Blackmore Bond – Two frauds don’t make a right

Another week and further disturbing developments in respect to the Blackmore Bond.

Before proceeding, I am going to make my formal allegations here and now, front and centre. I have accumulated a substantial amount of evidence from multiple sources, and these allegations are now, in my opinion, the only conceivable conclusions that can be drawn from this evidence and the actions of various parties. They are that:

  1. The FCA, and its senior executives, including its former CEO and now Bank of England Governor Andrew Bailey, and City of London Police/ActionFraud/NFIB have been, and are, deliberately concealing and suppressing evidence of fraud in respect to Blackmore Bond PLC so as to prevent all mention of fraud, and prevent a criminal investigation & full public enquiry.

2. The intent of this dishonest suppression and concealment is twofold:

a) To dishonestly deceive an insurance company (or companies) into making a payout to investors under a Capital Guarantee Scheme that existed for Blackmore Bond investors.

b) To be in a position, if the deception did force the insurance company (or companies) into paying out, to claim that little or minimal losses had occurred for investors and therefore no need for a full public, and top to bottom, enquiry into this case, and the handling of it by The FCA and City of London Police/ActionFraud/NFIB.

An enquiry that would expose the full extent of the failings of The FCA and City of London Police/ActionFraud/NFIB, who both had reports of fraud and breach of FSMA & FCA COBS dating back to 2016, against Blackmore Bond, other ‘Blackmore’ entities and the Directors of Blackmore Bond, and the subsequent dishonesty by The FCA and City of London Police/ActionFraud/NFIB in what appears to be attempts to conceal those failings.

3. The FCA has dishonestly represented to the media and the public since 2019 that everything pursuant to Blackmore Bond is beyond their perimeter, authority, scope and powers to act, and with intent to conceal the above mentioned failings by The FCA and City of London Police/ActionFraud/NFIB.

4. John Glen MP, HM Treasury and Mel Stride (Chair of the Treasury Select Committee (TSC)) has sought to ignore and suppress all evidence pursuant to Blackmore Bond, and indeed all mention of it, despite its parallel and absolute relevance to the LC&F failure, the findings of Dame Gloster, and cross examination value in respect to the false and/or misleading testimony of Andrew Bailey, Nikhil Rathi, Charles Randell and other senior executives that testified before the TSC in respect to the LC&F failure and Dame Gloster’s findings.

5. It is my opinion that Mr Glen on behalf of HM Treasury and others, and Mr Stride have conducted this suppression and concealment of evidence, with intent to:

a) Further the dishonest efforts of The FCA, its senior executives and City of London Police/ActionFraud/NFIB outlined above

b) Prevent an investigation and full enquiry that would expose the failings and dishonesty of The FCA and City of London Police/ActionFraud/NFIB and, in respect to The FCA, not just in this case but also LC&F, Connaught and others.

I will accept to some extent that Mr Stride and perhaps some others believed that they faced a moral dilemma and that their actions were in the best interests of these non-sophisticated and pensioner investors.

However, such beliefs are wrong and ‘misguided’ as I will outline later in this report.

They are my formal concerns, conclusions and allegation.

For the record and avoidance of doubt; Two frauds don’t make a right. It is not in the best interests of investors or the public at large, and will ensure that the same frauds and scams will occur again and again. Indeed, had The FCA not acted similarly in respect to Connaught over a decade ago, even destroying the whistleblower and his life in an effort to conceal their failings and their involvement in aspects of that fraud, then perhaps LC&F and countless other scams and frauds would not have occurred thereafter.

Public interest disclosure

I have raised these concerns with all parties named above, between May 4th and May 9th, and various other concerns dating back to March 2017, and all afforded the opportunity to challenge the conclusions and the evidence that I have. There has been no denial of any of the concerns raised as you will see, and only silence by several parties in return for the most part.

For the record, and having given all parties the opportunity to comment and challenge, I will have no problem in issuing an apology or retraction of any of the allegations, in the event that any of the parties can explain and prove to me and the public, that they are incorrect and that there is another conceivable explanation.

What I am not prepared to do is stay silent and allow my concerns and evidence be ignored, and essentially be ‘buried’ by the wall of silence. Enough really is enough, and time now for nothing but truth, fact and full transparency.

The last straw

This week on May 26th John Glen MP and Minister of State as Economic Secretary to the Treasury provided an answer in the House of Commons to MP’s and the public, to a question as to the making of a decision not to establish a compensation scheme for Blackmore Bond investors. His response and justification was one that featured multiple false representations, all of it contrary to the facts and evidence that I have provided him in recent months. For the record he said:

I am acutely aware of the situation at Blackmore Bond plc, and I am mindful that many individuals have lost money after investing in minibonds with the firm, which must be extremely distressing.

The Financial Services Compensation Scheme (FSCS) is the compensation scheme of last resort for financial services. The FSCS is an independent non-governmental body that carries out its compensation function within rules set by the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA), who are also independent of Government. Its scope is strictly limited and it can only pay compensation when a relevant regulated activity has been undertaken.

It is an important point of principle that the government does not step in to pay compensation in respect of failed financial services firms that fall outside of the FSCS. Doing so would create the wrong set of incentives for individuals and an unnecessary burden on the taxpayer.

However, as you will be aware, the government has taken the extraordinary step of establishing a compensation scheme for another failed minibond firm, London Capital & Finance (LCF). The government has considered the issues carefully, and the situation at LCF is unique and exceptional. While other minibond firms have failed, LCF is the only minibond firm which was authorised by the FCA and sold bonds in order to ‘on-lend’ to other companies. In particular, Blackmore Bond plc was not authorised by the FCA, and was not undertaking a regulated activity.

While I have not seen evidence that would indicate that the regulatory failings at the FCA were the primary cause of the losses incurred by LCF bondholders, they are a significant factor that the government has taken into account when deciding to establish this scheme.

  • Mr Glen falsely represented that Blackmore Bond was beyond the perimeter, scope, authority and powers of The FCA.
  • Mr Glen ignores the FACT that Blackmore Bond and the way it was being sold was ABSOLUTELY in breach of FSMA and FCA COBS, which absolutely prohibits the selling of ‘non-regulated’ investment products to non-sophisticated individuals.
  • Mr Glen ignores the FACT that evidence of fraud and breach of FSMA And FCA COBS involving Blackmore Bond, its Directors and their various ‘partners’, was reported to both The FCA and City of London Police/ActionFraud/NFIB independently, and in both cases as early as 2016 and before losses could have incurred, and could have been limited or stopped altogether.
  • Mr Glen ignores the FACT that both The FCA and City of London Police/ActionFraud/NFIB have an obligation to share information and evidence with each other. Both either failed to, or chose not to, share their evidence and information with each other, or they did share their evidence and information and did mutually agree that dishonesty and concealment was the best course of action. Either scenario is a gross failure by both.
  • Mr Glen ignores all of the evidence that I have provided him and his department, all of which proves scenarios contrary to that which he put forward last week in this answer to Parliament.

