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The Fair and Effective Markets Review: Tackling Misconduct in Financial Markets

stocksIt was recently announced (here) that the Bank of England, the Financial Conduct Authority (FCA) and HM Treasury have published the final report (available here) on the Fair and Effective Markets Review. This report follows a comprehensive investigation into the fixed income, currency and commodities (FICC) markets, aimed at identifying the causes of misconduct in the markets, assessing the impact of regulatory reforms, and making recommendations on improvements to be made.  

At over 100 pages long, the recommendations of the report are wide ranging and could have a significant impact on organisations operating in FICC markets. The financial and regulatory teams at Lewis Nedas have conducted an extensive review of the recommendations of the Fair and Effective Markets Review, and give an overview of some of the main findings of the report in this blog post.

What is the purpose of the Review?

As mentioned above, the review was conducted in the hope of identifying the causes of misconduct by organisations operating in the FICC markets. It is also hoped that the report’s recommendations will help to close gaps in the regulatory landscape, reducing the opportunity for organisations working in these markets to misbehave.

What are the main recommendations of the Review?

The report contains 21 recommendations some of which, if implemented, could have a significant impact on the way that organisations working in the FICC markets operate. Some of the main recommendations of the Review are as follows:

1. Extending the reach of the Senior Managers and Certification Regime

The report found that there was some merit to extending the number of individuals that are governed by the Senior Managers and Certification Regime (SMR). Under the current rules, certain individuals, including interdealer brokers and asset managers, fall outside the SMR. As a result, regulators are currently unable to hold these individuals personally responsible for breaches of conduct rules. The Review recommends a consultation to be undertaken to extend certain parts of the SMR, to cover at least those active in FICC wholesale markets.

Any extension of the SMR would obviously increase the personal responsibility owed by senior personnel operating in the FICC markets. However, there is still further guidance required on precisely which individuals within an organisation will be governed by the SMR, and what activities will be covered by the extended regime.

2. Creation of a new FICC Market Standards Board

Another recommendation of the Review was to create a new body charged with identifying emerging risks to the FICC markets. Another important part of the FICC Markets Standards Boards’ role will be to tackle uncertainties in trading practices and to provide practical guidance to those working in the markets, allowing them to meet the standards that are expected of them. It is also hoped that the Board would be able to contribute to the harmonization of market standards on a global scale.

The creation of this body and its potential usefulness to those working in the FICC markets will ultimately depend on how well it is to be resourced. Assuming that, if it is created, the Board is given the necessary tools to perform its duties, it could prove useful in acting as a forum for discussion between regulators and individuals/organisations working in the FICC markets. Furthermore, the Board would need to be effective in providing guidance to markets in a timeous manner where uncertainty regarding market practices arises, lest it simply become a burden on them and becomes an obstacle to effective market practices.

3. Greater emphasis on conduct risk management

The report recommends a number of steps, for both regulators and participants in the FICC markets, to better manage risk in the future. These include:

  • Greater scrutiny of FICC market structures and behaviours for potential conduct risks: the report points to the role that market participants have in being active in FICC markets and for the need for them to be conscious of their use of increasingly sophisticated technology, and the potential risks this creates for seemingly unrelated aspects of their business.
  • Identification of potentially inappropriate trading patterns through market surveillance: emphasis is placed on organisations operating in the FICC markets, and the need for them to use sophisticated technology to analyse trading patterns. The report also highlights the importance of organisations reporting questionable behaviour to the regulatory authorities at the earliest opportunity.
  • Encouragement of forward-looking supervision: it is suggested that senior personnel within organisations make use of the SMR regime, combined with regulatory bodies taking a more comprehensive approach to using their regulatory powers to police questionable activities in the markets.

An emphasis on improved risk management is admirable but also has inherent challenges. In order to be achievable, more successful risk management must be supported by sophisticated systems that will require significant investments in time and money to be effective.

The recommendations of the FEMR are ambitious and if fully implemented, could have a significant impact on market participants in the FICC sphere. In the near future, it is likely that further consultation will be undertaken, to establish when and how the recommendations outlined in the FEMR can be implemented, and how market participants will be able to adjust to their new regulatory environment. A report on the progress of the implementation of the FEMRs’ recommendations is scheduled to be complete by June 2016.

