Copy of my complaint sent the House of Lords' Commissioner for Standards:
"Name: Alison Wright
Details of complaint
Member or member’s staff concerned: Lord Waheed Alli
Substance of complaint:
Lord Waheed Alli appears to have breached several aspects of the House of Lords Code of Conduct. Discrepancies exist in his Register of Interests and Companies House records, indicating multiple identities with different dates of birth (1962 and 1964) (https://find-and-update.company-information.service.gov.uk/search?q=Waheed+Alli). He has failed to declare directorships in a company called The Charlie Parsons Foundation and recent former interests in Silvergate Group Holdings Limited and Vampire Squid Productions Limited. Additionally, he did not disclose several Person with Significant Control (PSC) roles in BM Creative Management Limited (which is incorrectly declared as "Ltd"), Silvergate BP Bidco Limited (which is incorrectly declared with "Limited" omitted), Silvergate Media Limited, and Silvergate PPL Limited, which are both incorrectly declared using "Ltd" rather than "Limited". His failure to disclose that he is PSC of Silvergate BP Bidco Limited conceals that he is a related party of Columbia Pictures Corporation Limited. Some interests are miscategorized as non-financial when they should be listed as directorships such as 450 Holdings (with overdue accounts), MAC (BVI) Limited, Le Chameau Holdings Limited, Executive Pipeline Limited, SGIF 2 Investments Limited, Hignell Gallery Limited and Olga TV Limited. Furthermore, he has not disclosed his involvement in dissolved companies with overdue accounts within the last 3 years, such as Silvergate Egglington Limited, and Koovs PLC, which has insolvency irregularities relating to outstanding charges. There is also a query regarding a possible conflict of interest involving a related party named Waheed Alli born October 1970.
Aspects of the Code engaged:
Paragraph 9 - Personal honour: Multiple identities and discrepancies in personal details undermine the principle of personal honour.
Paragraph 10 - Public interest: Failure to disclose directorships and PSC roles compromises transparency and accountability.
Paragraph 12(a) - Registration of interests: Inaccurate categorization of interests and omission of significant roles violate the requirement for complete and accurate registration.
Paragraph 16 - Declaration of interests: Non-disclosure of dissolved companies with overdue accounts contradicts the obligation to declare relevant interests.
Any other supporting details or evidence:
The compliance assessment highlights seven unique identities for Lord Alli in Companies House, with discrepancies in birth years. Undeclared interests include active roles in several companies, and misclassification issues are evident in his Register of Interests. These issues raise concerns about transparency and adherence to the Code. Further investigation is warranted to ensure compliance with the principles of public life. The full compliance assessment can be found here: https://alisonwright.substack.com/p/lord-wahid-alli-donor-to-keir-starmer?r=15h096.
The Secretary of State may by regulations make provision for the use, in connection with the register or dealings with the registrar], of reference numbers (“unique identifiers”) to identify each person who—
(a)is a director of a company,
(b)is secretary (or a joint secretary) of a company,
[F3(ba)is an authorised corporate service provider;
(bb)is an individual whose identity is verified,] or
(c)in the case of an overseas company whose particulars are registered under section 1046, holds any such position as may be specified for the purposes of this section by regulations under that section.
Can you point to such regulations having been made by the Secretary of State?
My experience is that company formation agents now require ID verification of company officials. The public register no longer requires publication of home addresses of company officials and service addresses can be used. A director may have different service addresses for each of their directorships.
Thank you for your comment regarding Section 1082 of the Companies Act. Despite the lack of detailed regulations from the Secretary of State, the law clearly intends for identifiers to be unique. By explicitly naming them "unique identifiers," the law underscores their purpose in maintaining the integrity of corporate records.
