Icon Tower Infrastructure Ltd due diligence for synthetic identity fraud [v3- final]
Multiple breaches of the Companies Act 2006 found. Letter of objection.
SDNP/24/01472/PA16
Letter of objection
Dear South Downs National Park Authority,
SDNP/24/01472/PA16
I am writing to express my strong objection to the planning permission sought by Icon Tower Infrastructure Limited (Icon Tower) for the proposed telecommunications project in Rottingdean. My objection is based on serious concerns regarding the integrity and trustworthiness of Icon Tower as a company. Herein, I summarise the key findings of my more detailed due diligence report.
Redacted Information
Crucial details about this application have been redacted from the cover letter submitted by Dalcour Maclaren, who is acting on behalf of Icon Tower, as well as within the Declaration of ICNIRP Conformity. These redactions prevent a thorough public assessment of the conformity, thereby failing to ensure transparency and trust.
Directors of Icon Tower have synthetic identities
The Companies Act 2006 specifies that an individual must have just one “unique identifier” in Companies House (Section 1082). I refer herein to a unique identifier as an identity. All appointments should be associated with an individual’s unique identity to enable transparency of related parties for audit and due diligence purposes. However, each of the four active directors of Icon Tower has multiple identities:
Thomas David Evans, born February 1980, has a minimum of 14 identities (https://find-and-update.company-information.service.gov.uk/search/officers?q=Thomas%20David%20Evans),
Scott Garland Bruce, born August 1961, has three identities registered (https://find-and-update.company-information.service.gov.uk/search/officers?q=Scott%20Garland%20BRUCE),
Richard Irwin Goldstein, born February 1961, has four identities (https://find-and-update.company-information.service.gov.uk/search?q=Richard+Irwin+Goldstein), and
Scott Emil Langeland, born December 1978, has two identities (https://find-and-update.company-information.service.gov.uk/search?q=Scott+Emil+Langeland).
Multiple identities are used to conceal interests from auditors and due diligence checks. Each director holds an appointment in Icon Tower Infrastructure Limited under an identity that exclusively associates them with this company, hiding their other appointments, for example, to AP WIP Investments Borrower UK Ltd, from anyone, or audit software, doing an audit or due diligence checks to meet anti-money laundering legislation.
Obscured Business Relationships
The cover letter for this application, authored by Dalcour Maclaren, states that “Icon Tower Infrastructure Ltd (Icon Tower) is a UK company owned by Radius Global Infrastructure Inc (Radius)” (SDNP_24_01472_PA16-COVER_LETTER-1992584.pdf (southdowns.gov.uk)). However, the supplementary information provided mentions that: “Icon Tower is a UK based company, headquartered in Lichfield, Staffordshire, who provide independent wireless infrastructure sites and equipment and also benefit from being an official Electronic Communications Code (‘Code’) Operator. (…) Icon Tower does not operate a retail mobile network of its own, but instead gathers Lease Premiums to develop its portfolio of infrastructure for the sole purpose of providing access to all wireless network operators on a shared basis. This is undertaken by Icon Tower Ltd’s parent company, AP Wireless. AP Wireless’ Investment Portfolio comprises thousands of sites across Europe, Asia, Australia and North and South America.” (SDNP_24_01472_PA16-SUPPLEMENTARY_INFORMATION-2000888.pdf (southdowns.gov.uk)).
The cover letter discloses ownership by Radius Global Infrastructure Inc (Radius) but does not disclose Icon Tower’s parent company as AP Wireless. The supplementary information discloses that the parent company is AP Wireless but fails to refer to the relationship with Radius Global. This inconsistency raises serious concerns about the integrity, transparency, and openness of these applicants.
A review of Companies House records reveals that the Person With Significant Control for Icon Tower is indeed declared as AP Wireless (UK) Ltd (https://find-and-update.company-information.service.gov.uk/company/11114036/persons-with-significant-control). However, AP Wireless (UK) Ltd fail to disclose any person with significant control, in its own records in Companies House (https://find-and-update.company-information.service.gov.uk/company/07853560/persons-with-significant-control). Contradictorily, the most recent accounts for Radius Global Infrastructure Inc for 2022 declare ownership of several "AP Wireless" companies, though not specifically AP Wireless (UK) Ltd (https://www.radiusglobal.com/static-files/b9fb28aa-e71e-4dcd-b8fb-8d04aaf95db7).
Failing to declare a company’s person with significant control is a breach of the Companies Act 2006. Given these discrepancies and the lack of clarity surrounding the ownership and control of Icon Tower Infrastructure Limited, it is evident that the integrity and transparency of the involved entities are highly questionable.
Conclusion
The redaction of crucial details, the use of multiple synthetic identities by the directors, and the obscured business relationships collectively indicate a significant lack of transparency and integrity. These issues undermine the trust necessary for granting planning permission for the proposed telecommunications project. I urge the South Downs National Park Authority to thoroughly investigate these matters and consider the serious implications for compliance with legal and regulatory standards before making a decision on this application.
Sincerely,
Alison Wright
Due Diligence Executive Summary:
This report scrutinises corporate governance issues surrounding Icon Tower Infrastructure Ltd, linked to Radius Global Infrastructure Inc, in their proposal to erect a telecommunications tower. The investigation uncovers discrepancies in key officers' appointments, indicating potential breaches of the Companies Act 2006 and synthetic identity fraud.
Key Findings
Officer Discrepancies and Synthetic Identity Fraud
Thomas David Evans holds multiple unique identifiers across various companies, suggesting an attempt to obscure interests from auditors and due diligence checks.
Similar patterns are observed with Scott Garland Bruce, Richard Irwin Goldstein, and Scott Emil Langeland.
AP WIRELESS (UK) LIMITED Irregularities
AP WIRELESS (UK) LIMITED, the “person with significant control” over Icon Tower Infrastructure Ltd, exhibits irregularities with a lack of registered active persons with significant control.
Daniel John Hasselman, an additional director, holds appointments under three different identities, with one identity using a different year of birth, indicating potential synthetic identity fraud.
Potential Clone Company Fraud
A search for AP Wireless returns two companies with very similar names registered at the same address: AP WIRELESS (UK) LIMITED and AP WIRELESS II (UK) LIMITED. The similarity of these names and shared address raises the risk of clone company fraud.
The registration of multiple entities under the name "Radius Limited" in Companies House, including name-switching between Radius Limited and Radius Payment Solutions Limited, previously called Radius Global Limited, suggests potential clone company fraud and breaches of the Companies Act.
Issues with Radius Payment Solutions Limited
The sole director of Radius Payment Solutions Limited, Lee John Everett, has three identities indicating potential synthetic identity fraud.
An anomalous "Page not found" result for one of his identities suggests possible concealment with the assistance of Companies House.
The recurrent use of the name "Radius" across various companies raises significant concerns about the risk of clone company fraud.
The association of these companies with the same address and the presence of multiple identities for Lee John Everett point to efforts to obscure true ownership and control, which could facilitate regulatory evasion, including OFCOM regulations.
Implications
Governance and Compliance Risks
The presence of multiple identities associated with each director complicates efforts to accurately assess and verify their backgrounds, increasing the risk of illicit activities going undetected.
