9 months)
Mr Sabri’s second identity has been used for a series of very short appointments, from one day to 9 months, and one longer appointment to MFM Investment Ltd from 16 June 2014 to 22 January 2016. He established Moneyfarm Ltd on 27 February 2017 and dissolved it 9 months later. No accounts were provided. This appears to be a vehicle that he established, acting alone. This registration would have enabled him to establish bank and trade accounts in the name Moneyfarm Ltd. Since he had resigned as a director of MFM Investment Ltd, which uses the copyright name “Moneyfarm”, a year before establishing Moneyfarm Ltd, he knowingly established a company using the copyright name of his previous interest. Establishing Moneyfarm Ltd enabled him to open trade and bank accounts in this name, which are potentially still in use.
Hasan Sabri’s registration of Moneyfarm Ltd on 27 February 2017 could have been with the permission of directors of MFM Investment Ltd, or not. If it is with their permission then this is another source for “off balance sheet” transactions and money laundering by MFM Investment Ltd. If it was without the permission of the directors of MFM Investment Ltd, then, I conclude that this company was established by Hasan Sabri for the purpose of impersonation of “Moneyfarm”.
Mr Sabri established his third identity Hasan SABRI (called identity 1 above) for one appointment to TABULA INVESTMENT MANAGEMENT LIMITED (11286661) which is an active company. He was appointed on 3 April 2018 and resigned on 19 December 2018. Tabula Investment Management Limited was established with nature of business (SIC) 66300 - Fund management activities. This requires further analysis.
Conclusion related to Hasan Sabri, MFM Investment Ltd and Moneyfarm Ltd.
Hasan Sabri was a director of MFM Investment Ltd 16 June 2014 to 22 January 2016 and he established Moneyfarm Ltd on 27 February 2017 and it was dissolved on 14 November 2017. Mr Sabri was already compromised, because he had established a second identity in Companies House on 21 July 2009.
I conclude that Mr Sabri’s firm, Moneyfarm Ltd, has potential to be another clone firm of MFM Investment Ltd. It was established, either with or without the permission of the directors of MFM Investment Ltd. Mr Sabri created a third identity for his appointment to Tabula Investment Management Limited on 3 April 2018. This compromises the audit of this company for the time he was active, from 3 April 2018 to 19 December 2018, and in my opinion associated accounts should be re-audited, taking his interest in “Moneyfarm” and Moneyfarm Ltd into account.
Conclusion: Dame Jayne-Anne Gadhia “Money farm” and systematic clone company fraud
Dame Jayne-Anne established her second identity (identity 9, in my report) on 12 March 2007, for an appointment as a director of Virgin Money Holdings (UK ) Limited. Previous to this, all of her interests were held in one identity (identity 11, in my report), including an earlier appointment to Virgin Money Holding (UK) Limited.
Given Dame Jayne-Anne’s role as chair of HMRC, these breaches require that she is investigated for this fraud by false representation (section 2), fraud by failing to disclose information (section 3) and for potential fraud by abuse of position (Section 4). The scale of the fraud is defined as the sum of the total annual finances of all the companies of which she has been a director since 12 March 2007 to date.
There are only four other identities registered in Companies House with the name Ghadia. These are:
Rajnikant GHADIA Total number of appointments 0 - Born December 1956 6 Deans Drive, Stanmore, Middlesex, United Kingdom, HA7 1HD
Rakesh GHADIA Total number of appointments 0 125 Moseley Avenue, Coventry, CV6 1HS
Tushar GHADIA Total number of appointments 1 - Born March 1982 17 Bryanston Square, London, United Kingdom, W1H 2DP
Rai GHADIA Total number of appointments 1 EDWARD FINK, 12 Cornwall Gardens, London, United Kingdom, United Kingdom, SW7 4AN
Disclosure by Jayne-Anne Gadhia / Ghadia of her related parties is requested.