Unique Identifiers: Companies House has confirmed that unique identifiers are established based on a person's name, date of birth, and usual residential address, which the director has a duty to keep up to date. By varying any of these attributes by even a day or a letter, another unique identifier is automatically generated. The onus is on the director to ensure these details are correct because additional identifiers, whether created accidentally or deliberately, compromise visibility of all their interests for audit and KYC checks. The residential address is not published, directors specify a correspondence address instead, which is published.
Current Practices: It is acknowledged that company formation agents now require ID verification, which aligns with the broader goal of ensuring accurate identification of company officials. However, if an individual has two homes and uses different residential addresses for company registrations, it can result in multiple identities being created.
Regulatory Intent: The overarching intent behind this section of the law is to enhance the integrity of corporate records and facilitate effective oversight by regulatory bodies. By designating these as "unique identifiers," the law makes it clear that they are intended to be distinct for each individual, aiding in the prevention of fraudulent activities and maintaining trust in corporate dealings. It is unfortunate that the Secretary of State has not provided more detailed regulations to ensure that this law is fully enforced.
Risk of Multiple Identifiers: Multiple identifiers (or identities) confound audit and KYC processes, leaving the public vulnerable to risks such as money laundering, terrorism financing, and human trafficking. These identifiers are critical tools relied upon to prevent fraud, and any compromise in their accuracy undermines these efforts.
In conclusion, while there may be room for interpretation regarding the specifics of implementing Section 1082, its foundational purpose is to ensure uniqueness and consistency in identifying individuals involved in company management. This principle remains vital for upholding transparency and accountability in corporate governance.
It is beyond disgraceful that the deceit you are uncovering is happening with no apparent redress. The people who govern us, and their cronies, appear to be above the Law of the land. I despair for the future.
We need to share this information as much as possible as the main stream or alternative media won't take this on, because many of their directors are at it too. Once this gets address our future will look a lot brighter. We need zero tolerance of identity fraudsters running the country. We need to weed them out prior to election since this method underpins serious organised crime at a scale that's hard to imagine but explains why our policies are a global hypocracy.
Copy of my complaint sent the House of Lords' Commissioner for Standards:
"Name: Alison Wright
Details of complaint
Member or member’s staff concerned: Lord Waheed Alli
Substance of complaint:
Lord Waheed Alli appears to have breached several aspects of the House of Lords Code of Conduct. Discrepancies exist in his Register of Interests and Companies House records, indicating multiple identities with different dates of birth (1962 and 1964) (https://find-and-update.company-information.service.gov.uk/search?q=Waheed+Alli). He has failed to declare directorships in a company called The Charlie Parsons Foundation and recent former interests in Silvergate Group Holdings Limited and Vampire Squid Productions Limited. Additionally, he did not disclose several Person with Significant Control (PSC) roles in BM Creative Management Limited (which is incorrectly declared as "Ltd"), Silvergate BP Bidco Limited (which is incorrectly declared with "Limited" omitted), Silvergate Media Limited, and Silvergate PPL Limited, which are both incorrectly declared using "Ltd" rather than "Limited". His failure to disclose that he is PSC of Silvergate BP Bidco Limited conceals that he is a related party of Columbia Pictures Corporation Limited. Some interests are miscategorized as non-financial when they should be listed as directorships such as 450 Holdings (with overdue accounts), MAC (BVI) Limited, Le Chameau Holdings Limited, Executive Pipeline Limited, SGIF 2 Investments Limited, Hignell Gallery Limited and Olga TV Limited. Furthermore, he has not disclosed his involvement in dissolved companies with overdue accounts within the last 3 years, such as Silvergate Egglington Limited, and Koovs PLC, which has insolvency irregularities relating to outstanding charges. There is also a query regarding a possible conflict of interest involving a related party named Waheed Alli born October 1970.
Aspects of the Code engaged:
Paragraph 9 - Personal honour: Multiple identities and discrepancies in personal details undermine the principle of personal honour.
Paragraph 10 - Public interest: Failure to disclose directorships and PSC roles compromises transparency and accountability.