The lack of transparency in the tower proposal, with key information redacted, necessitates detailed specifications for residents to assess potential impacts on frequencies, power ranges, and other crucial factors.
Regulatory and Financial Risks
Failure to address these issues risks regulatory scrutiny, reputational damage, and financial risks.
The existence of multiple identities associated with each director complicates efforts to accurately assess and verify their backgrounds, increasing the risk of illicit activities going undetected.
Conclusion
The application raises significant concerns regarding transparency, integrity, accountability, and compliance with the Companies Act 2006. The highlighted issues necessitate comprehensive investigations and corrective actions to address governance lapses, uphold regulatory compliance, and protect stakeholder interests.
Implementing robust governance practices and enhancing transparency are crucial to ensuring accountability and maintaining trust within the business community. Thorough investigations and corrective measures are necessary to address potential breaches of the Companies Act and safeguard the integrity of corporate records and financial disclosures.
This company is problematic with regards to integrity, accountability, openness, and trustworthiness. All directors hold their directorship of AP WIP Investments Borrower UK Ltd under separate identities from Icon Tower Infrastructure Limited. This arrangement potentially obscures related party transactions from auditors, undermining the reliability and comprehensiveness of financial assessments. This raises red flags in terms of due diligence for compliance with anti-money laundering, counter-terrorism financing legislation, and efforts to combat people trafficking.
Summary of company directorships held by the directors of Icon Tower Infrastructure Limited indicating which identity is appointed and the appointment date.
Due Diligence Introduction:
The proposal to erect a 20m high telecommunications lattice tower, along with supporting antenna headframes and ground-based equipment cabinets, within the South Downs National Park, has been submitted by Icon Tower Infrastructure Ltd (Icon Tower). Despite the importance of the project, crucial details remain redacted, leaving stakeholders in the dark about the specifics. This report aims to shed light on the directors of Icon Tower, who wield significant control over the project, despite the undisclosed specifications. As an entity owned by Radius Global Infrastructure Inc (Radius), understanding the backgrounds and potential implications of Icon Tower's directors is paramount for informed decision-making and regulatory compliance.
The cover letter from Icon Tower Infrastructure Ltd application to erect a 20m high telecommunications lattice tower supporting antenna headframes, plus ground-based equipment cabinets, in the South Downs National Park, which will host a variety of operators, is copied below:
What is evident is that we are being asked to agree to a project about which most of the details have been redacted.
Focussing on who has submitted this proposal:
“Icon Tower Infrastructure Ltd (Icon Tower) is a UK company owned by Radius Global Infrastructure Inc (Radius).”
The Overview of this company as provided in Companies House provides the following information: (ICON TOWER INFRASTRUCTURE LIMITED overview - Find and update company information - GOV.UK (company-information.service.gov.uk)). [Underlined text provides web linked references to the source information, the descriptive “Find and update company information - GOV.UK (company-information.service.gov.uk” has been deleted in later references, for brevity and to reduce repetition].
Icon Tower Infrastructure Limited, previously known as Radius BTS Limited and AP Mast Site Management Limited, is a private limited company registered in the UK under company number 11114036. Its registered office is located at First Floor Suite B Adamson House, The Towers Business Park, Didsbury, Manchester, M20 2YY. The company's status is active, and it was incorporated on 15 December 2017.
Icon Tower Infrastructure Limited primarily operates in the field of real estate, specifically under the Standard Industrial Classification (SIC) code 68209, which encompasses the letting and operating of own or leased real estate.
The company's next accounts are due to be filed for the year ending 31 December 2023, with the deadline set for 30 September 2024. The last set of accounts filed were for the year ending 31 December 2022. Additionally, the next confirmation statement is due on 14 December 2024, with the previous statement dated 14 December 2023.
The officers details (ICON TOWER INFRASTRUCTURE LIMITED people:
By clicking on each name the appointments held by each identity are listed. The appointments for the officers are reproduced below;
Thomas David EVANS personal appointments
Thomas David Evans, who holds the role of Secretary, has been serving in this capacity since the company's incorporation on 15 December 2017. The correspondence address for the company is First Floor Suite B Adamson House, The Towers Business Park, Didsbury, Manchester, M20 2YY.
Scott Garland BRUCE personal appointments
Scott Garland Bruce serves as a Director for Icon Tower Infrastructure Ltd. (appointed on 23 June 2021). He is also a Director in the following active companies:
AP Wireless II (UK) Limited (appointed on 30 March 2012).
AP Wireless (UK) Limited (appointed on 18 November 2011).
CELL:CM (Saltire) Limited (appointed on 24 May 2018, resigned on 5 April 2023).
CELL:CM Ltd (appointed on 24 May 2018, resigned on 5 April 2023).
Scott Garland Bruce is associated with the following addresses:
First Floor Suite B Adamson House, The Towers Business Park, Didsbury, Manchester, M20 2YY.
16-18, Conduit Street, Lichfield, Staffordshire, England, WS13 6JR (correspondence address).
16-18, Conduit Street, Lichfield, England, WS13 6JR (correspondence address).
Suite A, Deanway 2, Deanway Business Park, Wilmslow Road, Handforth, Wilmslow, England, SK9 3HW.
Thomas David EVANS personal appointments
In addition to his role as Secretary of Icon Tower Infrastructure Limited, Thomas David Evans is also a Director, appointed on 15 December 2017, with an additional, separate identity (unique identifier). This is a breach of Section 1082 of the Companies Act. Thomas David Evans and is also listed in the following active companies:
AP WIP Investments Borrower UK Ltd (appointed on 3 May 2023).
APW UK Datadas Limited (appointed on 22 September 2021).
APW UK WIP Limited (appointed on 22 September 2021).
APW UK Switch Limited (appointed on 22 September 2021).
APW UK Tower Holdings Limited (appointed on 21 September 2021).
APW UK Arcco Limited (appointed on 21 September 2021).
Horton Investments Ltd (appointed on 25 September 2017).
He has also served as a Director for the dissolved company Viris Brand Ltd (appointed on 25 June 2021). Additionally, Thomas David Evans previously held directorship positions in CELL:CM (Saltire) Limited (resigned on 5 April 2023) and CELL:CM Ltd (resigned on 5 April 2023), where he also served as a Company Secretary.
In addition to the address 16-18, Conduit Street, Lichfield, England, WS13 6JR, Thomas David Evans is also associated with the following addresses:
Woodland Lodge, Dunston Business Village, Dunston, Stafford, United Kingdom, ST18 9AB.
First Floor Suite B Adamson House, The Towers Business Park, Didsbury, Manchester, M20 2YY.
Hanover Court, 5 Queen Street, Lichfield, Staffordshire, United Kingdom, WS13 6QD.
Suite A, Deanway 2, Deanway Business Park, Wilmslow Road, Handforth, Wilmslow, England, SK9 3HW.
Richard Irwin GOLDSTEIN personal appointments
Richard Irwin Goldstein is a Director of Icon Tower Infrastructure Limited. He was appointed to this role on 3 May 2023. His correspondence address is First Floor Suite B Adamson House, The Towers Business Park, Didsbury, Manchester, M20 2YY. Richard Irwin Goldstein is an American national and resides in the United States.