Summary
“Moneyfarm” is:
the copyright name of MFM Investment Ltd,
the name that Dame Jayne-Anne declares in her biography,
the name of three companies called Moneyfarm Limited, Moneyfarm Ltd and The Moneyfarm Ltd, which are essentially the same name, and
the name of two dissolved companies that were previously called The Money Farm Limited.
Risk of Moneyfarm Limited impersonating “Moneyfarm”.
Dame Jayne-Anne Gadhia declares that she is a director of “Moneyfarm” in her biography without specifying that this is a copyright name of MFM Investment Limited, which is controlled by MFM Holding Ltd, of which she is also a director.
In Companies House there is one active company with the name Moneyfarm Limited and two dissolved companies with essentially the same name, The Moneyfarm Limited and Moneyfarm Ltd. This repetition of names should not occur in Companies House since names are supposed to be unique and “the” and “Ltd” are excluded from being validly different.
There is a risk that confusion between “Moneyfarm” and Moneyfarm Limited. This could enable authorisation of a transaction that should have been denied.
Although the name “Moneyfarm” carries a copyright, Moneyfarm Limited is not necessarily associated to MFM Investment Ltd and its holding company MFM Holding Ltd. If the bank accounts of the two dissolved companies with this name are still active, which must be tested, then, the existence of Moneyfarm Limited and two dissolved companies called The Moneyfarm Limited and Moneyfarm Ltd and two companies both previously called The Money Farm Limited, introduces a potential fivefold risk of fraud by impersonation of MFM investments Ltd.
If, however, any of Moneyfarm Limited, The Moneyfarm Limited, Moneyfarm Ltd, The Money Farm Limited company 1 or The Money Farm company 2, are connected with MFM Investment Ltd or MFM Holding Ltd, and this has not been made transparent in the accounts, then any, or all, of these companies could provide a vehicle for “off-balance sheet transactions” for MFM Investment Ltd and MFM Holding Ltd. This is a red flag for being a corporate infrastructure to enable money laundering.
There are additional company names that need to be tested for their potential to be impersonating “Moneyfarm” eg MFM UK, MFM Investment, MFM Holding, MFM Group. Annex B contains a start of this, looking at MFM Futura Capital Ltd and director Alicia Carmen Mouriz Guerrero. This requires more analysis.
During this due diligence five potential clones of “Moneyfarm” were located. The directors, William Voegt, Lucero Donald and Hassan Sabri each have the opportunity to be able to impersonate “Moneyfarm”. A police investigation, using forensic audits, is advised. That Dame Jayne-Anne Gadhia / Ghadia is a director of this firm is a cause for serious concern given her role as Chari of HM Revenue and Customs. I request that she resigns with immediate effect, for her incorrect declaration in her register of interests and for registering multiple identities in Companies House concealing the true extent of her interests. I conclude that there is evidence that requires that a police investigation must commence.
Due diligence not yet begun:
3. The Tate.
4. Vanquis Bank.
5. Usnoop.
6. Jagash.
7. Gadhiagroup.
Annex A. Summary of Dame Jayne-Anne’s undeclared interests.
Dame Jayne-Anne has registered eleven identities in Companies House. This compromises audits associated to her. She fails to disclose:
Two active directorships held in Jayne-Anne GADHIA identity 1 to MFM INVESTMENT LTD, since 13 January 2023, and MFM HOLDING LTD since 23 November 2022.
One active directorship held in Jayne-Anne GADHIA identity 2 to JAGASH LTD since 20 September 2018, a company in liquidation.
One resigned directorship held in Jayne-Anne GADHIA identity 3 to THE PRINCE'S SCHOOL OF TRADITIONAL ARTS from1 September 2018 to 23 March 2021.
One resigned directorship held in Jayne-Anne GADHIA identity 4 to THE PRINCE'S FOUNDATION RESIGNED from 3 December 2015 to 23 March 2021.