Contact our Regulatory and Financial Lawyers London

At Lewis Nedas, we are acutely aware of the challenging regulatory environment that financial organisations operate in. If you are concerned about the recommendations made by the FEMR, or how the obligations that your organisation owes to regulators may change, speak to us today. The lawyers at Lewis Nedas are some of the most experienced in their field, who understand clients’ need for comprehensive, practical legal advice. Our regulatory and financial lawyers will be following the progress of the FEMR closely, and will be able to give comprehensive advice on how it will impact you and your organisation. Contact us today and see how we can help you.

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Regulating Corrupt Practices in the UK

costs and damages cases ukThe Guardian recently reported (here) that during the G7 Summit in Germany last month, David Cameron warned that the Fifa scandal highlighted a need for a more concerted effort from world leaders to combat corruption. The prime minister is reported to have been highly critical of the reluctance on the part of many to identify corrupt organisations, noting that: “just as with Fifa, we know the problem is there, but there is something of an international taboo over pointing the finger and stirring up concerns”.

While allegations of corruption often feature on the pages of tabloids, the UK’s framework for combatting corruption is not particularly well understood. In this blog post, the team at Lewis Nedas give an overview of the legislation designed to combat corrupt practices in the UK.

What are ‘corrupt practices’?

The term ‘corrupt practices’ tends to cover a range of activities that are deemed illegal under UK law, including:

Money Laundering

This is where there has been an exchange of money that is the result of illegal activities. These ‘proceeds of crime’ are then exchanged for money that is not tainted by criminal activities.


Bribery relates to the providing (and receipt) of an advantage or benefit (either monetary or otherwise), so to entice someone not to fulfil his or her duties as would be expected. The offence of bribery also includes the payment (and receipt) of money or some other kind of payment, to condone questionable or improper conduct.


The offence of fraud is multifaceted. It covers a variety of activities including: representing to someone that something known to be false is true; failing to disclose information that someone owes a duty to disclose; and, abusing a position which someone is expected to protect.

How are corrupt practices regulated in the UK?

The different offences listed above are heavily governed by statute. Listed below are the important statutes that deal with each offence and who they apply to.

Money laundering

The rules concerning money laundering are contained within the Money Laundering Regulations 2007.

The Money Laundering Regulations 2007 apply to a variety of organisations, based on their being part of a particular business sector. Under the 2007 Regulations, the following organisations are required to observe their terms: money service businesses – businesses that exchange any currency, transmit money from one place to another or cash cheques; high value dealer – businesses that accept cash payments of €15,000 euros or more in exchange for goods; trust or company service providers – a firm of or individual practitioner(s) who are engaged in, amongst other things, the creation of legal entities, arranging for people to act as a director or secretary of a company or a partner for legal entities, and providing a registered office or business address for an organisation; accountancy service providers – auditors that carry out statutory auditory work, and accountants and tax advisors that provider advice to clients; and estate agency businesses – organisations that are involved in the buying and selling of residential or commercial property for and to customers.

In order to comply with the Money Laundering Regulations, an organisations must design and implement certain procedures to establish an individual’s identity; be aware of where their money is going to and coming from; and keeping individuals activities under constant review in terms of the risk of your business becoming implicated in money laundering.

HM Revenue and Customs (HMRC) is the organisation that has responsibility for ensuring that organisations observe their responsibilities under the 2007 Regulations. Where there is a failure to comply, HMRC is empowered to issue a financial penalty or in more serious cases, pursue criminal prosecutions.


The Bribery Act 2010 is the governing piece of legislation in the context of the offence of bribery.

The legislation applies to both organisations and individuals (including the employees of an organisation) and requires that they actively avoid becoming implicated or involved in bribery. It is not uncommon that different parts of the world handle the practice of bribery differently. However, the fact that bribery is deemed illegal in the UK will have dire consequences for UK-based organisations found to have engaged in bribery elsewhere. In order to avoid becoming embroiled into allegations of bribery, organisations are charged with implementing processes and procedures that will guard against, and identify risks of, bribery occurring at the earliest opportunity. In most cases this will come in the form of an ‘anti-bribery’ policy which should outline, amongst other things:

  • The organisation’s position on accepting gifts and corporate hospitality;
  • The approach the organisation takes to reducing risks of bribery; and
  • The rules that should be followed when engaging in business affairs e.g. negotiating contracts.

The responsibility for policing bribery, and enforcing the Bribery Act lies with a host of regulatory agencies. One of the most important of these is the Serious Fraud Office (SFO), which tends to work with other bodies in government and the police to monitor compliance with anti-bribery legislation.