Scott Emil LANGELAND personal appointments
Scott Emil Langeland is a Director of Icon Tower Infrastructure Limited. He was appointed to this role on 3 May 2023. His correspondence address is First Floor Suite B Adamson House, The Towers Business Park, Didsbury, Manchester, M20 2YY. Scott Emil Langeland is an American national and resides in the United States. His occupation is listed as Company Director.
Test for multiple unique identifiers, a breach of Section 1082 if the Companies Act 2006
In the process of investigating potential synthetic identities, it's crucial to acknowledge inherent limitations. For instance, in our examination of Thomas David Evans, while we've conducted thorough searches based on known addresses, three names, and date of birth, it's essential to recognise that this approach may not capture all potential identities.
One notable limitation is the possibility that Thomas David Evans may be registered as a secretary at an address not included in our search. Additionally, identities under variations of his name or with different dates of birth might remain undetected.
Given these constraints, it's imperative to approach our investigation with caution and consider the necessity for further measures to ensure a comprehensive understanding of potential synthetic identities associated with Thomas David Evans or any other individual under scrutiny.
We are already aware that Thomas David Evans holds two unique identifiers, one which solely holds his appointment as a secretary of Icon Towers Infrastructure Limited, and another which holds his appointment as a director of the same company, and in addition appointments to a further 10 companies, as described above.
A search on his name reveals that he has many more unique identities registered:
Thomas David Evans - Find
On the first page of the search results, there are evidently ten identities (unique identifiers) for Thomas David Evans, born February 1980 that are associated by variations of the same address, 16-18, Conduit Street, Lichfield, Staffordshire, WS13 6JR. These are marked with a red line, in the image above. These identities will be scrutinised later.
The second page reveals more identities that use the same three names and an address that is associated with the identity that Thomas David Evans uses for his appointment to Iconic Towers Infrastructure Limited, which are described above.
On the second page there are further identities for Thomas David Evans born February 1980. With a total minimum of fourteen “unique” identities Thomas David Evans. These are expanded below.
Total number of appointments 2 - Born February 1980
16-18 Conduit Street, Lichfield, Staffordshire, England, WS13 6JR
AP WIRELESS II (UK) LIMITED (08013103)
Company status Active
Role ACTIVE Director Appointed on 26 July 2013
AP WIRELESS (UK) LIMITED (07853560)
Company status Active
Role ACTIVE Director Appointed on 18 July 2013
Total number of appointments 1
16-18, Conduit Street, Lichfield, England, WS13 6JR
APW UK DATADAS LIMITED (13637190)
Company status Active
Role ACTIVE Secretary Appointed on 22 September 2021
Total number of appointments 1
16-18, Conduit Street, Lichfield, England, WS13 6JR
APW UK SWITCH LIMITED (13637807)
Company status Active
Role ACTIVE Secretary Appointed on 22 September 2021
Total number of appointments 1
16-18, Conduit Street, Lichfield, Staffordshire, England, WS13 6JR
AP WIP INVESTMENTS BORROWER UK LTD (14844088)
Company status Active
Role ACTIVE Secretary Appointed on 3 May 2023
Total number of appointments 1
16-18, Conduit Street, Lichfield, England, WS13 6JR
Company status Active
Role ACTIVE Secretary Appointed on 22 September 2021
Total number of appointments 1
16-18, Conduit Street, Lichfield, England, WS13 6JR
APW UK TOWER HOLDINGS LIMITED (13634971)
Company status Active
Role ACTIVE Secretary Appointed on 21 September 2021
Total number of appointments 1 - Born February 1980
Hanover Court, 5 Queen Street, Lichfield, Staffordshire, United Kingdom, WS13 6QD
TDE ACQUISITIONS LTD (07879626)
Company status Active
Role ACTIVE Director Appointed on 13 December 2011 Surveyor
Total number of appointments 1
16-18, Conduit Street, Lichfield, England, WS13 6JR
APW UK ARCCO LIMITED (13634921)
Company status Active
Role ACTIVE Secretary Appointed on 21 September 2021
Total number of appointments 1
16-18 Conduit Street, Lichfield, Staffordshire, England, WS13 6JR
AP WIRELESS (UK) LIMITED (07853560)
Company status Active
Role ACTIVE Secretary Appointed on 19 March 2013
Total number of appointments 1
16-18 Conduit Street, Lichfield, Staffordshire, England, WS13 6JR
AP WIRELESS II (UK) LIMITED (08013103)
Company status Active
Role ACTIVE Secretary Appointed on 19 March 2013
Total number of appointments 1
First Floor Suite B Adamson House, The Towers Business Park, Didsbury, Manchester, M20 2YY
ICON TOWER INFRASTRUCTURE LIMITED (11114036)
Company status Active
Role ACTIVE Secretary Appointed on 15 December 2017
Total number of appointments 10 - Born February 1980
16-18, Conduit Street, Lichfield, Staffordshire, England, WS13 6JR
AP WIP INVESTMENTS BORROWER UK LTD (14844088)
Company status Active
Role ACTIVE Director Appointed on 3 May 2023
APW UK DATADAS LIMITED (13637190)
Company status Active
Role ACTIVE Director Appointed on 22 September 2021
Company status Active
Role ACTIVE Director Appointed on 22 September 2021
APW UK SWITCH LIMITED (13637807)
Company status Active
Role ACTIVE Director Appointed on 22 September 2021
APW UK TOWER HOLDINGS LIMITED (13634971)
Company status Active
Role ACTIVE Director Appointed on 21 September 2021
APW UK ARCCO LIMITED (13634921)
Company status Active
Role ACTIVE Director Appointed on 21 September 2021
Company status Dissolved
Correspondence address Woodland Lodge, Dunston Business Village, Dunston, Stafford, United Kingdom, ST18 9AB
Role Director Appointed on 25 June 2021
ICON TOWER INFRASTRUCTURE LIMITED (11114036)
Company status Active
Role ACTIVE Director Appointed on 15 December 2017
HORTON INVESTMENTS LTD (10979173)
Company status Active
Role ACTIVE Director Appointed on 25 September 2017
CELL:CM (SALTIRE) LIMITED (10044061)
Company status Active
Correspondence address Suite A, Deanway 2, Deanway Business Park, Wilmslow Road, Handforth, Wilmslow, England, SK9 3HW
Role RESIGNED Director Appointed on 24 May 2018 Resigned on 5 April 2023
Company status Active
Correspondence address Suite A, Deanway 2, Deanway Business Park, Wilmslow Road, Handforth, Wilmslow, England, SK9 3HW
Role RESIGNED Director Appointed on 24 May 2018 Resigned on 5 April 2023
Total number of appointments 1
Suite A, Deanway 2, Deanway Business Park, Wilmslow Road, Handforth, Wilmslow, England, SK9 3HW
CELL:CM (SALTIRE) LIMITED (10044061)
Company status Active
Role RESIGNED Secretary Appointed on 24 May 2018 Resigned on 5 April 2023
Total number of appointments 1
Suite A, Deanway 2, Deanway Business Park, Wilmslow Road, Handforth, Wilmslow, England, SK9 3HW
Company status Active
Role RESIGNED Secretary Appointed on 24 May 2018 Resigned on 5 April 2023
Test for multiple unique identifiers reveals a breach of Section 1082 of the Companies Act 2006. In our investigation of Thomas David Evans, born in February 1980, we uncovered a total of fourteen unique identities associated with him. These identities span various active companies, including AP Wireless (UK) Limited, AP WIP Investments Borrower UK Ltd, and Icon Tower Infrastructure Limited, among others. Notably, Thomas David Evans holds appointments under different identities, with one solely for secretary roles and another for directorship positions. This arrangement raises concerns about transparency in related party transactions and compliance with regulatory requirements.
