In my previous article on LLPs and why they are a boon to money launderers, I promised in Part 2 I would move on to Scottish Limited Partnerships. That research is still ongoing and I will be writing about it shortly. But in the meantime, I would like to take you on a journey.
It is a journey through a similar landscape, full of loopholes and anomalies, but this time I am solely going to restrict myself to information gleaned from the new (beta) Companies House website.
Anyone who has read my previous article will know that I am not a fan of the less than robust governance that is currently in place in respect of the accuracy and veracity of the information uploaded but, as part of my research, some of the discrepancies have become so breathtakingly obvious that I wanted to share them with a wider audience.
Let me be quite clear from the outset though; I am not pointing an accusatory finger at the people who are about to appear in my story. For all I know there are perfectly rational reasons to explain every one of the deficiencies we are about to see – it’s just that I can’t actually think of one.
My starting point was one of the names that cropped up in my previous article.
She it was who signed off three consecutive years of dormant accounts (2014/2015/2016) for Seletrade Impex LLP after they had acquired 994,200 shares, valued at £1,072,218 in AS Tosmares kugubuvetava, a Rigan Shipbuilder, in December 2013. I wondered if this was the only part she played in UK entities, so I looked her up on the Companies House website.
The answer was, no it was not her only role. I found 112 limited companies for which she was a director. Of those, 31 were still active. I decided to investigate further and chose, at random, a company called Marinostro Limited. This is what I found.
Marinostro was incorporated on 11 May 2007.
Initially, the directors were Nilka Ines Urieta Yee and Lawsons Secretaries Limited.
Nilka is from Panama and Lawsons Secretaries Limited are based in Edinburgh. Nilka has been a director of 12 UK Limited Companies but at the time of her appointment with Marinostro she was director of 6, two of which happened on the same day as her appointment to Marinostro, on 11 May 2007. The remaining five appointments all took place over the next 5 months.
This is intriguing as here is the relevant part of the form which she filled in to become a director:
And here are the other two forms she filled out the same day:
This is for Kelmeks Ltd
And this one is for Seatradex Ltd.
Note that all three answer “none” to other directorships and all three of these were, allegedly, sworn in form of a commissioner for oaths.
Let’s have a look at the other director, Lawsons Secretaries Limited. They appear to have been appointed director to around 100 companies, approximately 20 of which are still current. Lawsons Secretaries Limited was incorporated on 11 July 2006 and its current director is Joanne Wight.
This is a record of its filing history:
Now the observant among you will notice that every year since incorporation, Lawsons Secretaries Limited have filed dormant accounts which is interesting for a company which has been a director to around 100 different companies. And again, not altogether surprisingly, when Ms Wight completed the declaration in 2006, she said on the forms that she had no other directorships. I have counted a total of 157 – not all of which were prior to 2006 but some were and, anyway, every form I’ve checked since also states “none” in the box requesting other directorships.
Lawsons Secretaries resigned on 1 May 2008 to be replaced by Arran Secretaries Ltd. They were incorporated on 22 October 2007. Its current director is Alise Ilsley (remember her?)
They have also filed dormant accounts every year from 2008 to 2016. They currently hold a number of active directorships and many more that have since been dissolved.
Back to Marinostro Limited. What else do we know about them?
The good news is that they have registered a person of significant control (PSC). Here they are:
And here is Mirmar’s registration:
Oh look when they were registered. The same date as they became the PSC for Marinostro. Really?
And all we know about Mirmar is that the General Partners are Kensington Consultants Ltd and Montrose Assets Limited, both of which are based in Belize.
By the way, I didn’t mention what Marinostro do by way of business. Well, nothing actually because they have also filed dormant accounts since 2007 but they give a SIC code of 49410 – freight transport by road. It’s actually worth looking at at least one of the pages of their filing history:
I don’t know about you but I think that’s a lot of activity for a dormant company. And am I the only one to think it odd that a freight haulage company should have such a complex ownership, located in offshore locations, hiding behind a Limited Partnership PSC.
It will also come as no surprise to learn that Kensington Consultants and Montrose Assets are Designated Members to hundreds of LLPs.
Before I finish, let me summarise what I’ve found.
1. Numerous instances of incorporation forms showing the answer “none” to the question “Other directorships” when self evidently, many other directorships were held
2. Numerous instances of Limited Company Directors holding significant numbers of directorships and yet, year after year, they are returning dormant trading accounts
3. Instances of PSCs being registered with other companies the same day as they are formed
4. Numerous instances of supposedly dormant companies over a period of years, changing directors, registered address etc for no obvious economic purpose
I don’t know what you think but I do know that if any bank I have ever worked for, conducted KYC to the standard that we see here (and I’ve worked for one or two shockers!!) they would be banned from conducting any more business until it was rectified.
Why is it OK for Companies House to have such disregard for obviously inconsistent information when they are supposed to be in the vanguard of the new transparent ownership register brought about by 4MLD. What’s the point of being transparent if you can see clear through to the other side because there is nothing of substance to see in between?
We should all be incandescent that this supposedly new age of transparency is nothing but a chimera, which is defined by Collins as:
· a fabulous beast made up of parts taken from various animals
· a wild and unrealistic dream or notion