I warrant that the concealment occurred from the point that they discovered there were real concerns with Blackmore Bond, and the realisation that they had early reports that they had ignored. Having realised that they had dropped the ball, instead of picking it up, admitting their failings and taking action, they decided to bury the ball. And knew that, in so doing, they would be ‘burying’ investors along with it.

  • HOWEVER, AND IMPORTANTLY, Mr Glen does accept that where it can be proven that the ‘primary cause of losses’ were ‘regulatory failings at The FCA’, then the Treasury has an obligation to compensate victims.

It is clear and unequivocal that the primary cause of losses was exactly such FCA regulatory failings and failings by City of London Police/ActionFraud/NFIB, and therefore Mr Glen, by this very standard, should see to it that victims should be compensated in full as a result, as well as there being a full top to bottom enquiry.

Recent developments and discoveries

Moving on to recent developments. On May 4th I sent this email (below) below to FCA CEO Nikhil Rathi, FCA Chairman Charles Randell, Andrew Bailey, Bank of England Governor and former FCA CEO, John Glen MP, Mel Stride MP, Steve Baker MP (TSC member alongside Mr Stride) and the press offices of the Bank of England And FCA.

Attached to it was the article that you will read below.

Before you read it, you should be aware that I already had concerns that the conclusions and allegations that I put forward above were the disturbing reality. I didn’t want to believe it but (and you will realise why when you read this article and the evidence within it) no matter how I processed the evidence I had, and considered the various actions or lack of actions by certain parties, I could not produce any other conceivable conclusions.

The key to my disturbing concerns was a Capital Guarantee Scheme (CGS) that Blackmore Bond investors had alerted me to after my presentation of March 17th at the Transparency Taskforce Symposium dedicated to Blackmore Bond.

For the record, it was not a “Guarantee from one of the world’s largest banks” as I heard this product being marketed and sold, and had reported to The FCA in March 2017. Far from it. That representation remains as false and criminal today as it was in March 2017 when I heard it and reported it.

The CGS was an ‘Insurance Policy’ obtained on behalf of investors that purported to payout up to £75,000 per investor in the event that investors suffered any losses. It was arrranged by a UK based FCA regulated insurance broker.

This FCA regulated insurance broker is another element of Blackmore Bond that absolutely fell well within The FCA perimeter, scope and powers. This was an FCA regulated firm! And bound to sell only products that were suitable and appropriate etc. The FCA and Mr Glen have both dishonestly ignored this FCA regulated element, and concealed it from the public when making their false representations as to beyond all FCA scope and powers.

However, the insurance companies providing this CGS were both based in…… Costa Rica. It will perhaps come as no surprise to anyone that, over a year since the collapse the insurance companies involved have not paid out on this CGS Insurance. More on this later.

However, and importantly, the evidence that investors had given me revealed a major issue, and that which I began to believe explained what was going on. It read, and please pay careful attention to that part I have highlighted in bold:

“To seek to protect Bondholders in such circumstances, the Directors have put in place protection for Bondholders such that in the case of any shortfall or default in repaying Bondholders at the time redemption is due, a Capital Guarantee Scheme is in place to seek to ensure that all investors are (in the absence of any fraud of the Company’s directors, and subject to the Directors complying with certain strategic limits on investment which serve to further diversify and de-risk the Company’s investment portfolio) repaid any shortfall in the amount they recover from the Company (in the event of its liquidation or insolvent administration) up to a maximum sum of £75,000. “

The CGS Insurance policy contained an exemption whereby it would not payout if there was fraud by the Company’s Directors. And therein lies the rub.

Notwithstanding that I don’t believe the policy is worth the paper it is written on in any event, because of the other exemption “….subject to the Directors complying with certain strategic limits on investment which serve to further diversify and de-risk the Company’s investment portfolio“. An investment generally fails if there is fraud and/or the portfolio is not properly diversified. Blackmore Bond portfolio was hardly ‘diversified’, if it existed at all and upon liquidation of the portfolio, it was discovered that there was no value whatsoever. This other term is the catch all that any insurer could use to argue must have been breached for the losses to have occurred, and justify non payment.

In this respect, I would ask what steps that the insurers, the trustees and The FCA regulated insurance broker undertook to ensure that the ‘diversification’ conditions were being met at inception of the policy and year on year and with the issues of each further tranche of Blackmore Bonds. They must have had obligations in this respect.

What steps did they take and, if steps were taken, what evidence, information or declarations were provided to them by Directors, Shareholders, accountants, auditors or Trustee etc. in response?

However, my concern was that this ‘fraud’ exemption was the reason that the FCA and City of London Police/ActionFraud/NFIB, were behaving in the extraordinary fashion that I was witnessing, and for the truly extraordinary evidence that was being provided to me by Blackmore Bond investors, in the shape of responses from the NFIB (National Fraud Intelligence Bureau), the unit that reviews and assesses all reports to Action fraud.

I did not want to believe this. If my concerns were correct, this would potentially represent insurance fraud being committed by The FCA and City of London Police/ActionFraud/NFIB. But I could see no other conceivable explanation for what you are going to read below.

HOWEVER, to corroborate this, I needed to prove that The FCA was aware of this CGS Insurance policy and this ‘fraud’ condition/exemption.

From experience, I know that to get a direct answer from The FCA, never ask the direct question. If I ask them if they’re aware of this CGS Insurance, they will cite FSMA or some other reason not to answer. I have found that the way to obtain the answer or information you are seeking from The FCA, is to ask a different question, or raise a different concern or allegation, a defence to which would be for them to provide the information you were really seeking.

My article below was drafted to see what responses I would get from all parties to its contents and concerns, but particularly to see if The FCA would confirm their awareness of this CGS Insurance. I will highlight where the draft article I sent to these parties ends, and the new part of this investigatory piece begins.

Any notations since the draft was produced can be found in red within the article.

The ‘Article’ below is that which was attached to my 4th May email.

In March of this year I made a presentation at a Transparency Taskforce Symposium dedicated to the Blackmore Bond collapse and the culpability of The FCA (Financial Conduct Authority) in respect to it.

For those that have not seen it, the presentation can be viewed via the link below. My presentation begins at approximately 38 minutes in.

However, in the weeks since this presentation the scandal has deepened, so much so that I do not necessarily believe that The FCA and several senior executives and former executives have not crossed a line and entered the far more serious realm of criminality.

Following the above presentation, the Transparency Taskforce issued a call for Blackmore Bond investors to contact me. A call for a full enquiry had been made, and more support and evidence was always going to be needed to ensure that an enquiry was launched.

It is clear from the actions and words of John Glen MP of the Treasury, and Mel Stride MP of the Treasury Select Committee (TSC) that the Blackmore Bond is a matter that they have zero intention of investigating and continue to avoid all mention of it, and that Steve Baker MP of the TSC appears rather more keen, judging by his uncomfortable ‘chummifying’ questioning (I use the term ‘questioning’ in the very loosest sense) of Andrew Bailey, to imply that the blame lay with the victims.