Query whether related party: Thomas David Evan born February 1990
Total number of appointments 0 - Born February 1990
Emstrey House, Shrewsbury Business Park, Shrewsbury, Shropshire, United Kingdom, SY2 6LG
FIXED CAPITAL LIMITED (08364328)
Company status Dissolved
Role Director Appointed on 17 January 2013
Total number of appointments 1 - Born February 1990
Regus House, Falcon Drive, Cardiff, United Kingdom, CF10 4RU
FIXED CAPITAL (UK) LIMITED (08764554)
Company status Dissolved
Director Appointed on 6 November 2013
INVESTMENT LEADS LIMITED (08720664)
Company status Dissolved
Correspondence address Sophia House, Cathedral Road, Cardiff, CF11 9LJ
Role RESIGNED Director Appointed on 7 October 2013 Resigned on 22 October 2015
Total number of appointments 1 - Born February 1990
Suite 2, Aus-Bore House, 19-25 Manchester Road, Wilmslow, Cheshire, United Kingdom, SK9 1BQ
TDE CONSULTING LIMITED (11262401)
Company status Active
Role RESIGNED Director Appointed on 19 March 2018 Resigned on 11 June 2021
Thomas David Evans born February 1990 has three identities registered. He is breaching section 1082 of the Companies Act 2006. In identity 3 he uses a correspondence address is based in Wilmslow. I note that Thomas David Evans, born February 1980 also uses addresses in Wilmslow in identities Identity 12, 13 and 14. The probability of two people having the same three names and month of birth, operating businesses in the same location, without being related, are very low. It is recommended that Thomas David Evans, born 1990 is considered as a potential related party, or possibly, that this is an identity that has been established by Thomas David Evans, with an incorrect year of birth, in order to conceal these interests.
Query whether related party: Thomas David Evans born July 1938
Query whether related party, possible patriarch.
Total number of appointments 1 - Born July 1948
Oil Technics Ltd, Linton Business Park, Gourdon, Aberdeenshire, United Kingdom, DD10 0NH
Company status Active
Role ACTIVE Director Appointed on 26 May 2022
Total number of appointments 6 - Born July 1948
Upper Mill Of Allardice, Inverbervie, Montrose, DD10 0SP
INFECTION CONTROL LIMITED (SC341445)
Company status Dissolved
Director Appointed on 16 April 2008
ESRAM TRADING LIMITED (SC258437)
Company status Active
Role ACTIVE Director Appointed on 29 October 2003
OIL TECHNICS HOLDINGS LIMITED (03393270)
Company status Active
Allardyce Mill, Inverbervie, Montrose, Scotland, DD10 0SP
Role ACTIVE Director Appointed on 17 November 1997
BIO TECHNICS LIMITED (03008596)
Company status Active
Role ACTIVE Director Appointed on 11 January 1995
OIL TECHNICS (FIRE FIGHTING PRODUCTS) LIMITED (02678773)
Company status Active
Allardyce Mill, Inverbervie, Montrose, Scotland, DD10 0SP
Role ACTIVE Director Appointed on 26 March 1992
OIL TECHNICS LIMITED (02119389)
Company status Active
Allardyce Mill, Inverbervie, Montrose, Scotland, DD10 0SP
Role ACTIVE Director Appointed before 31 October 1991
BIO TECHNICS LIMITED (03008596)
Company status Active
Role RESIGNED Secretary Appointed on 11 January 1995 Resigned on 17 October 2005
Thomas David Evans has two identities indicating a breach of Section 1082 of the Companies Act 2006. He holds directorship in several active companies, including Oil Technics Holdings Limited, Bio Technics Limited and Oil Technics (Fire Fighting Products) Limited, among others. Additionally, he has held roles in companies like Infection Control Limited and Esram Trading Limited, although Infection Control Limited is now dissolved. These appointments span several decades, suggesting a long-standing involvement in these organizations. The inconsistent spelling of "Allardice Mill" as both "Allerdyce Mill" and "Allardice Mill" by Thomas David Evans across different company records can lead to false non-matches in audit and due diligence software. Such discrepancies highlight the importance of meticulous data entry and consistency in corporate records to ensure accurate assessments and prevent potential errors in compliance checks. Additionally, dissolved companies, like Infection Control Limited in this case, may continue to operate informally or even maintain active bank accounts, posing a risk for financial oversight and regulatory compliance.
Scott Garland BRUCE - Find
Scott Garland Bruce holds three distinct identities in Companies House records.
Identity 1 is associated with AP WIP INVESTMENTS BORROWER UK LTD (14844088), an active company with its correspondence address located at 16-18, Conduit Street, Lichfield, Staffordshire, England, WS13 6JR. Bruce serves as a director, appointed on 3 May 2023.
Identity 2 holds five appointments, including director roles in active companies such as APW UK DATADAS LIMITED (13637190), APW UK WIP LIMITED (13637323), APW UK SWITCH LIMITED (13637807), APW UK TOWER HOLDINGS LIMITED (13634971), and APW UK ARCCO LIMITED (13634921). These companies also share the same correspondence address at 16-18, Conduit Street, Lichfield, England, WS13 6JR. Bruce, an American national residing in the United States, holds these positions.
Identity 3 is the one we previously encountered, associated with various appointments, including to Icon Tower Infrastructure Limited, and holds the same correspondence address at First Floor Suite B Adamson House, The Towers Business Park, Didsbury, Manchester, M20 2YY.
Richard Irwin GOLDSTEIN - Find
These identities have the appointments held by each additional identity inserted, below:
1. Richard Irwin GOLDSTEIN
Total number of appointments 5 - Born February 1961
16-18, Conduit Street, Lichfield, England, WS13 6JR
APW UK DATADAS LIMITED (13637190)
Company status Active
Role ACTIVE Director Appointed on 22 September 2021
Company status Active
Role ACTIVE Director Appointed on 22 September 2021
APW UK SWITCH LIMITED (13637807)
Company status Active
Role ACTIVE Director Appointed on 22 September 2021
APW UK TOWER HOLDINGS LIMITED (13634971)
Company status Active
Role ACTIVE Director Appointed on 21 September 2021
y Director
APW UK ARCCO LIMITED (13634921)
Company status Active
Role ACTIVE Director Appointed on 21 September 2021
2. Richard Irwin GOLDSTEIN
Total number of appointments 1 - Born February 1961
16-18, Conduit Street, Lichfield, Staffordshire, England, WS13 6JR
AP WIP INVESTMENTS BORROWER UK LTD (14844088)
Company status Active
Role ACTIVE Director Appointed on 3 May 2023
3. Richard Irwin GOLDSTEIN
Total number of appointments 1 - Born February 1961
First Floor Suite B Adamson House, The Towers Business Park, Didsbury, Manchester, M20 2YY
ICON TOWER INFRASTRUCTURE LIMITED (11114036)
Company status Active
Role ACTIVE Director Appointed on 3 May 2023
4. Richard Irwin GOLDSTEIN
Total number of appointments 2 - Born February 1961
16-18 Conduit Street, Lichfield, Staffordshire, England, WS13 6JR
AP WIRELESS (UK) LIMITED (07853560)
Company status Active
Director Appointed on 8 January 2020
AP WIRELESS II (UK) LIMITED (08013103)
Company status Active
Role ACTIVE Director Appointed on 8 January 2020
The existence of multiple identities associated with Richard Irwin Goldstein raises concerns regarding compliance with the Companies Act and transparency in corporate governance. Each identity is linked to various directorial roles across different companies, indicating a potential breach of regulatory requirements.