Three directorships held in Jayne-Anne GADHIA identity 5; one active directorship to GADHIAGROUP LIMITED since 14 August 2018, and two resigned directorships to GADHIA CONSULTANTS LIMITED from January 2019 to 24 October 2019 and from 2 July 2020 to 30 September 2021.
One resigned directorship held in Jayne-Anne GADHIA identity 6 to
STAGECOACH GROUP LIMITED from 1 March 2019 to 31 July 2019.
One resigned directorship held in Jayne-Anne GADHIA identity 7 to UK FINANCE LIMITED from 1 July 2017 to 26 September 2018.
One resigned directorship held in Jayne-Anne GADHIA identity 8 to SCOTTISH BUSINESS IN THE COMMUNITY LIMITED from 7 November 2013 to 31 March 2017.
Two resigned directorships held in Jayne-Anne GADHIA identity 9 to
BUSINESS IN THE COMMUNITY from 28 April 2014 to 8 June 2015 and from 1 January 2016 to 8 February 2017.
One resigned directorship held in Jayne-Anne GADHIA identity 10 to THE BRITISH INSPIRATION TRUST from 1 May 2010 to 21 June 2011.
Nine resigned appointments held in Jayne-Anne GADHIA identity 11 to:
BANK AND CLIENTS PLC Liquidation from 27 January 2010 to 30 November 2014
SENTEBALE RESIGNED from 15 December 2008 to 17 November 2011
SAPPHIRE CARDS LIMITED from 20 March 2007 to 12 February 2009
LOMBARD HOME LOANS LIMITED from 21 February 2005 to 10 January 2007
THE ONE ACCOUNT LIMITED from 6 August 2001 to 10 January 2007
DIRECT LINE FINANCIAL SERVICES from 1 March 2005 to 10 January 2007
RE LIFE LIMITED from 21 September 1995 to 27 July 2001
CHALLENGER (NORWICH) LIMITED from 21 November 1997 to 27 July 2001
RE LIFE LIMITED Secretary from 21 September 1995 to 23 April 1997
There are several Virgin interests which are not disclose accurately. This includes directorships held in identity 9:
VIRGIN MONEY GIVING LIMITED from 6 December 2012 to 15 October 2018
VIRGIN MONEY UNIT TRUST MANAGERS LIMITED from 17 November 2016 to 15 October 2018
VIRGIN MONEY PERSONAL FINANCIAL SERVICE LIMITED from 28 December 2016 to 15 October 2018
Virgin interests which are not disclosed accurately in identity 11:
THE VIRGIN FOUNDATION from 8 July 2009 to 7 April 2012
VIRGIN MONEY GIVING LIMITED RESIGNED from 11 February 2009 to 23 February 2012
VIRGIN FINANCIAL SERVICES UK HOLDINGS LIMITED from 2 May 2008 to 16 December 2011
VIRGIN MONEY NOMINEES LIMITED from 21 April 1997 to 27 July 2001
VIRGIN MONEY MANAGEMENT SERVICES LIMITED from 11 January 1996 to 27 July 2001
VIRGIN MONEY PERSONAL FINANCIAL SERVICE LIMITED from 13 July 1995 to 23 April 1997
VIRGIN MONEY PERSONAL FINANCIAL SERVICE LIMITED from 13 July to 27 July 2001
VIRGIN MONEY UNIT TRUST MANAGERS LIMITED from 16 December 1994 to 27 July 2001
VIRGIN MONEY MANAGEMENT SERVICES LIMITED Secretary from 11 January 1996 to 27 June 1996.
The directorship held in identity 5 to USNOOP LIMITED from 30 January 2019 to 7 August 2023 is incorrectly declared as “Snoop” in Dame Jayne-Anne’s biography. This is evidence of obfuscation. Dame Jayne-Anne failed to declare Usnoop Limited. Instead she recorded “Usnoop” as “Snoop”, which is false representation that has a material impact on her transparency and accountability.
