Multiple identities breach the law. Follow up with the Committee on Standards in Public Life.

Breaches Section 1082 (multiple unique identifiers) and Section 441 (accurate accounts).

This is a copy of the email sent today, 10 December 2024, with a minor spelling correction.

For the attention of Mr Chalmers.

Dear Mr Chalmers.

I am writing to follow up on our conversation at the Institute for Government event on 21 November 2021, regarding the critical issue of multiple identities in Companies House being used by public officials to conceal interests and potentially enable fraud.

The Issue

I have observed a worrying trend of civil servants and politicians registering multiple identities in Companies House. This practice allows them to conceal interests and fail to declare them, which is a breach of Section 1082 of the Companies Act 2006. Here is the specific concern I raised during the event:

"I’ve observed a worrying trend of civil servants and many politicians having registered multiple identities in Companies House. The way accounts, auditors and KYC checks work is that you are supposed to have one unique identifier and all of your appointments associated to that identifier. But if you leave out your middle name it appears that Companies House gives you a second unique identifier and then it’s really easy to conceal interests that you then fail to declare. I’ve noticed this and raised many complaints with Mr Greenberg. He has addressed the failure to declare interests and made those MPs declare those interests but he says that the multiple identities in Companies House is beyond his remit. The suggestion is that you should take it to Action Fraud because it is a breach of Section 1082 of the Companies Act (2006) to have multiple identities, the problem is Action Fraud won’t act on it and when I do compliance assessments of the leadership of Action Fraud I find that (some of them) have multiple identities, so they have no incentive to address it. How could the Committee address this significant breach of transparency as well as breach of the law? Remember that declaring interests in the register of interests is a legal requirements and when you don’t put your interests in the Register of Interest, that’s a breach."

You did not respond to this question, at the time, but I waited and we spoke afterwards. During our conversation, you acknowledged the concern and agreed that it was a serious issue. You reassured me that you would follow it up and suggested I approach the Committee on Standards in Public Life for further comment. However, I am concerned that you were not aware of this issue despite my detailed submission to the Committee's consultation on "Accountability within public Bodies - acting on early warning signs" in April 2024. Here is an excerpt from my submission:

"I have identified widespread use of two simple methods of fraud, employed by individuals in control of these Public Bodies, which have compromised the accounts of every Public Body studied and requires police investigation. However, the compromises extend to the leadership of the fraud and cyber-security investigatory services, which are supplied by the City of London Police through their “Action Fraud” crime reporting system. My repeated attempts to report the methods enabling widespread fraud have been deflected and remain inadequately investigated." (April 2024) My full response is available here: Response to open consultation on Accountability within public bodies - acting on early warning signs.

Could you please confirm whether my response to the Committee's consultation on 'Accountability within public Bodies - acting on early warning signs' in April 2024 was received and processed? If so, could you provide an explanation of what actions were taken or considered in response to my submission?

While the Economic Crime and Corporate Transparency Act 2023 is a significant step towards improving transparency and reducing economic crime, however, it will not enable the detection or prevent the establishment of multiple identities unless additional systematic measures are implemented to cross-reference and verify identities comprehensively.

Request for Action

Given the severity of this issue and its implications for public sector integrity, I urge the Committee on Standards in Public Life to take the following actions:
1. Conduct a Thorough Investigation: Investigate the use of multiple identities by public officials and the potential breaches of law and ethical standards.
2. Police Investigation: Ensure that individuals found to have multiple identities and who have failed to declare interests are investigated by the police. This investigation should include a full discovery of all their business dealings to uncover any potential fraudulent activities.
3. Collaborate with Companies House: Work with Companies House to implement stricter identity verification processes and cross-referencing mechanisms to detect and prevent multiple identities.
4. Advocate for Legislative Changes: Advocate for any necessary legislative changes to close this loophole and strengthen accountability measures.
5. Enhance Enforcement: Ensure that regulatory bodies, including Action Fraud, are held accountable for addressing these breaches and that there are clear penalties for non-compliance.

Conclusion

The issue of multiple identities in Companies House is a significant threat to transparency, accountability, and the integrity of public life. It is imperative that the Committee addresses this issue promptly to prevent further exploitation by individuals who may be using these tactics to conceal their interests and engage in fraudulent activities.

Drawing on my experience as an IBM Systems Engineer, I must alert you that multiple identities for an individual fundamentally breach accountability and cybersecurity principles. Fraud is the most frequent crime, estimated at £200 billion, and public sector fraud is estimated at £50 billion. Multiple identities, used to conceal interests that fail to be declared, are a fundamental enabler of fraud.

I am certain that you are aware that these breaches by public officials put the public at risk of money laundering and terrorism financing from a cadre of individuals who act with duplicity and have seized positions of control throughout HM Government and the private sector.

Please will you engage with this serious issue which has rendered our systems of governance and accountability compromised?

Thank you for your attention to this critical matter.

Yours sincerely,

Alison Wright.

Brighton.

Here is a link to my document about the event at which I met Mr Chalmers and raised this issue on 21 November 2024