These identities not only complicate the oversight of Goldstein's directorial responsibilities but also raise questions about the accuracy and reliability of corporate records and financial disclosures. Such discrepancies could impact the integrity of past accounts and audits and hinder effective due diligence processes.
To ensure regulatory compliance and uphold transparency and accountability in corporate practices, thorough investigations and appropriate corrective actions are warranted. Regulatory authorities and stakeholders should address these issues promptly to mitigate potential risks and safeguard the interests of shareholders and the broader business community.
Scot Emil Langland
A search for identities of Scott Emil Langeland locates two unique identifiers. The associated company information has been added below.
1. Scott Emil LANGELAND
Total number of appointments 1 - Born December 1978
First Floor Suite B Adamson House, The Towers Business Park, Didsbury, Manchester, M20 2YY
ICON TOWER INFRASTRUCTURE LIMITED (11114036)
Company status Active
Role ACTIVE Director Appointed on 3 May 2023
2. Scott Emil LANGELAND
Total number of appointments 1 - Born December 1978
16-18, Conduit Street, Lichfield, Staffordshire, England, WS13 6JR
AP WIP INVESTMENTS BORROWER UK LTD (14844088)
Company status Active
Role ACTIVE Director Appointed on 3 May 2023
Conclusion:
The discovery of two unique identifiers associated with Scott Emil Langeland highlights potential discrepancies in corporate governance and regulatory compliance. Langeland's involvement as a director in multiple companies raises concerns about the accuracy and transparency of corporate records.
The existence of multiple identities for Langeland could complicate oversight and due diligence processes, impacting the reliability of financial disclosures and the integrity of past accounts and audits. This situation underscores the importance of robust regulatory oversight and diligent corporate governance practices to ensure transparency and accountability in business operations.
Addressing these discrepancies and ensuring compliance with regulatory requirements is crucial to maintain trust and confidence among stakeholders. Regulatory authorities and relevant stakeholders should investigate these issues thoroughly and take appropriate corrective actions to uphold the integrity of the corporate ecosystem and protect the interests of shareholders and the broader business community.
Summary of company directorships held by the directors of Icon Tower Infrastructure Limited indicating which identity is appointed and the appointment date.
Analysis and Observations
Multiple Identities and Non-Compliance with Section 1082
Multiple Identities for the Same Individual:
Thomas David Evans: At least 14 different identities across various companies.
Scott Garland Bruce, Richard Irwin Goldstein, and Scott Emil Langeland: Multiple identities, though fewer than Evans.
Breach of Section 1082:
Section 1082 mandates the allocation of unique identifiers to individuals to prevent duplication and ensure transparent identification in the Companies House register.
The existence of multiple identities for these individuals without the proper allocation of unique identifiers directly breaches this regulation.
Implications of Multiple Identities
Compromised Audits:
Audits are fundamentally compromised because auditors cannot see the full scope of an individual’s appointments and potential conflicts of interest when they are spread across multiple identities.
For instance, each individual holds an appointment in Icon Tower Infrastructure Limited under an identity that exclusively associates them with this company, hiding their other appointments.
Missed Related Party Transactions:
With identities fragmented, auditors and related parties are unaware of the full extent of relationships and transactions between companies, increasing the risk of undisclosed related party transactions.
This lack of visibility directly affects the accuracy and reliability of financial statements and disclosures.
Compromised Due Diligence and Anti-Money Laundering (AML) Checks:
Effective due diligence and AML checks are significantly hindered. Multiple identities make it difficult to trace all activities and associations of an individual.
Financial institutions and regulatory bodies might miss critical connections, increasing the risk of financial crimes such as money laundering.
Specific Examples from the Data
Thomas David Evans:
Holds directorships under different identities, which obscures the full range of his influence and control within these companies.
This has been ongoing since the second identity was established, breaching section 1082.
Scott Garland Bruce:
Multiple roles in different companies, which are not properly linked via unique identifiers, might go unnoticed in related party transactions checks.
This continuous breach affects the reliability of audits and financial disclosures.
Richard Irwin Goldstein:
His multiple roles under different identities hinder transparency and compliance, impacting related party transaction analysis and audit reliability.
Scott Emil Langeland:
Two identities with single appointments in different companies, complicating thorough compliance checks and due diligence processes.
Conclusion
The existence of multiple identities for these directors breaches section 1082 of the Companies Act 2006. This practice compromises audits by hiding related party transactions and conflicts of interest. It undermines due diligence checks for money laundering and other financial crimes, posing significant risks to regulatory compliance and the integrity of financial reporting. The regulatory framework must enforce the allocation and management of unique identifiers to enhance transparency and oversight.
ICON TOWER INFRASTRUCTURE LIMITED persons with significant control
The details of the person with significant control of Icon Tower Infrastructure Limited was accessed via the tab in the People section of Companies House.
The Ap Wireless (Uk) Limited holds significant control over Icon Tower’s operations, with ownership of 75% or more of shares and voting rights, as well as the right to appoint or remove directors. This information is inconsistent with the disclosure in the cover letter, which states that Radius Global Infrastructure Inc is the owner.
Obscured business relationships.
The cover letter for this application, authored by Dalcour Maclaren, states that “Icon Tower Infrastructure Ltd (Icon Tower) is a UK company owned by Radius Global Infrastructure Inc (Radius)” (SDNP_24_01472_PA16-COVER_LETTER-1992584.pdf (southdowns.gov.uk)). However, the supplementary information provided mentions that: “Icon Tower is a UK based company, headquartered in Lichfield, Staffordshire, who provide independent wireless infrastructure sites and equipment and also benefit from being an official Electronic Communications Code (‘Code’) Operator. (…) Icon Tower does not operate a retail mobile network of its own, but instead gathers Lease Premiums to develop its portfolio of infrastructure for the sole purpose of providing access to all wireless network operators on a shared basis. This is undertaken by Icon Tower Ltd’s parent company, AP Wireless. AP Wireless’ Investment Portfolio comprises thousands of sites across Europe, Asia, Australia and North and South America.” (SDNP_24_01472_PA16-SUPPLEMENTARY_INFORMATION-2000888.pdf (southdowns.gov.uk).
The cover letter discloses ownership by Radius Global Infrastructure Inc (Radius) but does not disclose Icon Tower’s parent company as “AP Wireless”. The supplementary information discloses that the parent company is AP Wireless but fails to refer to the relationship with Radius Global. This inconsistency raises serious concerns about the integrity, transparency, and openness of these applicants.