One identity spelt “Ghadia”, instead of “Gadhia”, Jayne-Anne GHADIA identity 12 holds a directorship to UniCredit S.P.A., over which Trustees of the Banca Di Roma Retirement Benefits Scheme Deutsche Bank Ag Abn Amro N.V. (The Beneficiary) are entitled. Dame Jayne-Anne fails to declare that she is a director of UNICREDIT S.P.A., since 15 April 2021, and she has used a different spelling of her name to register this interest in Companies House, this is evidence of obfuscation. Her directorship of Unicredit SPA represents a potential conflict of interest with her role at HMRC.
Annex B. MFM UK and MFM Futura Capital
In the company accounts, MFM Investment Ltd is referred to as MFM UK, regulated by the Financial Conduct Authority.
MFM UK is a third name by which “Moneyfarm”, is referenced. This creates an a risk, another route through which companies with similar names to Moneyfarm, MFM Investment Ltd and MFM UK, can impersonate this firm. It is also an additional route for directors to manage money laundering and tax evasion, if they are complicit with any of the companies that hold similar names.
A search in Companies House for MFM UK returns 7 companies that include this term, see image 7. During an audit of MFM Investment Ltd and MFM Holding Ltd, these companies require being tested to be ruled in or out as a source of impersonation or for handling related party transactions that are fraudulent. Note that just because a company is listed as dissolved, it does not mean that bank accounts, for example, have been closed. Bank accounts can remain active, particularly if a director did not resign before dissolution.
The search returns 7 companies that should be on the auditors “watch list” for related party transactions and impersonation:
MFMUK LTD, incorporated on 8 June 2023
MFM UK ENTERTAINMENT LTD, incorporated on 19 December 2022
MFM FUTURA CAPITAL UK LTD, dissolved on 12 September 2023
MFM HOLDINGS U.K. LTD, incorporated on 12 May 2023
MFM PROJECT UK CIC, incorporated on 19 September 2014
MFM GUARDS UK LIMITED dissolved on 22 January 2013
MFM MARKETING SOLUTIONS UK LIMITED dissolved on 18 January 2011.
For example, MFM Holdings U.K. Ltd, which was recently incorporated in 12 May 2023, is a name that is very similar to MFM Holding Ltd, and this could facilitate impersonation, with or without “Moneyfarm” directors’ complicity. Vigilance, such as this, is required by auditors and the Financial Conduct Authority.
Since “future” is “futuro” in Italian, there is a risk of either impersonation and, or, unethical collaboration between of MFM Future SRL and MFM Futura Capital UK Ltd, which was dissolved on 12 September 2023 (refer to image 7). Therefore MFM Futura Capital UK Ltd is described further, even though it is not proven that it is associated to MFM Holding Ltd.
MFM Futura Capital UK Ltd was incorporated on 23 July 2021 with nature of business (SIC) 62012 - Business and domestic software development and 64306 - Activities of real estate investment trusts. It was dissolved on 12 September 2023, no accounts for this company were produced. There were three officers appointed, two resigned, leaving one director active, when the company was dissolved, Carmen Alicia GUERRERO DOMINGUEZ, date of birth March 1990. Appointed on 5 July 2022, nationality Spanish, country of residence Spain.
A search in Companies House on the name Carmen Alicia Guerrero Dominguez returns only one identity. A search on the names “Carmen Guerrero” returns an unusual cluster of five identities at the top of the list with the same three names; Carmen, Guerro and Alicia, with three dates of birth.