Where there is evidence that bribery has occurred, the consequences for those involved can be severe. In the case of individuals implicated in bribery, there is a penalty of up to 10 years imprisonment alongside an unlimited fine. For companies that are found to have been involved in bribery, there is also an unlimited fine.


The crux of the Fraud Act 2006 is to dissuade anyone – either a corporate entity or an individual – from engaging in fraudulent activity. Policing against fraudulent activity is complicated, and tends to involve a number of organisations. In the UK, considering that fraud often tends to involve some kind of financial element, where organisations are regulated by the Financial Conduct Authority (FCA), so too will it investigate their suspected involvement in fraud. It is empowered to fine and issue sanctions against organisations found to have been involved in fraud and, for failing to prevent it from occurring.

Penalties for involvement in fraud will depend on the circumstances. Where an individual is found to have been involved in fraud, the maximum penalty is up to ten years imprisonment. It will also be open to the courts to issue an unlimited fine, if it deems it necessary. Organisations that are found to have been involved in fraud will also likely be issued with an unlimited fine.

Corrupt Practices in the UK

The law in the UK governing corrupt practices is highly sophisticated and difficult to understand. If you are concerned that you or your organisation have been implicated in any of the activities mentioned above, it is important that you take specialist legal advice at the earliest opportunity. Suspected corruption – however defined – can be disastrous for both individuals and organisations in terms of their reputation and prospects for future success.

Contact Lewis Nedas Solicitors in London

At Lewis Nedas, we are experts in dealing with allegations concerning corrupt practices. Our specialist lawyers are routinely sought for their knowledge of the law governing corporate crime, financial crime and fraud. We understand that being faced with allegations of corruption can be an incredibly damaging experience, and that they must be handled delicately by experienced professional advisors. If you need detailed, practical legal advice on how to deal with allegations of being involved in bribery, fraud or money laundering, contact the team at Lewis Nedas now.

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Should Cryptocurrency be Regulated?

cryptocurrencySince its invention in 2009, the government has paid increasing attention to cryptocurrency, such as the Bitcoin, and its associated risks. There are concerns it can facilitate tax evasion, money laundering, terrorism, fraud, evasion of sanctions and other crimes. Its rise in popularity and sophistication led the government to issue a call for evidence in November 2014 in a bid to examine the benefits and risks of the currency. Following this, the Budget Report of March 2015 proposed cryptocurrency should be regulated in order to support innovation by legitimate businesses and prevent criminal misuse. The proposals will be consulted on early in the next parliament.

Here we take a look at the key features of cryptocurrency, the government’s proposals for regulation, particularly in the context of anti-money laundering rules, and the current powers of law enforcement authorities where they suspect that cryptocurrency is being used for criminal purposes.

The Key Features of Cryptocurrency

Cryptocurrency is considered an ‘alternative’ digital currency, which is transferred entirely online and directly between users. Its users say it is a secure method to affect free, instant, and borderless transactions around the globe without having to go through banks. Each user has a private key associated with their specific account (known as a ‘wallet’) to affect their digital transactions and the transitions are permanently recorded and time-stamped in a public ledger that is updated by software. So far, the system has been completely untouched by banks or regulation.

However, there are two issues with the system that lead the government to believe regulation should be brought in:

  1. The decentralised nature of the system presents jurisdictional difficulties for the authorities, as there is no central point where accounts are located. This causes problems when an authority attempts to claim jurisdiction over a particular exchange.
  2. The identities of users are anonymous and many cryptocurrency addresses are merely a series of numbers attached to a wallet. This makes the transactions untraceable and therefore cryptocurrencies have been associated with illegal payments and purchases.

The Government’s Proposals for Regulation

The government’s current focus is clamping down on money-laundering and other financial crimes. To ensure cryptocurrency does not hamper these efforts, the Government intends:

  • To apply anti-money laundering regulation to digital currency exchanges in the UK
  • To ensure that law enforcement bodies have effective skills, tools, and legislation to identify and prosecute criminal activity relating to digital currencies, including the ability to seize and confiscate digital currency funds where transactions are for criminal purposes
  • To work with the BSI (British Standards Institution) and the digital currency industry to develop voluntary standards for consumer protection.