Indeed, Mr Stride and the TSC continue to ignore, when questioning all concerned with the LC&F collapse and failings, the substantial evidence I have presented to them in respect to the Blackmore Bond, all of which challenges or exposes the very testimony being put to the TSC by the procession of ‘witnesses’ including Andrew Bailey, Nikhil Rathi, Charles Randell, Megan Butler and Jonathan Davidson.

Why would Mr Stride and the TSC ignore evidence that challenges, if not proves, that the very testimony being put to them by the Bank of England Governor and the CEO and Chairman of The FCA, is entirely false or misleading?

The difference between LC&F and Blackmore Bond is that The FCA has successfully played the ‘incompetence’ card in respect to LC&F. The standard playbook of banks and their lawyers; “Lie and deny, but if that fails, better to appear incompetent than corrupt”. The FCA and Bailey claims that had they known about LC&F earlier they would have acted and that the damage and losses to victims would have been less.

Whereas, in the case of the Blackmore, Bailey and The FCA don’t have this luxury:

  1. The FCA knew about Blackmore Bond marketing and selling to non-sophisticated customers at least as early as March 2017.
  2. Mark Steward, Head of FCA Enforcement received a report in March 2018 from an IFA raising serious concerns in respect to Blackmore Bond and its Directors.
  3. Andrew Bailey, Mark Steward and Jane Attwood (Head of FCA Intelligence) were made personally aware in August 2018 of my reports made in March 2017 and my further and ongoing concerns at the apparent lack of action by The FCA in respect to them.

I now know that The FCA was in receipt of reports of fraud by Blackmore Bond Directors at least as early as 2016 if not before, and months before my first reports in March 2017.

The FCA did…… Nothing. And Blackmore Bond investors would go on to suffer the exact fate of LC&F investors. Loss of their entire investment.

The FCA under Andrew Bailey and even in April 2021 under new CEO Nikhil Rathi continue to make false representations claiming that EVERYTHING to do with Blackmore Bond was beyond the FCA’s perimeter, scope and powers.

These are knowingly false representations. I will produce a separate report as to why. For now I want to focus on the disturbing recent developments.

In the days following the presentation I was contacted by numerous investors in Blackmore Bond. Each shared their information and their story. It will come as no surprise that some of the stories were incredibly upsetting, and the consequences for many of the victims are financially and emotionally devastating, so much so that some have experienced that darkest of places where none of us want to go, or should ever find ourselves in.

I shared several of these harrowing stories, anonymised, with Mel Stride MP and Steve Baker MP of the TSC and asked them both for their response and a suggestion as to how perhaps I should respond. Neither have bothered to respond personally or on behalf of the TSC. Anything to avoid mentioning the Blackmore Bond and those that have lost everything, and avoid implicating those senior persons in The FCA, Treasury and Bank of England.

Let the many suffer to protect the few, and their jobs and reputations.

One investor mentioned that they had made a report to Action Fraud about Blackmore Bond. When I asked what response they got, they sent me the response from NFIB (National Fraud Intelligence Bureau), the department where Action Fraud send the report for review. Here is the response they forwarded me:

The response is dated 14th March 2020, and states that

“it has not been possible to identify a line of enquiry which a law enforcement organisation in the United Kingdom could pursue.”

Of all the responses I expected to see, this was not one of them. It was inconceivable, and actually impossible, for this to be true. I started asking other investors if they had made a report to Action Fraud and before long I had information and responses in respect to six unique reports to Action Fraud.

I also had six exact replica responses from NFIB in respect to each. Each replicated the response I included above;

“it has not been possible to identify a line of enquiry which a law enforcement organisation in the United Kingdom could pursue.”

This was impossible, and immediately disturbing. It suggested at least one of three conclusions:

a) Action Fraud/City of London Police/NFIB had dropped the ball, and had failed to escalate these reports to The FCA as is their normal protocol when it comes to financial, banking, investment type matters.

and/or

b) Action Fraud/City of London Police/NFIB had forwarded these reports to The FCA, and The FCA had chosen to conceal all of the evidence they had, knowing this would prevent a criminal investigation being launched, despite their knowledge, evidence and multiple flags as to fraud or potential fraud.

and/or

c) Collusion had taken place between The FCA, Action Fraud/City of London Police/NFIB and/or other parties so as to prevent a criminal investigation into Blackmore Bond, despite their knowledge, evidence and multiple flags as to fraud or potential fraud.

I shared this information and these concerns with journalists, who submitted an FOI request to City of London Police and Action Fraud. This was the FOI request:

The National Fraud Intelligence Bureau (NFIB) has received a Freedom of Information request to provide the following information:

  • –  How many times did the City of London Police (including NFIB and Action Fraud) contact the Financial Conduct Authority with regard to the investment firm Blackmore in each of the calendar years 2016, 2017, 2018, 2019, 2020?
  •  How many occasions did the FCA contact the City of London Police to alert it to potential fraud at Blackmore in each of the calendar years 2016, 2017, 2018, 2019, 2020?

The FOI response from City of London Police received confirms the following:

  • There had been 52 reports made to Action Fraud that were specific to Blackmore Bond.
  • The FCA had never reported Blackmore Bond to Action Fraud or City of London Police, despite substantial evidence to demonstrate or prove fraud.
  • However, it showed that whilst 44 of the reports had been made in 2020, two had been made in 2017 and one had been made as early as 2016.

Immediately, The FCA was challenged regarding this data, they leapt to their own defence. Chris Hamilton of the Press Office leading the charge, but at all times representing the positions of The FCA, and therefore its CEO, Nikhil Rathi and Chairmen Charles Randell, and any other senior executives with appropriate responsibility and oversight.

The FCA claimed that the data was wrong, and that no reports had been received prior to 2018, at the same time as repeating false representations that EVERYTHING about the Blackmore Bond was beyond The FCA perimeter, scope and powers.

The FCA claimed that the data sent in response to the FOI had been collated April 2020 and had contained errors that had since been corrected.

(I suspect that The FCA have dishonestly tried to use the date typo in the document as an escape route. The date says the document was produced April 16th 2020. This is clearly a typo and should read ‘2021’ because there is information in the document referring to multiple reports made after April 2020 and up to December 2020.)

Hamilton and The FCA knew that this was intended for publication in mainstream media, and that anything The FCA states for public consumption MUST be truth and fact. Honesty & Integrity being the cornerstone of FCA principles and regulation of course.

On Saturday 24th April articles were published that reflected the representations made by The FCA as statements of truth and fact, and reported that 45 reports were made to Action Fraud, and had been escalated to The FCA, but that none occurred prior to 2018.

I wrote to Nikhil Rathi and Charles Randell personally, with Andrew Bailey at the Bank of England copied to challenge the representations being put forward by The FCA, seeking to deny the accuracy of the CoLP FOI response, and that was intended for public consumption.