Carmen Alicia GUERRERO DOMINGUEZ (0 appointments) - Born March 1990 Carlyle House, 235-237 Vauxhall Bridge Road, Lower Ground Floor…
MFM FUTURA CAPITAL UK LTD (13526613) Dissolved Director Appointed on 5 July 2022 Nationality Spanish Country of residence Spain
Carmen Alicia GUERRERO RANGEL (0 appointments) - Born May 1985 67 Flat 2, Axminster Road, London, England, N7 6BP CARMEN ALICIA LTD (11742450) Company status Dissolved Director Appointed on 27 December 2018 Nationality Venezuelan Country of residence England
a. Alicia Carmen MOURIZ GUERRERO (0 appointments) - Born September 1986 71-75 Shelton Street, London, Greater London, United Kingdom, WC2H 9JQ AWYREN LTD (11038496) Company status Dissolved Role Director Appointed on 30 October 2017 Nationality Spanish Country of residence United Kingdom
b. Alicia Carmen MOURIZ GUERRERO (0 appointments) 71-75 Shelton Street, London, Greater London, United Kingdom, WC2H 9JQ AWYREN LTD (11038496) Company status Dissolved Role Secretary Appointed on 30 October 2017
c. Alicia Carmen Mouriz GUERRERO (1 appointment) - Born September 1986 Uxbridge High School Academy Trust, The Greenway, Uxbridge, Middlesex, UB8 2PR. UXBRIDGE HIGH SCHOOL ACADEMY TRUST (07623418) Company status Active Role RESIGNED Director Appointed on
19 October 2015 Resigned on 4 April 2018 Nationality Spanish Country of residence United Kingdom Occupation Project Manager (Heathrow Airport)
Chronological summary
Alicia Carmen Mouriz Guerrero, born September 1986, established her first identity for an appointment as a director of Uxbridge High School Academy Trust, appointed on 19 October 2015, resigned on 4 April 2018. Her nationality is Spanish and country of residence, United Kingdom. Her occupation is given as “Project Manager (Heathrow Airport)”. She established two more identities on 30 October 2017, for two appointments to Awyren Ltd, one identity as director, and another identity as secretary. Holding two appointments in separate identities presents the opportunity to establish duplicate bank accounts for Awyren Ltd, one remaining concealed from the auditor and for tax evasion. Multiple identities are used to gain duplicate bank accounts and conceal interests for criminal purposes. This company is dissolved but there is a considerable risk that bank accounts may still be operating.
Carmen Alicia Guerrero Rangel, born May 1985, established Carmen Alicia Ltd on 27 December 2018. She was an active director when it dissolved. Her nationality is Venezuelan and country of residence is England. I query whether this is an example of Alicia Carmen Guerrero “reinventing” herself, as a limited company, with another bank account, with the name order changed to Carmen Alice.
Carmen Alicia Guerrero Dominiguez, born in March 1990 and was director of MFM Futuro Capital UK Ltd, appointed on 5 July 2022, she was active when it was dissolved on 12 September 2023. Her nationality is Spanish and country of residence is Spain. There is a considerable risk associated to MFM Futuro Capital UK Ltd impersonating MFM Future S.R.L., particularly if bank accounts are still active in this company name.
If these are three distinct people, then it is possible that they are related parties, sharing familial names. However, it is also possible that this is one person deliberately using inconsistent information, to create multiple identities.
These interests, and any linked directors, require further analysis (not yet completed).
I advise testing all the other companies with MFM UK, MFM Investment, MFM Holding, MFM Group for related party transactions and potential impersonation.
I've submitted this as a pdf in a report to the Financial Conduct Authority, with the following cover note: The record for The Money Farm Limited in the Financial Services Register is materially incorrect: the company provides a Companies House registration number of The Moneyfarm Limited, without a space between Money and Farm; the link to the company website routes to the website of MFM Investment Ltd website, also known as “Moneyfarm”; and the address provided, is that of Mr Voegt’s only active interests, Associated Trading Limited. The FCA provides a notice, that “Money Farm” is a clone firm of MFM Investment Ltd and I bring to your attention that the record for The Money Farm Limited supports the fiction that William Voegt is officially linked to "Moneyfarm". I query if he is a shadow director of "Moneyfarm" and there is collusion between William Voegt and "Moneyfarm" also known as MFM Investment LTD.