A search for AP Wireless returns two companies with very similar names that are registered at the same address. The similarity of these names is a risk that clone company fraud might be being facilitated, by the directors. These are marked with a red line:
07853560 - Incorporated on 18 November 2011
16-18 Conduit Street, Lichfield, Staffordshire, England, WS13 6JR
08013103 - Incorporated on 30 March 2012
16-18 Conduit Street, Lichfield, Staffordshire, England, WS13 6JR
Due diligence on each of these companies is appropriate.
AP WIRELESS (UK) LIMITED people
In summary, the directors of this company are the same as for Icon Tower Infrastructure Limited with the addition of Daniel John HASSELMAN who holds this as his sole appointment in this identity (Daniel John HASSELMAN personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk).
A test for multiple identities was conducted:
The additional director of Ap Wireless (Uk) Limited is Daniel Hasselmann. He has three identities that are linked with the same address, the third identity uses a different year of birth. The appointments to these identities are added below:
Daniel John HASSELMAN Total number of appointments 5 - Born March 1979 16-18, Conduit Street, Lichfield, England, WS13 6JR
APW UK DATADAS LIMITED (13637190) Active
Appointed on 22 September 2021
APW UK WIP LIMITED (13637323) Active
Appointed on 22 September 2021
APW UK SWITCH LIMITED (13637807) Active
Appointed on 22 September 2021
APW UK TOWER HOLDINGS LIMITED (13634971) Active
Appointed on 21 September 2021
APW UK ARCCO LIMITED (13634921) Active
Appointed on 21 September 2021
Daniel John HASSELMAN Total number of appointments 1 - Born March 1979 16-18 Conduit Street, Lichfield, Staffordshire, England, WS13 6JR
AP WIRELESS (UK) LIMITED (07853560)
Appointed on 8 January 2020
Daniel John HASSELMAN Total number of appointments 1 - Born March 1978 16-18 Conduit Street, Lichfield, Staffordshire, England, WS13 6JR.
AP WIRELESS II (UK) LIMITED (08013103)
Appointed on 8 January 2020
The presence of multiple identities associated with Daniel John Hasselmann, with variations in details such as the date of birth, underscores the need for meticulous attention to detail in corporate records and due diligence processes. Such discrepancies can introduce complexities and potential errors in audits and due diligence assessments.
These variations could lead to false non-match errors in due diligence and audit software, potentially compromising the accuracy and reliability of financial disclosures. Furthermore, discrepancies in directorial identities could obscure the true extent of directorship interests and potential conflicts of interest, hindering effective oversight and risk management.
In summary, the directors of AP Wireless (UK) Limited, which is the “person with significant control” of Icon Tower Infrastructure Limited, are the same as those for Icon Tower Infrastructure Limited, with the addition of Daniel John Hasselman. Hasselman holds this as his sole appointment under this identity.
A test for multiple identities revealed that Daniel Hasselman operates under three identities linked to the same address, with one identity using a different year of birth. This raises significant concerns regarding the transparency and integrity of these appointments. The multiple identities and inconsistent birth years suggest potential efforts to obscure the true nature of the directorships, compromising the accuracy of due diligence and regulatory compliance.
Charges for AP WIRELESS (UK) LIMITED (07853560)
The AP WIRELESS (UK) LIMITED, registered under company number 07853560, has a total of 5 charges, with 1 outstanding, and 4 satisfied. The outstanding charge, created on 9 November 2017 and delivered on 13 November 2017, remains active and is associated with Glas Trust Corporation Limited. This charge contains a fixed charge, although further details on the nature of the charge are not provided. The satisfied charges were all associated with Deutsche Bank Trust Company Americas.
Due diligence on Glas Trust Corporation Limited is required.
The records for Glas Trust Corporation Limited were located in a search in Companies House (Glas Trust Corporation Limited - Find).
Glas Trust Corporation Limited is an active private limited company based in London, England. Its primary business activity is categorised under SIC code 66190, which includes activities auxiliary to financial intermediation not elsewhere classified.
Glas Trust Corporation Limited was incorporated on 27 January 2012 and has undergone a name change from GLOBAL LOAN SERVICES NOMINEES LIMITED, reflecting a shift in its business focus or corporate structure. The company's registered office address is located at 55 Ludgate Hill, Level 1, West, London, England, EC4M 7JW.
Given its involvement in financial intermediation activities, Glas Trust Corporation Limited likely plays a role in managing financial assets, holding charges, or acting as a trustee for various financial arrangements. Further investigation into its financial stability, track record, and any potential conflicts of interest is advisable to understand its role in the outstanding charge against AP WIRELESS (UK) LIMITED and its implications for the company's financial affairs.
No person with significant control of AP Wireless (Uk) is disclosed
AP WIRELESS (UK) LIMITED persons with significant control
“0 active persons with significant control / 1 active statement
The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company”.
The person with significant control of Icon Tower Infrastructure Limited is given, in Companies House, as AP Wireless (UK) Limited and this company has no person with significant control registered. This is a contradiction with the statement in Icon Tower Infrastructure Limited’s cover letter, accompanying their application for a new telecommunications tower, which states that “Icon Tower Infrastructure Ltd (Icon Tower) is a UK company owned by Radius Global Infrastructure Inc (Radius).”
Referring to OpenCorporates for details of this company registered overseas
Referring to the record for RADIUS GLOBAL INFRASTRUCTURE, INC. :: Delaware (US) :: OpenCorporates:
The registry records for Radius Global Infrastructure Inc refers to The Corporation Trust Company as its agent and director.
I note that The Corporation Trust Company has multiple unique identifiers breaching accountability requirements.
Further analysis is required.
Summary:
AP WIRELESS (UK) LIMITED, the entity with significant control over Icon Tower Infrastructure Limited, is associated with a total of 5 charges. Out of these, 4 have been satisfied, while 1 remains outstanding. The outstanding charge, linked to Glas Trust Corporation Limited, was created on 9 November 2017, featuring a fixed charge without detailed specifications. The satisfied charges were all attributed to Deutsche Bank Trust Company Americas.
However, according to Companies House records, AP WIRELESS (UK) LIMITED does not have any active persons with significant control registered. This contradicts the statement in Icon Tower Infrastructure Limited's cover letter, which identifies Radius Global Infrastructure Limited as the owner. Further investigation into the ownership and control structure of AP Wireless (UK) Limited is warranted.
Referring to OpenCorporates for details of Radius Global Infrastructure Inc, purported owner of Icon Tower Infrastructure Ltd, it is registered in Delaware (US). The registry records for Radius Global Infrastructure Inc indicate The Corporation Trust Company as its agent and director, raising concerns about accountability and transparency, particularly due to its use by multiple identities.
Conclusion:
Discrepancies in charges and significant control information for Icon Tower Infrastructure Limited and AP WIRELESS (UK) LIMITED, alongside conflicting statements regarding ownership, underscore potential issues in corporate governance and regulatory compliance. Further analysis and due diligence are imperative to grasp the ownership structure, control mechanisms, and accountability of AP Wireless (UK) Limited, as well as its relationship with Icon Tower Infrastructure Ltd and other related entities.