On April 29th I received a response on behalf of The FCA, Mr Rathi and Mr Randell, from Martin Kuzmicki of the Executive Casework Unit. In it he claimed:

“The original FOI response that you have from the City of London Police (CoLP) purporting to show when reports relating to ‘Blackmore’ suspect companies were disseminated to the FCA is incorrect. The CoLP issued a corrected version in April of this year, which is set out below. The table in the original FOI response was ordered by the year in which the report was made to CoLP, and incorrectly presented as the year that it was disseminated to the FCA. If you have any further queries about the CoLP FOI response please contact them directly.”

(Kuzmicki included this table)

Month disseminated to the FCAdisseminations
November 18 
Blackmore Global2
 
March 19 
Blackmore Global Pension Investment1
  
February 20 
Blackmore1
Blackmore Bond21
  
March 20 
Blackmore4
Blackmore Bond16
total45

I had already obtained from City of London Police a copy of the original FOI response they had provided that prompted the article. However, unbeknown to Mr Kuzmicki, Mr Rathi and Mr Randell, I had already submitted a new FOI request myself to City of London Police seeking to clarify the accuracy of the information originally provided. It read:

1. How many times did the City of London Police (including NFIB and Action Fraud) contact the Financial Conduct Authority with regard to the investment firm Blackmore in each of the calendar years 2016, 2017, 2018, 2019, 2020?

2. And on how many occasions did the FCA contact the City of London Police to alert it to potential fraud at Blackmore in each of the calendar years 2016, 2017, 2018, 2019, 2020?

The first two questions were the same as my first request and those of journalists. This time I added the following question:

3. Please confirm that the document you directed me to, and that can be found at this link

https://colp.disclosurelog.co.uk/case/91cb2a63-e412-4c09-9a2e-a1d0f6f3344d

contains answers to the questions 1 & 2 that you know to be accurate and correct both as of today, and knew them to be accurate responses when directing me to this information on April 28th?

I specifically asked City of London Police if the data they provided in that first FOI response was accurate in respect to those first two questions, and that it was accurate and correct as of now. I.E. Any errors or differences claimed by The FCA had been correctly updated. Their response on April 29th was:

DECISION

For questions 1 and 2, Section 21(1) of the FOIA applies whereby the information is reasonably accessible by other means, via the following link:

https://colp.disclosurelog.co.uk/case/91cb2a63-e412-4c09-9a2e-a1d0f6f3344d

For questions 3, I can confirm that yes, the data enclosed in the link is correct as of 29th April.

I have permission from the City of London Police to publish that data. This is the data that the City of London Police state is accurate and correct as of this April 29th 2021

Below is the table of fraud reports made to Action Fraud in the name of a ‘Blackmore’ entity.

As you can see, they quite clearly state that there were 52 reports made in total specific to ‘Blackmore Bond’, one of which was made in 2016 and two of which were made in 2017. This is contrary to that which The FCA have been aggressively claiming.

The table below shows the number of reports made to Action Fraud specific to ‘Blackmore Bond’ that were in turn reported by to The FCA by Action Fraud/CoLP/NFIB. The table clearly shows that a report was forwarded to The FCA in 2016.

It further proves that 3 of the 4 reports made in 2017 that were specific to a ‘Blackmore’ named entity were also in turn reported by to The FCA by Action Fraud/CoLP/NFIB. If we look back at the previous page, we can see that there were a total of 4 reports, and that two of these were specific to Blackmore Bond, therefore demonstrating that at least one of these reports forward to The FCA in 2017 was specific to ‘Blackmore Bond’.

SINCE THIS DRAFT WAS PRODUCED, it has been determined that the date of the report received by Action Fraud did not always match the date when it was disseminated to The FCA. For example, but still incredibly, the report made to Action Fraud about Blackmore Bond in July 2016 was not disseminated to The FCA until several years later.

Of further note on this page is the fact that City of London Police confirm that NONE of the reports came from The FCA. This despite The FCA having substantial evidence to demonstrate if not prove fraud.

So, who is lying?

a) The FCA, Martin Kuzmicki on behalf of Nikhil Rathi & Charles Randell, (and presumably Andrew Bailey who my email was also sent to)? Who claim that the City of London Police information that was disclosed to me and the Telegraph separately, was incorrect and had been updated this year.

Or,

b) City of London Police who wrote to confirm that the information that was disclosed to me and the Telegraph separately is accurate and correct as of April 28th this year?

Action Fraud belatedly forwarded their reports to The FCA. However, at no time prior to April 29th 2021, according to Action Fraud/CoLP/NFIB, had The FCA ever reported or shared their significant evidence, suspicions and intelligence with Action Fraud/CoLP/NFIB.

Both The FCA and Action Fraud/CoLP/NFIB had reports and evidence independently dating back to 2016 and neither body did anything with them, including not sharing with the other.

It is petulant childishness by The FCA to be trying to argue the toss as to when Action Fraud/CoLP/NFIB shared their reports, when The FCA was sitting themselves on a mountain of evidence and had done nothing, and they themselves had not shared it with Action Fraud/CoLP/NFIB. Had either body shared with the other what they had, when they received it, it is hard to believe that investor losses would have been greatly minimised, if not avoided altogether.

Moving on to the NFIB responses, how is it possible that the NFIB produced multiple identical responses to every report, each claiming:

“it has not been possible to identify a line of enquiry which a law enforcement organisation in the United Kingdom could pursue.”

It is important to understand that Blackmore Bond were still receiving identical responses from NFIB in mid-April 2021, more than a month after my presentation, and despite all of the evidence they and The FCA had by this time.

Let’s look at that and consider how that is possible given the following clear and obvious ‘Lines of enquiry’:

  1. Many of those that reported Blackmore Bond to Action Fraud and that received that same response, were never asked to provide any of the evidence or information that they had. This means that when the NFIB letter says “Experts at the NFIB examine the information you provide”, it was largely limited to the 2,500 character report victims are limited to submitting within their initial report.

2. The Serious Fraud Office (SFO) announced a criminal investigation into LC&F and its collapse with loss of all investor money in March 2019:

2.1. LC&F was similar product to Blackmore Bond, and all investor monies were lost

2.2. How is it possible that £47mio apparently invested in property since 2016, and over a period where UK property prices rose, was all lost?

2.3. Reports from June 2019 confirm that Paul Careless founder of Surge Financial that made tens of millions of pounds from marketing LC&F, was arrested and questioned by the SFO as part of they investigation and released pending further investigation.

Surge Financial it has been confirmed had also marketed Blackmore Bond in return for significant commissions. These commissions being a % of any investment they could secure.

A statement from a former Amyma employee was quoted by Ben Chapman of the Independent in his excellent piece on Blackmore Bond in April 2020, also confirms that Surge took over marketing of Blackmore Bond:

“He said Amyma only sold Blackmore’s products for “a few months” in 2017. Sales and marketing were then taken over by Surge Financial, which also sold London Capital & Finance’s bonds.”

(Ben’s full article can be found here)

https://www.independent.co.uk/news/business/news/blackmore-bond-collapse-administration-investment-scam-minibonds-a9489921.html

Indeed, if we look at the accounts for Blackmore Bond up to December 2017, we find this entry:

(More on the ‘Blackmore Group Ltd. below)

3. In my original written reports to The FCA in March 2017 I confirm that the Blackmore Bond was being marketed as having the principal amount invested:

“guaranteed by one of the worlds biggest banks”.