Paragraph 12(a) - Registration of interests: Inaccurate categorization of interests and omission of significant roles violate the requirement for complete and accurate registration.
Paragraph 16 - Declaration of interests: Non-disclosure of dissolved companies with overdue accounts contradicts the obligation to declare relevant interests.
Any other supporting details or evidence:
The compliance assessment highlights seven unique identities for Lord Alli in Companies House, with discrepancies in birth years. Undeclared interests include active roles in several companies, and misclassification issues are evident in his Register of Interests. These issues raise concerns about transparency and adherence to the Code. Further investigation is warranted to ensure compliance with the principles of public life. The full compliance assessment can be found here: https://alisonwright.substack.com/p/lord-wahid-alli-donor-to-keir-starmer?r=15h096.
Yours sincerely,
Alison Wright"
Section 1082 of the Companies Act states
The Secretary of State may by regulations make provision for the use, in connection with the register or dealings with the registrar], of reference numbers (“unique identifiers”) to identify each person who—
(a)is a director of a company,
(b)is secretary (or a joint secretary) of a company,
[F3(ba)is an authorised corporate service provider;
(bb)is an individual whose identity is verified,] or
(c)in the case of an overseas company whose particulars are registered under section 1046, holds any such position as may be specified for the purposes of this section by regulations under that section.
Can you point to such regulations having been made by the Secretary of State?
My experience is that company formation agents now require ID verification of company officials. The public register no longer requires publication of home addresses of company officials and service addresses can be used. A director may have different service addresses for each of their directorships.
Thank you for your comment regarding Section 1082 of the Companies Act. Despite the lack of detailed regulations from the Secretary of State, the law clearly intends for identifiers to be unique. By explicitly naming them "unique identifiers," the law underscores their purpose in maintaining the integrity of corporate records.
Unique Identifiers: Companies House has confirmed that unique identifiers are established based on a person's name, date of birth, and usual residential address, which the director has a duty to keep up to date. By varying any of these attributes by even a day or a letter, another unique identifier is automatically generated. The onus is on the director to ensure these details are correct because additional identifiers, whether created accidentally or deliberately, compromise visibility of all their interests for audit and KYC checks. The residential address is not published, directors specify a correspondence address instead, which is published.
Current Practices: It is acknowledged that company formation agents now require ID verification, which aligns with the broader goal of ensuring accurate identification of company officials. However, if an individual has two homes and uses different residential addresses for company registrations, it can result in multiple identities being created.
Regulatory Intent: The overarching intent behind this section of the law is to enhance the integrity of corporate records and facilitate effective oversight by regulatory bodies. By designating these as "unique identifiers," the law makes it clear that they are intended to be distinct for each individual, aiding in the prevention of fraudulent activities and maintaining trust in corporate dealings. It is unfortunate that the Secretary of State has not provided more detailed regulations to ensure that this law is fully enforced.
Risk of Multiple Identifiers: Multiple identifiers (or identities) confound audit and KYC processes, leaving the public vulnerable to risks such as money laundering, terrorism financing, and human trafficking. These identifiers are critical tools relied upon to prevent fraud, and any compromise in their accuracy undermines these efforts.
In conclusion, while there may be room for interpretation regarding the specifics of implementing Section 1082, its foundational purpose is to ensure uniqueness and consistency in identifying individuals involved in company management. This principle remains vital for upholding transparency and accountability in corporate governance.
Your work is so detailed and brilliant.
It is beyond disgraceful that the deceit you are uncovering is happening with no apparent redress. The people who govern us, and their cronies, appear to be above the Law of the land. I despair for the future.
We need to share this information as much as possible as the main stream or alternative media won't take this on, because many of their directors are at it too. Once this gets address our future will look a lot brighter. We need zero tolerance of identity fraudsters running the country. We need to weed them out prior to election since this method underpins serious organised crime at a scale that's hard to imagine but explains why our policies are a global hypocracy.
Brilliant work as ever Alison thank you.