Transparency Task Force

Letter to raise awareness to systematic identity and clone company breaches by establishment directors.

Dear Chelsea,

I have been researching and publishing Compliance Assessments of company directors who are members of the UK establishment.

My focus has been on prima facie breaches of the Companies Act 2006 (CA2006) as evidenced by registrations in Companies House and their Register of Interests.

The evidence is that there is widespread identity fraud, through registration of multiple identities for an individual in Companies House, in breach of section 1082 (CA2006). This is often accompanied with un-resigned directorships of dissolved companies with accounts overdue, in breach of section 441 (CA2006), and involvement in companies with similar names, in breach of section 66 (CA2006). This enables the concealment of interests that are failed to be declared, unmonitored bank accounts in dissolved company names, and diversion of funds between similarly named companies.

Establishing multiple identities compromises audits and Know Your Customer analysis. These are the controls that are intended to prevent money laundering, people trafficking and terrorism financing. Since multiple identities, unmonitored bank accounts in clone company names subvert the processes that are designed to prevent these crimes, the risk that these establishment figures are involved in activities of money laundering, people trafficking and terrorism financing is high.

If found to have benefitted materially from these breaches of the Companies Act 2006 then the individual must face the due process of the law to determine whether

• multiple identities and similar names (sections 1082 and 66 (CA2006) breaches) meets the definition of section 2 of the Fraud Act 2006 (FA2006), fraud by false representation.

• failing to register interests meets the definition of section 3 (FA2006), fraud by failing to disclose information.

• a forensic audit would be able to answer the question of whether or not they have breach section 4 (FA2006) fraud by abuse of position.

Please refer to my published Compliance Assessments located at

.

Tilores, using their software, deduplicated the active companies in Companies House and identified approximately 600,000 duplicate director profiles out of 10.1 million records, resulting in a duplicate rate of about 6% (https://tilores.io/companies-house-deduplicated).

At 94% compliance, the vast majority of directors have a single unique identity. It’s a pity that so many MPs and Lords are amongst the 6% who display characteristics of fraud.

Concern about the use of Companies House to register multiple identities and clone companies, reflect compromised transparency, which overlaps with the focus of the Transparency Task Force. Might you publish my observations and work with me to draw attention to and rectify the harm presently enabled by Companies House's weak deduplication processes and zero enforcement of final Accounts and closure of bank accounts of dissolved entities?

Yours sincerely,

Alison Wright.

Sent 17 /4/2025 to Andy Agathangelou:

• FRSA Founder, Transparency Task Force;

• Certified Social Enterprise Chair, Secretariat Committee, APPG on Investment Fraud and Fairer Financial Services

• Founder, The International League of Ethical Financial Services Leaders

• Founder, The March for Justice

• Chair, Violation Tracker UK

• Advisory Board Co-Founder, The Woodford Campaign Group

• Founder, RSA’s Responsible Finance for Good Network

• Governor, The Pensions Policy Institute

• Associate Member, Better Finance