Anyone with any experience in banking or financial markets, and most definitely The FCA, and certainly Andrew Bailey & Mark Steward, will know that this had to have been a ‘false representation’ when I reported it. No large bank (or any reputable bank for that matter) is EVER going to offer such a guarantee, and certainly not for a product already boasting of 9.9% guaranteed annual returns.

And to be very clear, there was no benefit of hindsight needed here to determine that this was a false representation at that time. A false representation made with intent to make financial gain (lucrative commissions for the marketing firm), and/or with intent to cause loss or risk of loss.

Indeed, to prove that Mark Steward and The FCA were well aware of this, I refer you to a recent Press Release dated 24th February 2021 regarding the FCA’s actions taken in respect to a non-regulated firm promoting non-regulated products with similar ‘guaranteed’ returns:

“The FCA again reminds consumers not to invest in schemes being offered by firms that are not authorised by the FCA and that look too good to be true, like these ones.”

And referred to the FCA taking action…

‘…….before it inevitably collapsed’ 

Steward, like me and any other financial professional, knew that ‘too good to be true = inevitable collapse’

And let’s note for the record, The FCA took action in this other case despite neither the firm or product being FCA regulated.

Indeed, even if we accept that Mr Bailey, Mr Steward, Ms Attwood and everyone else at the regulator wishes to play the inconceivable ‘benefit of hindsight’ card and claim that there was any doubt about these representations being unlawful at that time:

a) Had they and The FCA investigated this in March 2017, they would have been able to establish for sure if such a guarantee from one of the worlds largest banks did exist, and therefore if it was a false representation or not.

and

b) When Blackmore Bond collapsed and, lo and behold, it was confirmed that all investor money was lost and there was no evidence of any such guarantee from one of the worlds largest banks, this absolutely confirmed that those representations I reported were False.

Fraud. Pure and simple. Yet The FCA never once reported this or even the suspicion of fraud to City of London Police, either in March 2017 or at any time thereafter despite the collapse proving this was false.

4. In my original reports to The FCA in March 2017 I could not be any clearer that the ‘sophistication’ of those being marketed and sold to was being manipulated, and that pensioners were being targeted. There is only one reason to manipulate the sophistication of those consumers and that is with intent to circumvent applicable laws and FCA Codes. These being FSMA (Financial Services and Markets Act 2000) and FCA COBS 4.12. both of which PROHIBIT the promotion and sale of unregulated products to non-sophisticated and retail consumers.

Indeed, Dame Gloster specifically highlights this manipulation in her report into LC&F and criticises The FCA for failing to act on reports of this.

And to be VERY clear, The FCA has the powers and the obligation to act in these circumstances whether the firm or product was regulated or not.

5. Phillip Nunn and Patrick McCreesh, the Directors of Blackmore Bond Plc.

I have evidence that reports and allegations were made to The FCA in 2016 in respect to both Nunn and McCreesh, and in respect to a variety of concerns, all of which were supported by evidence, and in respect to a variety of firms and ‘projects’ they were involved in, or associated with.

Ben Chapman in his article confirms that Nunn & McCreesh were taking a 5% commission from all monies invested in Blackmore Bond for ‘services rendered’ via a parent company. Indeed, here are extracts from the Blackmore Bond accounts spanning two different years that show these substantial sums being paid to Blackmore Group, the ‘parent company’, that Nunn and McCreesh were both Directors of.

And just what did Nunn and McCreesh do exactly to justify those eye watering amounts for their ‘services’?

Whether or not they were involved with the fraudulent marketing of the Blackmore Bond, they were clearly beneficiaries (unwitting or otherwise) of it via these commissions received.

Various reports about the pair to The FCA also cite associations or direct involvement in Blackmore Global, Capita Oak pension scheme and others. Indeed, Redd Monitor on 14th May 2020, summarise some of these documented activities:

“The Telegraph reports that Nunn and McCreesh’s “early work included drumming up leads for Jackson Francis Ltd, an introducer for the Capita Oak Pension Scheme.” The Serious Fraud Office is now investigating Capita Oak as part of a major investment fraud investigation. Investors lost £120 million in Capita Oak’s pension fund.

And the Independent reports that an investigation by the Insolvency Service found that Nun McCreesh LLP received almost £900,000 in commissions beteen March 2012 and May 2014 for generating leads for Capita Oak.”

This includes links to the investigations announced by the SFO into activities including Nunn and McCreesh.

When did the Serious Fraud Office announce this investigation in to Oak Capita?

22nd May 2017, just two months after my initial report to The FCA about Blackmore Bond.

In March 2018 a superbly articulated report was made direct to Mark Steward by an IFA raising serious and multiple concerns in respect to Blackmore Bond, and also raised concerns about Nunn and McCreesh.

It is not possible that The FCA and/or NFIB did not join these dots.

6. Mark Steward confirmed to me in response to my serious concerns, and earlier reports, that I escalated direct to him, Bailey and Attwood in August 2018 that The FCA were “making enquiries”.

A year later, after I raised yet further concerns direct to Steward, Bailey and Attwood, Steward responds:

“We are aware of these matters which are the subject of ongoing work on our part.”

Therefore confirming that The FCA had been investigating Blackmore Bond for at least a year, and presumably the activities of its Director’s that were subject to separate reports.

Firstly, this rather confirms that Blackmore Bond was very much within The FCA perimeter, scope and powers. Why else does The FCA spend over a year investigating?

Secondly, any investigation will have uncovered further concerns, further flags and further evidence to demonstrate, if not prove, Fraud.

For the record and avoidance of doubt there are multiple lines of enquiry that exist in respect to Blackmore Bond, associated persons and associated businesses.

It is impossible that The FCA, its CEO and Senior Executives did not recognise these flags, did not join these dots and did not know that breaches of FSMA, FCA COBS and almost certainly UK law including the Fraud Act 2006 were taking place, possibly as early as 2016, but certainly as early as March 2017 when I made my first reports.

WHEREAS, the evidence from City of London Police and NFIB more than suggests that not only at no time did The FCA ever report any concerns about Blackmore Bond, Nunn or McCreesh to City of London Police, but that they also failed to provide any concerns, flags or evidence to City of London Police in response to the multiple Action Fraud reports specific to Blackmore Bond that were sent by City of London Police to The FCA.

Why? There is an MOU (Memorandum of Understanding) between The FCA and City of London Police that specifically references the sharing of information between the two, and has terms specific to the passing on of reports or evidence that might be more appropriate for the other.

Why did The FCA conceal substantial evidence and information from City of London Police knowing that it would prevent a criminal investigation, deny victims the opportunity for justice and remedy, and therefore pervert the course of justice?

I do not necessarily believe that it was because unlike LC&F, where The FCA had successfully played the ‘incompetent’ card and pinned much of the blame on the contact centre, with Blackmore Bond The FCA and its most senior executives were much more significantly exposed and responsible.