Prompt and comprehensive action is crucial to ensure transparency, regulatory compliance, and accountability in corporate operations. Failure to address these issues could subject the company to regulatory scrutiny, reputational harm, and financial risks. Therefore, thorough investigations and appropriate corrective measures are essential to mitigate risks and safeguard stakeholders' interests and the broader business community.
Radius Global is also registered in Companies House, potential for clone company fraud.
A search in Companies House on “Radius Global” returns two entities that require further consideration (https://find-and-update.company-information.service.gov.uk/search?q=Radius):
Matching previous names:
RADIUS PAYMENT SOLUTIONS08260702 - Incorporated on 19 October 2012
Eurocard Centre Herald Park, Herald Drive, Crewe, England, CW1 6EG
RADIUS PAYMENT SOLUTIONS LIMITED
Matching previous names:
RADIUS · RADIUS GLOBAL14655929 - Incorporated on 10 February 2023
Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG
These two entities have switched names between them, the former Radius Payment Solutions Limited is now called Radius Limited and the present Radius Payment Solutions Limited was previously called Radius Limited, and Radius Global Limited. This is a breach of the Companies Act.
Referring again to the search results, it is noted that there are additionally four companies that have previously used the name Radius Limited.
Matching previous names:
RADIUS13439073 - Incorporated on 4 June 2021
86-90 Paul Street, London, England, United Kingdom, EC2A 4NE
12021833 - Dissolved on 23 March 2021
6 West Way, Slinfold, Horsham, England, RH13 0SB
03596837 - Dissolved on 8 April 2016
2 Burston Road, Putney, London, SW15 6AR
Matching previous names:
RADIUS01241271 - Incorporated on 21 January 1976
Southbank Central, 30 Stamford Street, London, England, SE1 9LQ
Six companies use or have used the same name, Radius Limited. These are events that should not occur. Duplicated names are prohibited on the register as the risk of clone company fraud increases which each duplication.
Looking at the details of RADIUS PAYMENT SOLUTIONS LIMITED which was previously called Radius Global Limited:
RADIUS PAYMENT SOLUTIONS LIMITED
Company number 14655929
Registered office address Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Company status Active
Company type Private limited Company Incorporated on 10 February 2023
Accounts First accounts made up to 31 March 2024 due by 10 November 2024
Confirmation statement Next statement date 9 February 2025 due by 23 February 2025 Last statement dated 9 February 2024
Nature of business (SIC) 99999 - Dormant Company
Previous company names
RADIUS LIMITED14 Apr 2023 - 28 Nov 2023
RADIUS GLOBAL LIMITED10 Feb 2023 - 14 Apr 2023
Note that Radius Payment Solutions is registered as dormant.
There are four directors of this company, three have resigned, leaving one active director, Lee John Everett, who is appointed to 29 companies, 25 of which are active (https://find-and-update.company-information.service.gov.uk/company/14655929/officers).
The active appointments to this identity for Lee John Everett are summarised below.
Lee John EVERETT personal appointments
RADIUS TELEMATICS LIMITED (09970051)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 31 March 2024
RADIUS BUSINESS SOLUTIONS MIDCO 1 LIMITED (14783380)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 29 January 2024
RADIUS BUSINESS SOLUTIONS MIDCO 2 LIMITED (14783384)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 29 January 2024
RADIUS BUSINESS SOLUTIONS BIDCO LIMITED (14783392)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 29 January 2024
RADIUS VELOS LIMITED (15240654)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, United Kingdom, CW1 6EG Appointed on: 27 October 2023
MAXI-LOW (UK) LIMITED (08184104)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 31 August 2023
RADIUS PAYMENT SOLUTIONS LIMITED (14655929)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 10 February 2023
RADIUS VEHICLE SOLUTIONS (NI) LIMITED (NI046821)
Correspondence address: Unit 33, City Business Park, Dunmurry, Belfast, Northern Ireland, BT17 9HY Appointed on: 29 September 2022
GUS COMMERCIALS LIMITED (NI051978)
Correspondence address: 22 Central Park, Mallusk, Newtownabbey, Co Antrim, BT36 4FS Appointed on: 29 September 2022
AIR TELECOM GROUP LIMITED (10740921)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 28 February 2022
AIR TELECOM UK LIMITED (06927845)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 28 February 2022
MILESTONE INSURANCE CONSULTANTS LIMITED (04587285)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 6 December 2021
SIGNATURE UNDERWRITING AGENCY LTD (08637877)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 6 December 2021
MILESTONE GROUP (HOLDINGS) LTD (08838627)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 17 November 2021
GO! HOLDINGS LTD (11379254)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 30 September 2021
RADIUS ENERGY LIMITED (11211289)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 30 April 2021
FRONTIER TELECOM LTD (07244453)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 23 March 2021
RAINBOW TELECOM IRELAND LIMITED (FC037995)
Correspondence address: Block 2, Galway Financial Services Centre, Moneenageisha Road, Galway, H91W1YV, Ireland Appointed: 1 March 2021
T.S.I. (IRELAND) LTD (NI034069)
Correspondence address: 42 Campsie Industrial Estate, Mclean Road, Eglinton, Londonderry, Northern Ireland, BT47 3XX Appointed 1 March 2021
TARIFFCOM LIMITED (SC221516)
Correspondence address: Euro Card Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 19 January 2021
RADIUS CHARGE LIMITED (13033954)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 20 November 2020
DCP (CREWE) LTD (NI060409)
Correspondence address: 42 Campsie Industrial Estate, Mclean Road, Eglinton, Londonderry, BT47 3XX Appointed on: 6 May 2020
RADIUS BUSINESS SOLUTIONS LIMITED (10887812)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, United Kingdom, CW1 6EG Appointed on: 21 April 2020
RADIUS PAYMENT SOLUTIONS TOPCO LIMITED (11047034)
Correspondence address: Euro Card Centre, Herald Park, Herald Drive, Crewe, CW1 6EG Appointed on: 30 January 2018
EUROPEAN DIESEL CARD LIMITED (05551346)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, Cheshire, CW1 6EG Appointed on: 18 June 2012
Judging from the names of these businesses, it looks like these could be companies set up to manage applications that could operate over the Icon Tower infrastructure. Many of these companies use the name Radius. It is highly likely that these are associated to Radius Global Infrastructure Inc. If this is the case, then it brings into question whether they might be evading OFCOM regulations requiring separation of retail applications and infrastructure provision.
Testing for multiple identities for Lee John Everett
A search in Companies House locates four identities with this name:
Total number of appointments 1 - Born September 1974
Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG
Total number of appointments 29 - Born September 1974
Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG
Total number of appointments 0 - Born October 1985
15 Winser Drive, Reading, United Kingdom, RG30 3EG
Total number of appointments 6 - Born September 1974
Eurocard Centre, Herald Park, Herald Drive, Crewe, Cheshire, CW1 6EG
Since three identities have the same address and date of birth, September 1974. We can conclude that these are certainly multiple identifies for the same person. Whether Lee John Everett born October 1985 is potentially the same person, using a different date of birth, requires determining.
The first identity listed for Lee John Everett, when clicked on, instead of identifying his appointment returns “Page not found” (https://find-and-update.company-information.service.gov.uk/officers/jg4TMOXSOvgUcr72x-WC6oaNYX8/appointments). This is an anomalous result from Companies House and suggests that this identity is being concealed with the assistance of Companies House.