The Application of Anti-Money Laundering Regulation

The government is considering extending existing EU legislation such as the Anti-Money Laundering Directive to those issuing cryptocurrency, although the parameters of the legislation are not yet clear. It could possibly cover all institutions handling or dealing with digital currencies, exchange businesses as the entry and exit points of the digital currency system, digital currency ATMs and wallet providers.

There are several arguments in favour of this move, not least that including wallet providers within the scope of regulation would increase the visibility of transactions, which is hoped would help curb the misuse of cryptocurrency. Another argument for the move is that it would dispel any uncertainty on whether the currency is covered by the law or not and it would thereby enhance its legitimacy, credibility and mainstream appeal.

However, consumers against regulation have argued that the lawlessness associated with the currency is the very thing that attracted them to it. The fact that it was first created to avoid the need for central authorities’ involvement means that the government should not interfere with it in any way. To do so would mean an unwelcome shift of power away from individuals and towards the government and banks. Amid news that the Bank of England is researching central bank-issued digital currencies with a view to obtaining a framework that could overhaul the current system, there is concern that the application of regulation would pave the way for the currency to be eventually transferred through banks.

Separately, the NCA have indicated there is not a particularly strong case for introducing regulation in the UK. Although the scale of the threat is difficult to assess, cryptocurrency has not been widely adopted as a means of payment for goods or services in the broader criminal community and there is little evidence to indicate use by established money laundering specialists.

The Powers of Law Enforcement

At present, UK law enforcement authorities do not have jurisdiction to freeze users’ accounts because there is no central repository for the currency. Whilst the online storage is an intrinsic feature of the currency system that cannot be easily reformed, the government is considering how to overcome the difficulties associated with asserting jurisdiction.

One option the government is examining is co-ordinating the powers of law enforcement at European or International level and having regulations covering the ability to seize and confiscate cryptocurrency funds where transactions are for criminal purposes. It is unclear exactly what regulation will be put into place, although account will likely be taken of the fact that courts in other countries such as Belgium and the Netherlands have ruled cryptocurrency a seize-able asset. Their authorities are also developing methods of storing confiscated currency. The public in these countries have largely welcomed the move, so the UK government may wish to follow these examples.

Arguments against the move, again, come from the libertarians who wish to preserve the lawless origins of the currency and the content of those arguments would be similar to those they provided against anti-money laundering regulation.

Consumer Protection

At present, there is no express consumer protection in relation to cryptocurrency. The government is considering creating a framework for consumer protection, involving voluntary rather than compulsory compliance with best practice standards.

Consumer protection is felt necessary to offer cryptocurrency users the same protections as those using conventional methods of payment. Complaints about cryptocurrency transactions include that they are irreversible and, unlike credit cards, users will not receive any cash back for payments made in error or because of fraud or theft. Where theft of cryptocurrency occurs, for example, because of computer hacking, no intermediary steps occur that could potentially mitigate the owner’s loss. The currency’s users therefore have a greater responsibility to protect their funds, as they cannot be assured of any recourse to a bank or regulator.

The other side of that argument comes from some users who have said they find being completely in charge of their money empowering as it provides a sense of personal control and freedom. In addition, some cryptocurrency providers have responded to the need for consumer protection by reviewing and upgrading their own systems to allow a third party to arbitrate in the event of a dispute and return any money due to the user. It remains to be seen whether these new systems will be deemed to provide sufficient consumer protection alone, or whether the government will still press ahead with its proposals to implement its own standards for consumer protections in any event. If it does, the fact the standards are voluntary rather than mandatory will cause uncertainty amongst consumers who may not be clear on whether a cryptocurrency provider has adopted the standards or not.

Going Forward

At this stage, it is difficult to assess whether regulation should be put into place, as more specific details from the government are needed. However, it appears the government are faced with striking a balance between providing regulations that effectively prevent the misuse of cryptocurrencies, and attempting to avoid compromising the features that make it attractive to its consumers.

Contact Lewis Nedas

At Lewis Nedas we have a long and successful history of advising clients concerned with cybercrime or money laundering investigation/prosecution. If you require advice, contact our expert specialist defence lawyers either by calling us on 0207 387 2032 or by completing our online enquiry form here.