Unlike LC&F, reports about Blackmore Bond did not get stuck in the ‘Contact Centre’, but made it to the very departments where it needed to go in March 2017, and to the most senior and relevant executives in March 2018 and August 2018.

It is one thing for The FCA and senior executives to ‘drop the ball’ so shockingly as they have with Blackmore Bond, but to then try to bury the ball to conceal these failings, even going to the extraordinary lengths in preventing a criminal investigation in the process, is crossing a line into criminality.

And what about the TSC, Mel Stride MP, Steve Baker MP and John Glen MP? I have provided all with substantial and significant evidence specific to Blackmore Bond that demonstrates or proves that testimony that has been made to the TSC by Andrew Bailey, former CEO and Bank of England Governor, and various current FCA senior executives in recent weeks, is significantly lacking in honesty and integrity and substantially misleading.

All of this evidence is relevant evidence with which to cross examine these executives, and I produced a summary before Andrew Bailey testified to the TSC as to how this evidence should be used to challenge and cross examine Mr Bailey’s testimony, both that which he had made publicly and to Dame Gloster and her investigation, and even included appropriate lines of questioning for him.

All of it was ignored and Blackmore Bond has never once been mentioned in any TSC proceedings, relating to LC&F.

How is that possible? The TSC, Mr Stride, Mr Baker and Mr Glen are elected persons who have been put in a position of oversight and to represent the interest of the UK public on exactly these matters, and yet choose to conceal everything specific to Blackmore Bond and, in so doing, are preventing the Bank of England Governor, The FCA and its senior executives from being held accountable for their failings and dishonesty, and preventing victims from receiving justice and remedy.

Why? And does this not also constitute a perversion of the course of justice?

A non-Conservative member of the TSC has confirmed to me that significant reports that I made to the TSC and Mr Stride last year, on serious issues and with significant evidence, were concealed from them.

Why?

There MUST be a full and independent enquiry into Blackmore Bond, but it must encompass everything within the hierarchy of oversight from The FCA, to John Glen, to the TSC and Mr Stride and to law enforcement and the interactions between all.

Anything less is a continuation of the perversion of the course of justice that has taken place to date.

END OF ARTICLE THAT I SUBMITTED TO THOSE PARTIES ON MAY 4TH.

As you can see from the above, there are multiple and clear lines of enquiry in this case in respect to potential fraud, if not fraud already proven by some evidence, making the NFIB response; “it has not been possible to identify a line of enquiry which a law enforcement organisation in the United Kingdom could pursue” as entirely impossible, and therefore entirely dishonest.

For the record, since I drafted this article, I have uncovered yet further evidence of wrongdoing and fraud, and a highly qualified individual has identified even more obvious and clear flags and lines of enquiry. All of which took little effort to identify. And all of which MUST already he known to The FCA and/or Action Fraud/CoLP/NFIB.

Having reasonably afforded each party to which my May 4th email and draft was sent, the reasonable opportunity to provide a challenge or comment by 5.00pm, I received a response only from Sarah Partridge-Smith of The FCA on personal behalf of Nikhil Rathi and Charles Randell, and it appears Mark Steward who was not copied on that email from me. Andrew Bailey, Mel Stride and John Glen MP’s did not challenge any of the content prior to its proposed publication.

Please note that Ms Partridge-Smith describes herself as ‘Acting Private Secretary’ to Mark Steward. She is also listed as a Barrister. Please also note her response was timed at 5.01pm. Petulant, childish arrogant and ignorance of the highest order from The FCA. ‘We will not be told what to do’.

Ms Partridge-Smith’s opening statement claims that The FCA takes its commitment to sharing intelligence with partner agencies seriously. This despite substantial evidence to the contrary provided to The FCA in my draft, and in multiple other cases also.

She says this despite statements by ActionFraud/COLP/NFIB that The FCA never once shared the substantial evidence and intelligence that they held in respect to Blackmore Bond and its Directors with them.

It does not matter how many times you make dishonest, incorrect and false representations, and no matter how badly you want them to be true, it does not make them anything but dishonest and a furtherance of prior dishonesty.

Ms Partridge-Smith goes on to provide a table that shows the dates that reports were actually disseminated to The FCA by Actionfraud/COLP/NFIB.

The COLP data had documented the date when each report was received by Action Fraud, and had confirmed that each had been disseminated to The FCA, but had not detailed the date when this dissemination had occurred.

However, let’s be clear here, this does little to diminish the FCA’s failings that I had highlighted and she had failed to address:

  • She and The FCA had failed to explain why they had initiated no report or suspicion to Actionfraud/COLP/NFIB in respect to in respect to Blackmore Bond, its associated companies and its Directors.
  • She and The FCA had failed to explain why they had failed to initiate any sharing of the significant evidence and intelligence that they had with Actionfraud/COLP/NFIB
  • She and The FCA had failed to explain why that in more than a year since Actionfraud/COLP/NFIB had disseminated reports to The FCA regarding Blackmore Bond, its associated companies and its Directors, that Actionfraud/COLP/NFIB were telling those reporting fraud that they had been ‘unable to identify any lines of enquiry’. The FCA evidence and intelligence alone demonstrates multiple lines of enquiry, and significant evidence of fraud and/or other criminality including potential Ponzi scheme.
  • She and The FCA had failed to explain why The FCA was dishonestly claiming that everything about Blackmore Bond was beyond The FCA perimeter, scope and powers.

Ms Partridge-Smith then produced the typical FCA spiel when seeking to lie, deny or conceal.

Yes, on the personal behalf of Nikhil Rathi and Charles Randell, she chose to rely upon FSMA so as not to divulge any information or address any of my concerns and allegations.

However, she does prove that she, Nikhil Rathi, Charles Randell and The FCA are aware of “ongoing activities’ in respect to Blackmore and that non-disclosure is being undertaken so as not to ‘prejudice’ these ongoing activities.

FOR THE RECORD AND AVOIDANCE OF DOUBT, we know that:

  • Actionfraud/COLP/NFIB are undertaking zero activities, and are not pursuing any investigation whatsoever.
  • John Glen on behalf of the Treasury has confirmed that there is no intention of compensating investors, and no intention of launching an enquiry, period.
  • Mel Stride has demonstrated personally and on behalf of the TSC, that there is no intention of ever mentioning Blackmore Bond, the evidence or calling for any kind of enquiry or investigation.
  • The FCA (Falsely) claims that EVERYTHING pursuant to Blackmore Bond is beyond their perimeter, scope and powers and therefore they are doing nothing to investigate.

THEREFORE, what other activities is she referring to?

Ms Partridge-Smith on behalf of The FCA and Nikhil Rathi & Charles Randell personally, then corroborates my worst fears, when she adds:

Contradicting her earlier statement that FSMA prevents sharing of information by The FCA, she proves this to be a false and a convenient position when she chooses to disclose on behalf of The FCA and Nikhil Rathi & Charles Randell personally, that they are very well aware of the Capital Guarantee Scheme that existed.