The fourth identity listed above for Lee John Everett holds the following appointments:
UK FUELS LIMITED (02212080)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, Cheshire, CW1 6EG Appointed on: 1 April 2015
DIESEL CARD INTERNATIONAL LIMITED (NI033126)
Correspondence address: Unit 42 Campsie Real Estate, Campsie Industrial Estate, Mclean Road, Eglinton, Londonderry, Northern Ireland, BT47 3XX
Appointed on: 22 May 2014
RADIUS LIMITED (08260702)
Correspondence address: Eurocard Centre, Herald Park, Herald Drive, Crewe, England, CW1 6EG Appointed on: 8 April 2014
DCI CARD SERVICES LIMITED (NI044205)
Correspondence address: Unit 42 Campsie Real Estate, Campsie Industrial Estate, Mclean Road, Eglinton, Londonderry, Northern Ireland, BT47 3XX
Appointed on: 22 May 2014 Resigned on: 1 April 2015
FUEL CONTROL SERVICES LIMITED (SC179113)
Correspondence address: Flat 1, / 2, 10 Bluebell Drive Newton Mearns, Glasgow, Scotland, G77 6FN
Appointed on: 22 May 2014 Resigned on: 1 January 2015
UK DIESEL CARDS LIMITED (SC379124)
Correspondence address: Flat 1, / 2, 10 Bluebell Drive Newton Mearns, Glasgow, Scotland, G77 6FN
Appointed on: 22 May 2014 Resigned on: 1 January 2015
In conclusion, the registration of multiple entities under the name "Radius Global" in Companies House, including name-switching between Radius Limited and Radius Payment Solutions Limited, suggests potential clone company fraud and breaches of the Companies Act. The recurrent use of the name "Radius" across various companies raises significant concerns about the risk of clone company fraud. Additionally, the association of these companies with the same address and the presence of multiple identities for individuals such as Lee John Everett and Daniel John Hasselman point to efforts to obscure true ownership and control, which could facilitate regulatory evasion, including OFCOM regulations. This situation warrants further investigation to ensure compliance and transparency.
Overall Summary:
The application for the project presented for consultation involves a proposal with redacted details, submitted by Icon Tower Infrastructure Ltd, a UK company owned by Radius Global Infrastructure Inc.
Icon Tower Infrastructure Ltd, previously known as Radius BTS Ltd. and AP Mast Site Management Ltd., is a private limited company registered in the UK since 15 December 2017. It primarily operates in the real estate sector under the Standard Industrial Classification (SIC) code 68209.
The company's officers include Thomas David Evans serving as Secretary and Director, Scott Garland Bruce and Richard Irwin Goldstein, both serving as Directors, and Scott Emil Langeland, also serving as a Director.
Thomas David Evans holds two unique identifiers, one as a secretary and another as a director of Icon Tower Infrastructure Ltd, which is a breach of Section 1082 of the Companies Act 2006. Additionally, he holds appointments in multiple other companies, with a total of fourteen unique identities, raising concerns about potential synthetic identity fraud.
Scott Garland Bruce, Richard Irwin Goldstein, and Scott Emil Langeland each have multiple unique identifiers associated with their names, indicating potential breaches of the Companies Act and raising questions about the accuracy of corporate records.
AP WIRELESS (UK) LIMITED, the entity with significant control over Icon Tower Infrastructure Limited, is associated with a total of 5 charges, out of which 4 have been satisfied, and 1 remains outstanding. The outstanding charge, linked to Glas Trust Corporation Limited, was created on 9 November 2017, featuring a fixed charge without detailed specifications. The satisfied charges were all attributed to Deutsche Bank Trust Company Americas. The additional director of this company is Daniel John Hasselman. He holds appointments under three different identities, with one identity using a different year of birth, indicating synthetic identity fraud.
According to Companies House records, AP WIRELESS (UK) LIMITED does not have any active persons with significant control registered. This contradicts the statement in Icon Tower Infrastructure Limited's cover letter, which identifies Radius Global Infrastructure Limited as the owner. Further investigation into the ownership and control structure of AP Wireless (UK) Limited is warranted.
Additional Findings:
The registration of multiple entities under the name "Radius Limited" in Companies House, including name-switching between Radius Limited and Radius Payment Solutions Limited, previously called Radius Global Limited, suggests potential clone company fraud and breaches of the Companies Act. The recurrent use of the name "Radius" across various companies raises significant concerns about the risk of clone company fraud.
The sole director of Radius Payment Solutions Limited, Lee John Everett, has three identities indicating potential synthetic identity fraud. The anomalous "Page not found" result for one of his identities suggests possible concealment with the assistance of Companies House.
The association of these companies with the same address and the presence of multiple identities for the point to efforts to obscure true ownership and control, which could facilitate regulatory evasion, including OFCOM regulations.
Conclusion:
The application raises significant concerns regarding transparency and compliance with the Companies Act 2006, particularly with regard to the appointment of Thomas David Evans under multiple unique identifiers. This raises red flags for potential synthetic identity fraud, concealing interests from auditors and due diligence checks.
The presence of multiple unique identifiers associated with these individuals highlights significant risks to corporate transparency and accountability. The use of multiple identities and the potential involvement in clone company fraud necessitate thorough investigations and corrective measures to address potential breaches of the Companies Act.
Regulatory authorities and stakeholders must take prompt action to mitigate these risks and uphold the trust and confidence of shareholders and the broader business community. By ensuring compliance with regulatory requirements and enhancing corporate governance practices, we can strengthen transparency and accountability in the corporate sector and protect the interests of all stakeholders involved.
To Do:
Test the accounts for completeness and plausibility: Conduct a thorough examination of the financial accounts associated with the companies mentioned in this report. Verify the accuracy and completeness of the financial information to ensure compliance with regulatory standards and to assess the financial health of the entities involved.
Analyse the appointments held in separate identities: Investigate the appointments held by the directors in their separate identities to gain insight into potential discrepancies or irregularities. Analyse the implications of these multiple identities on corporate governance, regulatory compliance, and transparency.
Assess for Related Party Transactions: Evaluate the relationships between the companies and directors involved in this significant linked directorate to identify any potential related party transactions. Investigate whether these transactions have been appropriately disclosed and accounted for in financial reports and whether they comply with regulatory requirements.
Comprehensive Due Diligence: Recognise that this report provides only a preliminary overview and scratches the surface of a full due diligence process. Further investigation and analysis are necessary to uncover the extent of the issues identified and to address any additional concerns regarding corporate governance, regulatory compliance, and financial integrity.
Audits Compromised of All Companies: Ensure that audits are conducted for all the companies associated with the directors mentioned in this report. Verify the accuracy and reliability of financial statements, assess internal controls, and identify any potential risks or discrepancies that may require further investigation or remediation.
By addressing these action items, stakeholders can gain a deeper understanding of the complex interrelationships and potential risks associated with the companies and directors involved in this significant linked directorate. This will facilitate informed decision-making, enhance transparency and accountability, and mitigate potential risks to stakeholders and the broader business community.
Great work Alison, and thanks for your letter. I'll be in touch.