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Banks, FIFA and Fraud: Who broke the law?

corporate insolvency sports law footballThe past month has seen FIFA feature heavily in the media. Unfortunately, it has been for the wrong reasons. The ruling body for football across the world has been implicated in suspected breaches of anti-money laundering and bribery rules. If the news was not already damning enough, several UK banks including Barclays and HSBC, have now been implicated in the unlawful processing of allegedly corrupt payments made out to FIFA officials. With HSBC already reported to having settled an investigation into its banking practices by the Swiss authorities for £28 million (available here), more and more questions are now being asked about whether or not there is any truth to the allegations against the banks.

The speculation around the practices of banks and their suspected processing of corrupt payments to FIFA officials throws into light a very important question: what are the rules governing money laundering and bribery? As experts in financial crime, we at Lewis Nedas set out here what these rules are, and how they apply.

Precisely what is it that banks need to be concerned with?

The main concern for banks in relation to the situation involving FIFA, is whether they have processed payments to/from corrupt officials and in so doing, breached anti-money laundering rules. Furthermore, if there is any evidence that the banks were aware of the questionable nature of any payments, and had taken payment without question, they could also have violated bribery laws.

How are these areas regulated?

Banks operate on a plane governed by a variety of complex rules and regulations, and the anti-money laundering regulations and bribery legislation are among the most complicated to understand.

Money Laundering

Money laundering involves the exchange of either money or some other kind of asset that was obtained as a result of criminal activity, which is then exchanged for legitimate money or assets. In the UK, this is regulated by a variety of agencies including Her Majesty’s Revenue & Customs (HMRC) and the Financial Conduct Authority (FCA), who monitor the observation of the Money Laundering Regulations 2007 by the relevant businesses.

It is true that the Money Laundering Regulations only apply to certain organisations, but in reality, this applies to a lot of different businesses. This includes, amongst others:

  • Banks;
  • Accountants;
  • Lawyers; and
  • Tax Advisors.

If your organisation is governed by the Money Laundering Regulations, it is obliged to implement a series of processes and procedures that will actively detect potential instances of individuals attempting to launder money. This includes a requirement to:

  • Confirm that an individual is who they say they are by checking official documents e.g. passport;
  • Establish what the nature of the relationship between your organisation and an individual will be, and where money will be coming from/going to;
  • When dealing with individuals that are politically exposed, ensure that senior management approve the organisation engaging with this individual; and
  • Keeping up-to-date with an individual’s business and developing your risk assessment accordingly.

If you are suspicious that finances are the result of criminal activity, you must report this to the National Crime Agency (NCA) at the earliest opportunity. You should only continue with a proposed transaction after the NCA has given you its permission to do so.


Bribery, like money laundering, is illegal in the UK. The Bribery Act 2010 is the most important piece of legislation in this area and it outlaws the giving (and taking) of some kind of advantage (financial or otherwise), to require someone not to fulfil their duties as would be expected. Bribery also covers the giving (and taking) of finances or some other kind of reward, to reward improper conduct. It does not matter whether dealings concern an individual or an organisation, both are governed by the Act.

The legislation obliges organisations to take active steps to avoid being implicated in bribery. While it is not unlikely that bribery may be permitted in other countries, if a UK business is caught as having acquiesced in any such activities, it will be vulnerable to a legal charge under the legislation. Organisations must train their staff, and implement systems that are designed to identify the risk of bribery. Furthermore, they must instigate safeguards to prevent any such activity occurring.

Is there are defence to a claim that the rules have been violated?

If it is suspected that your organisation has breached the rules against money laundering or bribery, there will be a detailed investigation into your affairs. However it is possible, where legal proceedings are brought against you, to mount a defence in each case:

Money Laundering

It may sound simple but in order to credibly defend a claim for breaching the Money Laundering Regulations, you must be able to refute this by proving that you did follow them.

This is why it is incredibly important that you understand your obligations under the 2007 Regulations, and implement sophisticated procedures that allow you to satisfy your obligations. Record keeping is of particular importance in this respect.


There is a defence to an allegation of having been involved in bribery. You must be able to demonstrate that you and your organisation took the necessary steps expected of you to prevent bribery from occurring. In practice, this involves your training staff to spot bribery, and discouraging them from being involved in, and implication the business in bribery.

What is the penalty for failing to follow the rules?

Depending on the type of regime in question, the implications for an organisation of being found guilty of not honouring their responsibilities can be severe.

Money laundering

There are in fact a variety of penalties available to regulators, if you are found to have violated the Money Laundering Regulations. Depending on the severity of your non-compliance, there could be a significant fine issued against you and your organisation. Alternatively, in severe cases, a criminal prosecution can be launched.