Indeed, she not only corroborates my worst fears and confirms that they knew of the existence of this CGS, but also proves that they knew every detail about it, including the £75,000 alleged protection and IMPORTANTLY, that they were very well aware that this CGS Insurance policy was:

“subject to conditions”

And there you have it. The FCA, Nikhil Rathi and Charles Randell confirming that they knew about this CGS Insurance policy, and knew of the conditions that existed in respect to it. This being the ‘fraud’ and ‘diversified portfolio’ conditions.

Furthermore, she confirms that they all knew that a claim had been made on it.

This is the ONLY ‘ongoing activity’ that she is referring to when stating ‘risk of prejudice’. A claim being made on this CGS Insurance policy.

She confirms that this is what is driving the actions or lack of actions of The FCA & NFIB, and therefore likely those of John Glen MP and the Treasury, and Mel Stride and the TSC.

Please note the implied threat in her last paragraph when declining to comment further.

I am sorry, but you don’t get to refuse to answer serious questions, and address serious concerns & allegations, that I have raised repeatedly, and then imply that there is a risk to me if I publish them.

All of these bodies and individuals have a duty to the public and the public interest, and the laws and codes that they are responsible for upholding. I, and others, have identified multiple failings across that spectrum, and all have refused to address them.

And the reasons are quite clear, and as per my formal allegations at the start of this piece.

Threats against me, and “the interests of investors

Threats have been made and/or implied that should I disclose the evidence of potential fraud, and make the allegations (supported by evidence) that this evidence and these lines of enquiry are being deliberately concealed and/or suppressed by The FCA and Actionfraud/COLP/NFIB, that I would be prejudicing ongoing activities and/or damaging the interests of investors.

I have considered this extensively:

a) Do I ‘blow the whistle’ and disclose/publish this evidence and make these formal allegations?

or

b) Do I stay quiet and allow this concealment and suppression continue? Concealment and suppression with intent to pervert the course of justice and commit insurance fraud.

The implied threat by The FCA is that if I expose the evidence of fraud, and the fact that their is active concealment and suppression of this, that it would damage investors, who would lose the opportunity to claim back on this CGS Insurance policy.

That to do this would be to act against the best interests of the public and investors.

However, The FCA are perhaps unaware of the other evidence that I have. Evidence, that I am certain that The FCA and Actionfraud/COLP/NFIB MUST have and/or be aware of. If they are not, then it is because they have abjectly failed to look for it, investigate properly, or to simply ask those that have made fraud reports for their information and evidence.

The additional concerns and evidence

  1. The right to claim on this CGS Insurance policy does not lie with investors it transpires. Instead it rests with the Trustees of the Blackmore Bond, “Oak Fund Services (Guernsey) Limited” (Hereafter referred to as OFS). Notwithstanding that Oak have not adequately explained how the collapse occurred under their watch.
  2. Investors have shared correspondence they have had with OFS. Correspondence whereby OFS state:

a) A claim has been made on this CGS Insurance policy

b) That the insurers have not paid out in response to this claim

c) They have, to date, incurred £600,000 costs in securing legal advice in respect to pursuing the CGS Insurance policy. (It is not discernible what advice has been obtained, or actions undertaken, in respect to these huge fees)

d) There is no possible chance to secure a payout or enforcement of this insurance policy without obtaining litigation funding to do so.

e) That the cost of litigation finding will be a minimum of 60% of any monies recovered from the insurers. (Albeit that a more recent letter dated May 7th 2021 that I have a copy of, confirms that they are apparently utilising the services of a ‘Litigation Funding Broker’ in an effort to reduce the % cost.) It will be unlikely that any funder will agree to less than 40%)

3. All of the above is disturbing. Let’s be clear, OFS were the trustees responsible for oversight of Blackmore Bond and in the interests of the bondholders. How did Blackmore Bond collapse with all monies lost under their watch? What role did they play in determining if the CGS Insurance policy obtained via FCA regulated insurance brokers was suitable and appropriate?

HOWEVER, it is perhaps more concerning that which OFS are NOT telling investors.

4. I have asked various investors questions about OFS, the CGS etc. and none of them have the answers. This despite investors confirming that they have sought this information from OFS themselves. These include:

a) What advice has OFS ben given in return for the £600,000 in legal fees allegedly for this advice?

b) What actions have been undertaken in respect to making a claim on this CGS Insurance policy, either by OFS or their legal representation to which this £600,000 has been paid?

c) Has a claim actually been made on this CGS?

d) If so, what reason or positions are being put forward by the insurers for not having paid out?

5. Investors I have spoken to, confirm that none of this information is being provided to them by OFS.

6. What is further disturbing is that whilst The FCA appear certain that a valid claim has been made, and whilst OFS imply the legitimacy of the insurance and validity of investor rights and claims in their correspondence, I have evidence that demonstrates an altogether different picture.

6.1. Earlier this year, frustrated at the lack of information being provided by OFS, an investor wrote directly to one of the Costa Rican based insurance companies that had provided this CGS Insurance policy.

6.2. Here is the response sent by the lawyers representing that insurance company

6.3 As you can see it paints an altogether different picture. This correspondence quite clearly claims that:

a) The insurance company “does not accept that a valid demand (claim) has been made”

b) That “nor was or is anyone entitled to make such a demand”

c) A letter was sent to “SH” (‘Shareholders’. I presume to be McCreesh and Nunn) and OFS on 22nd October 2020. It is clear that positions and/or requests for information were put forward in “the contents of” that letter.

d) There has been no response to that letter in the five months between it being sent on 22nd October 2020 and the lawyers letter dated 22nd March 2021.

e) The insurance company and their lawyers confirmed that they are happy for Shareholders and OFS to share all correspondence between them, with bondholders

f) The insurance company and their lawyers confirmed that they are aware that “A number of bondholders have said that they have done so (request this information and/or correspondence), but OFS/SH have not shared that correspondence with these bondholders”

7. Why are the shareholders and the Trustees, OFS, not sharing this information with bondholders? I presume that it must be the reasons why no payment has been forthcoming from the insurers.

8. Why have the shareholders and OFS not responded to these communications, and are instead solely pursuing costly litigation?

9. What actual chance does litigation have against a Costa Rican based insurance company in the first instance, regardless of any ‘conditions’ or ‘exemptions’ that might exist to void the protection?

10. Indeed, why did The FCA regulated insurance brokers deem insurance provided by a company beyond the borders of the UK and EU to be appropriate? Was it because no such ‘local’ insurance company would provide it?

The questions and concerns go on and on…..

So, what options do investors have, and how are their best interests served?

My assessment of the position that investors find themselves in, and the options available to them, based entirely upon the substantial evidence that I have, is as follows:

There are three options:

OPTION 1 – The current scenario whereby nothing is being done by either FCA, ActionFraud/COLP/NFIB, HMT or TSC in the sense of investigation, enquiry or remedy, and with non-disclosure and concealment of information by the shareholders and/or OFS, the Trustees.

