Karl Dunlop, Stuart Grehan and Ian Dunsford previously accepted disqualification undertakings for their management roles within the group of companies involved in the transfer of pension funds.
Stuart Grehan, Director of Sycamore Crown Ltd and also known as Stuart Chapman-Clark, agreed to a 9-year voluntary ban as a result of false and misleading statements made to encourage investors to transfer their pension pots.
Karl Dunlop (9 years), Director of Imperial Trustee Services Ltd, and Ian Dunsford (7 years), Director of Omni Trustees Ltd, agreed to voluntarily bans for failing to act in the best interests of pension members and subsequently failing to ensure investments were adequately diverse.
And despite not formally being appointed a director of Transeuro Worldwide Holdings Ltd, Stephen Talbot recently accepted a 9-year disqualification undertaking for failing to explain what happened to millions pounds worth of assets.
The investigation, led by the Insolvency Service, centred on the conduct of the directors connected with Transeuro Worldwide Holdings Ltd (TWH), who helped fund two introducer firms Sycamore Crown Ltd (Sycamore) and Jackson Francis Ltd (JF).
The introducer firms cold-called members of the public, inviting them to transfer their pension pots into Self Invested Personal Pension plans (SIPPs) and pension schemes operated by Omni Trustees Ltd (Omni) and Imperial Trustee Services Ltd (Imperial), who provided trustee and administrator services for two occupational pension schemes – Henley Retirement Benefit Scheme (HRBS) and Capita Oak Pension Scheme (COPS).
However, investigators found that the introducers from both Sycamore and Jackson Francis misled clients about their expertise and experience, offering ‘guaranteed’ returns designed to encourage them to transfer their existing pension funds.
As a result, more than £39m was paid into SIPPs, over £10m into COPS and more than £8m to HRBS. Members’ funds were then largely invested in unregulated investments in storage units which ultimately did not yield the level of returns promised to members.
Ken Beasley, Official Receiver for the Insolvency Service’s Public Interest Unit, said that unfortunately he has seen an increase in cases where members of the public have been persuaded to transfer their hard-earned pension pots into new schemes on the basis of unsubstantiated promises of higher returns which inevitably never materialise.
You may have seen the current campaign by the Financial Conduct Authority, where they recommend that you reject unexpected offers, especially those originating from a cold call. You should check who you are dealing with, avoid being rushed or pressured into making decisions and seek out impartial advice before going ahead with any pension transfer.
Suspicions should also be raised if you are promised high or guaranteed returns, unusual investments or complicated structures, high-pressure sales tactics, involvement of several parties, all taking a fee which significantly cuts into your pension pot, and long-term pension investments which could take years before you realise something is wrong.
Omni and Imperial are currently the subject of an ongoing investigation by the Serious Fraud Office (SFO) who are inviting members of HRBS and COPS to complete a questionnaire.
Notes to editors
On 21 January 2017 The Pension Regulator appointed Dalriada Trustees Ltd as trustee of HRBS and COPS. Work is still ongoing in relation to the status and value of individual members’ pensions.
About the directors
Stephen Michael Talbot
Director of Transeuro Worldwide Holdings Ltd (Company number: 103954) from Salford and DOB: Jan 1972
On 6 July 2018, the Secretary of State accepted a disqualification undertaking from Stephen Michael Talbot, who whilst acting as a director of TWH despite not being formally appointed as such:
- failed to ensure that TWH maintained or delivered up adequate accounting records.
- as a result of this it has not been possible to ascertain whether payments out of the bank account of over £37 million were for a purpose connected with the business, the reason over £740k was paid out to Mr Talbot, the reason why £7.5 million (net) was paid out to a Panamanian foundation for which Mr Talbot was protector, show commissions due to or received from the company, show the nature of receipts into the company or establish the presence of any claims for the liquidator to pursue.
His ban was effective from 27 July 2018 and lasts for 9 years.
Director of Omni Trustees Ltd (Company number: 08175702) from Barnet, Hertfordshire and DOB: Jan 1974
On 19 July 2017, the Secretary of State accepted a disqualification undertaking from Ian Dunsford, after he admitted that he:
- failed to ensure that Omni, as trustee of a retirement benefit scheme, had acted in the best interest of members.
- took the appointment as director despite lacking the relevant knowledge and understanding to manage a pension scheme, allowed a third party to make investment decisions, failing to ensure that the investments were sufficiently diverse.
- failed to take sufficient steps to safeguard returns on investments promised to members resulting in potential losses to the scheme of at least £560k.
- failed to take sufficient steps to prevent the transfer of £3.7 million of scheme assets to a third party outside the jurisdiction.
His ban was effective from 10 August 2017 and lasts for 7 years.
Director of Imperial Trustee Services Ltd (Company number: 08133190) from Worcester and DOB: May 1965
On 3 July 2017, the Secretary of State accepted a disqualification undertaking from Karl Dunlop, after he admitted that he:
- failed to ensure that Imperial, as trustee of a retirement benefit scheme, had acted in the best interest of members.
- took the appointment as director despite lacking the relevant knowledge and understanding to manage a pension scheme
- failed to ensure that adequate accounting records had been maintained (in particular relating to member transfers in of over £4 million when he was director)
- failed to ensure that over £9m investments were sufficiently diverse
- failed to take sufficient steps to safeguard returns on investments promised to members resulting in potential losses to the scheme of at least £1.6 million.
His ban was effective from 25 July 2017 and lasts for 9 years.
Director of Sycamore Crown Ltd (Company number: 08023102) and Jackson Francis Ltd Company number: 07763545) from Salford Worcester and DOB: August 1981
On 6 October 2016, the Secretary of State accepted a disqualification undertaking from Stuart Grehan, after he admitted:
- false and misleading claims had been made about Sycamore and JF’s level of expertise and experience to induce prospective investors to transfer their pension funds.
- claims were also made about the companies offering a range of investment products and ‘unbiased advice’ despite the only product actively promoted being unregulated investments in storage units which the companies had a vested interest in promoting due to the way in which they were funded.
- claims were made that a strict due diligence process was followed but there was no evidence that independent checks were carried out meaning so called ‘guaranteed’ returns were not received by pension members.
His ban was effective from 27 October 2016 and lasts for 9 years.
A disqualification order has the effect that without specific permission of a court, a person with a disqualification cannot:
- act as a director of a company
- take part, directly or indirectly, in the promotion, formation or management of a company or limited liability partnership
- be a receiver of a company’s property
Disqualification undertakings are the administrative equivalent of a disqualification order but do not involve court proceedings.
Persons subject to a disqualification order are bound by a range of other restrictions.
The Insolvency Service administers the insolvency regime, investigating all compulsory liquidations and individual insolvencies (bankruptcies) through the Official Receiver to establish why they became insolvent. It may also use powers under the Companies Act 1985 to conduct confidential fact-finding investigations into the activities of live limited companies in the UK. In addition, the agency deals with disqualification of directors in corporate failures, assesses and pays statutory entitlement to redundancy payments when an employer cannot or will not pay employees, provides banking and investment services for bankruptcy and liquidation estate funds and advises ministers and other government departments on insolvency law and practice.
Further information about the work of the Insolvency Service, and how to complain about financial misconduct, is available.
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