If you are deemed to have personally been involved in Bribery, you could be imprisoned for up to 10 years and be given an unlimited fine. For organisations, the penalty for involvement in Bribery will also be an unlimited fine.

Contact our Financial and Regulatory Law Solicitors in London

If you have questions regarding the rules on Money Laundering or Bribery, contact us today. Lewis Nedas are experienced solicitors with particular expertise in financial and regulatory law. Our team is often engaged to assist clients facing investigations into alleged illegal conduct. We take a comprehensive approach to legal services, handling every aspect of your case and dealing with regulators on your behalf. Contact us today and see how we can help you.

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The FCA Get Tough with Keydata Officers – by Rhys Mardon

escape with cashWhat do terminally ill US pensioners, Amazon rainforest carbon credits, the British Virgin Islands, the mysterious death of a Malaysia-based UK fraudster, and the near-collapse of the Norwich & Peterborough Building Society all have in common? The answer is Keydata.

Keydata, founded by Stewart Ford, has been personally fined by the Financial Conduct Authority a record £75million fine, after the collapse of an investment firm left 37,000 investors with losses of up to £475million. The fine is nearly twenty times the previous highest fine against an individual by the FCA. The FCA also fined the firm’s sales director £4million and the company’s compliance officer a further £200,000, and banned the trio from working in financial services again.

Ford founded Keydata and, with this, he created a £2.8billion financial empire selling ‘death bonds’. Through a complex web of companies and trusts in the British Virgin Islands, Ford earned £72.4million in fees out of the £373million invested in Keydata’s ‘Lifemark’ funds. Along with an additional £22.7million paid to Keydata itself, the scale of the fees seriously undermined the chances of investors seeing the returns promised, according to the FCA. As a direct result of this, the level of the fine on Ford is equal to the extraordinary fees and commissions he allegedly took from investors who thought they were buying relatively low-risk bonds that would pay an income in retirement and protect their capital.

As part of the accusations against Ford, the FCA say that he acted “recklessly” and with “clear and acute” conflicts of interest. The investigation began under the FCA’s predecessor body, the Financial Services Authority. It is also alleged that Keydata’s promotions were grossly misleading and its products wholly inadequate, with investors being told their money was in tax-free ISAs, when in fact it was not.

In a press release, the FCA said, “Mr Ford deliberately concealed the problems with the portfolio underlying these products from investors, IFAs and the then FSA.” It continued, “The FCA further considers that the individuals deliberately misled the FCA by making false representations to the FCA in compelled interviews about the performance of the investment products.”

Ford denies the FCA’s allegations, and in a response statement he said, “The FSA set out deliberately to destroy Keydata and did so without any proper reason. In order to close the company down without notice they enlisted the assistance of PwC to report that the company was insolvent which they did without even bothering to speak to Keydata’s management – and which finding was wholly wrong.” He also went on to say, “The FSA and PwC collaborated and conspired to carry out a regulatory hatchet job on Keydata and on me.” He further said the FCA had been “over-aggressive” in its investigations into the firm, as the regulator was, at the time, stung by accusations over its performance during the financial crisis. He added that the FCA had blocked his efforts to put together a financial rescue package for Keydata. In 2011, the Serious Fraud Office closed its investigation into Keydata after it found insufficient evidence to prosecute.

Mr Ford is currently appealing to the High Court against the fine, and countersuing the FCA and auditors PwC for £700million.

It is alleged that savers were given assurances that banking group HSBC oversaw trading in the insurance contracts, which the bank strenuously denies. In reality, £103million from investors ended up in the hands of businessman David Elias.

Elias became a fugitive from justice after eluding a warrant for his arrest in 2001. All of the £103million has since disappeared. Elias died in May 2009, aged 54, in the Malaysian tax haven of Labuan, and was at the time involved in a string of other businesses, including promoting carbon credits in the Amazon. However, investigators have never been able to confirm his death, and there are suspicions he may still be alive and on the run somewhere in the Far East.

Keydata’s collapse also prompted the demise of the 150-year-old Norwich & Peterborough Building Society in 2011. N&P’s advisers had sold Keydata policies to 3,200 customers, and after regulators ordered the Society to pay a fine and compensation totalling £52.4million, it was forced into an emergency merger with the Yorkshire Building Society.

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