OPTION 2 – The OFS could continue to pursue payouts under the CGS. This will come with the following costs:

A) Whatever costs have so far been incurred. At least £600,000 according to investors testimony to me.

B) Whatever litigation funding % of payout is agreed in the event it is required, which will likely be minimum of 40%

C) Anyone potentially guilty of fraud, be that McCreesh and Nunn or others, will be able to walk away scot free. In the case of McCreesh and Nunn, this would include them walking away with the more than £2mio cash they took from Blackmore Bond as their ‘commission’ for ‘services’ rendered to Blackmore Bond.

D) FCA, City of London Police and senior persons within both, escape any scrutiny and sanction for their failings, dishonesty and/or criminality regarding Blackmore Bond and their handling and involvement in respect to it. 

C) & D) Mean that both will be free to commit further wrongdoing and/or fraud and regulatory and oversight failings, and therefore perpetuate the never ending line of losses for innocent victims.

And let’s be clear, what are the % chances of a successful judgement, and the % chances of a successful enforcement of said judgement? Particularly when there is already clear evidence to demonstrate or suggest potential fraud.

OPTION 3 – Demand a criminal investigation and for a full enquiry and from top to bottom. What did The FCA, COLP, HMT and TSC know and when, why it was all ignored, and fully expose the extent of failings, dishonesty and/or criminality by all parties be it those directly involved in Blackmore Bond or those responsible for oversight.

If LC&F victims are going to get paid out as they have for FCA ‘incompetence’ albeit falsely engineered ‘incompetence’ by the FCA in many respects, Blackmore Bond holders should receive 100% back from HMT given the far more serious failings and dishonesty by The FCA in this case.

3.1. Obviously, the announcement of a criminal investigation, would create a barrier in terms of the CGS Insurance paying out. And this is the implied threat that such disclosure of potential fraud and a fraud investigation would act against the interests of investors.

3.2. HOWEVER, such an allegation or threat is entirely misleading, if not knowingly false. A criminal investigation and full enquiry is a WIN/WIN for investors and the wider public.

a) In the event that a full criminal investigation for fraud is undertaken and those involved are found not guilty by a jury, then it removes any potential for the insurance firm to deny payment on the condition of ‘fraud’ by Directors. This can only HELP secure an insurance payout and likely without the need for expensive litigation that would see investors deprived of most of the monies.

b) In the event that a full criminal investigation for fraud is undertaken, and those involved are found guilty, then investors would have to be compensated for 100% of their losses by HM Treasury and/or City of London Police, on the basis that it was entirely preventable and would have been prevented BUT FOR the failings of The FCA and City of London Police.

c) Those persons found responsible within The FCA and City of London Police, HM Treasury etc. would be held accountable, and other cases where the same or similar failings, and dishonesty have occurred in the past, would also be reviewed. The resulting transparency and disclosure would finally lead to an entire overhaul of the entire hierarchy of oversight, and the development of one that is finally fit for purpose and free of the conflict and dishonesty that infests the current one.

The ONLY parties whose interests are served by way of there being no criminal investigation and no full enquiry are those of The FCA, COLP and HM Treasury.

If they can ‘engineer’ a payout on the CGS Insurance policy they can, and will argue, that there is no need for an enquiry as investors received some compensation.

WHEREAS, any criminal investigation and full independent enquiry is going to expose the failings and the dishonesty by The FCA and COLP and senior executives within it.

Finally, and for the record, I submitted my own report to Action Fraud on April 27th 2021 after yet more investors sent me yet more identical NFIB responses claiming that they had been “unable to identify any lines of enquiry”.

There is no opportunity to upload any evidence when filing your initial report. You are limited to just 2500 characters. A month later and I have received no response at all. So, I called Action Fraud on Thursday and Friday to determine what was going on and to speak to someone about provision of my substantial evidence.

I spoke to two different people at Action Fraud and neither was able to access my crime report. Both said that the letters I had given them from my ‘memorable word’ did not match (not possible as I have the word clearly recorded), and without this they could not access my report.

Neither was able to transfer to NFIB to discuss my report and evidence. A manager did call me back on Friday and appeared to have genuinely tried to get a senior person within Action Fraud to call me back, but without success.

In addition to the above mentioned evidence, I have been provided with substantial evidence by investors in the shape of communications between themselves and McCreesh, Nunn and others within the ‘Blackmore’ empire.

The communications are disturbing in every respect, particularly those that take place throughout 2019, and those in January 2020, just three months prior to the collapse of Blackmore, and the ultimate discovery that there was NOTHING in the pot, and all investor monies were lost.

They are damning in every respect, and contain representations within them that are absolutely false when compared with the findings of fact by liquidators.

Enough is enough. Two frauds don’t make a right, and the reputations and status of the few can no longer be protected at the expense of the many victims of Blackmore Bonds and countless other preventable scams, and the billions of pounds that have been lost as a result.

HOT OFF THE PRESS – Ponzi?

Within the last week, further disturbing evidence has come tonight that rather confirms further concerns that I raised in August 2019, and that were subsequently raised directly with Andrew Bailey, then CEO of The FCA.

You might recall that Blackmore Bond paid a quarterly interest payment in 2019 to some investors. It was significantly late. However, I raised concerns as to just how they had managed to make this interest payment.

I asked if this had been made from genuine returns on investment, or simply from new monies being invested. I couldn’t see how it could have been paid from profits, and was concerned that this could represent evidence of a Ponzi scheme.

These questions were escalated to Andrew Bailey. It is unclear what he did with these concerns.

However, this week I have received evidence to show that at least two investors who had invested in another McCreesh and Nunn ‘vehicle’, Blackmore Estates, were encouraged and/or forcibly had their ‘investment’ ‘transferred’ into Blackmore Bond.

One Blackmore Estates investor who had their long term ‘investment’ maturing in 2017 was encouraged to ‘re-invest’ their principal and % returns from that Blackmore Estates investment directly into Blackmore Bond.

They were sold Blackmore Bond on the basis of the guaranteed returns, and the principal protection. And of course they were under the impression that their investment in Blackmore Estates had performed exactly as promised.

HOWEVER, their principal and profits were never paid back to them, and for them to invest these monies themselves into Blackmore Bond. Instead, these monies were ‘transferred’ to Blackmore Bond by those running the ‘investment/s’.

It is a classic Ponzi flag. The investor pays money in to one ‘investment’ for a fixed term. As that investment nears maturity, they are persuaded to ‘re-invest’ in either the same or new investment for another lengthy fixed term. Whichever it is, the investor is informed that they have earned all of the promised returns, and persuaded to ‘re-invest’ the original principal plus the returns into the new investment.

They are told that the amount is equal to their original investment plus the promised returns on it. However, the investor has no way of knowing how much is actually ‘transferred’.

If the above Ponzi flag is of serious concern, what happened to one investor in 2019 is of an even greater concern. More on this at a later date, but in the meantime, how is it possible that The FCA have not identified this, or have they identified it, and simply sought to add this to the list of concealed evidence?

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