Bribery and corruption tracker

Year of allegation(s)/offence(s): 2015 onwards

Enforcement body: SFO

Summary of allegation(s)/offence(s): Suspected fraud

• On 4 August 2023, CAA and the European Union Aviation Safety Agency issued safety notices to alert owners, operators, maintenance organisations, and distributors of suspected unapproved parts distributed by AOG Technics.
• On 21 September 2023, the United States’ Federal Aviation Administration issued a similar notice about parts distributed by the company.

Stage of enforcement action/investigation: Ongoing

• On 6 December 2023, the SFO conducted a dawn raid at a site in Greater London and made one arrest in connection with the investigation.
  

Year of allegation(s)/offence(s): 2023

Enforcement body: SFO

Summary of allegation(s)/offence(s): Suspected fraud

• Individuals at Axiom Ince, a law firm, were found to be misappropriating client monies to a total of approximately £66 million which meant it was forced to cease trading in September 2023.

Stage of enforcement action/investigation: Ongoing

• On 14 November 2023, seven individuals were arrested and searches were carried out across nine sites to bring individuals in for questioning and to search for potential evidence.

Year of allegation(s)/offence(s): 2018

Enforcement body: SFO

Summary of allegation(s)/offence(s): Suspected corruption

• Self-report relating to the conduct of the business in Algeria.

Stage of enforcement action/investigation: Ongoing

• As of the 12 June 2023, the investigation has been expanded to include further suspected corruption in the conduct of business in Oman.

Year of allegation(s)/offence(s): Pre 2022

Enforcement body: SFO

Summary of allegation(s)/offence(s): Suspected fraud

• The companies operated a pre-paid funeral plan scheme that collapsed in 2022 after failing to secure authorisation from the Financial Conduct Authority.
• Approximately 46,000 plan holders had paid toward funeral plans before the company collapsed.

Stage of enforcement action/investigation: Ongoing

Additional notes:

• On 11 October 2023, notices were issued compelling stockbrokers and financial institutions to produce information. This followed similar notices to UK banks and other potential witnesses issued at the end of September. Non-compliance with these requests is a criminal offence.
  

Year of allegation(s)/offence(s): 2015-2018

Enforcement body: SFO

Summary of allegation(s)/offence(s): Conspiracy to defraud, fraud by false representation and making and supplying articles for use in frauds.

• All four suspects including: former director and CFO Christopher Marsh; accountant Louise Marsh; Financial Controller Pritesh Mistry; and financial consultant Nilesh Kumar Lad, are charged with conspiracy to defraud for inflating the cash in Patisserie Holdings’ balance sheets and annual reports.
• Lad, Mistry and C Marsh are also charged with five counts of fraud by false representation and one count of making and supplying articles for use in frauds.
• Christopher Marsh is additionally charged with making false statements as a company director.

Stage of enforcement action/investigation: Ongoing

• On 10 October 2023, all four defendants attended the first hearing at Westminster Magistrates Court.
• All four defendants have been summoned to appear at Southwark Crown Court on 7 November 2023.

Year of allegation(s)/offence(s): 2009-2014

Enforcement body: SFO

Summary of allegation(s)/offence(s): Bribery and corruption

• The SFO alleges that Graeme Hossie, Rachel Rhodes and Ariel Armon paid bribes in Sierra Leone so that London Mining would receive favourable treatment in the progression of the mining business.
• Allegations related to irregularities concerning the company executives and their consultants.

Stage of enforcement action/investigation: Ongoing

• On Friday 14 July 2023 the three defendants appeared for the Plea and Trial Preparation Hearing at Southwark Crown Court . A trial date was set for January 2025, with the defendants being required to next appear at court on 6 October 2023 to enter their plea.
  
  

Year of allegation(s)/offence(s): 2013-2018

Enforcement body: SFO

Summary of allegation(s)/offence(s): Fraud and money laundering

• Conduct relates to investments sold through Sales Aid Finance (England) Ltd (SAFE), which changed its name to London Capital & Finance Ltd in July 2015.

Stage of enforcement action/investigation:

• Several individuals have been arrested in the Kent and Sussex areas and released pending further investigation.

Additional notes: Ongoing

• In September 2020, the SFO and FCA asked investors in London Capital & Finance Plc to complete a questionnaire by 31 October 2020 to be considered as a witness. 3,825 responses have been submitted.
  

Year of allegation(s)/offence(s): 2002

Enforcement body: SFO

Summary of allegation(s)/offence(s): Fraud

• Stolen funds in a suspected email fraud by the British-Lebanese national Abdallah Ali Jammal.

Stage of enforcement action/investigation: Ongoing

• In June 2023, the SFO secured provisional High Court approval to recover over £500,000 stolen from victims of the scam, trialling a new approach to victim reparation.

Additional notes:

• The SFO has identified a number of victims of the fraud and, working alongside the US Federal Bureau of Investigation, Australian Federal Police and European authorities, will seek to trace the stolen funds back to each of the known victims’ own accounts.
  

Year of allegation(s)/offence(s): 2010-2015

Enforcement body: SFO

Summary of allegation(s)/offence(s): Fraud by abuse of position

• SFO charged David Ames, chairman of the Harlequin Group of companies, with three counts of Fraud by abuse of position.

Stage of enforcement action/investigation:

• On 3 August 2022 the jury returned a unanimous guilty verdict.
• On 30 September, Ames was sentenced to 12 years in prison and disqualified as a company director for the max term of 15 years.

Additional notes:

• Mr Ames’ renewed application for permission to appeal his 12 year sentence was granted by the Court of Appeal on the 20 June 2023. In December 2023, Mr Ames’ was unsuccessful in appealing his conviction and sentence.
  

Year of allegation(s)/offence(s): 2008-2016

Enforcement body: SFO

Summary of allegation(s)/offence(s): Conspiracy to commit fraud by false representation and fraudulent trading

• Investigation into tree-based investment schemes run by the Ethical Group that included Ethical Forestry Limited.

Stage of enforcement action/investigation:

• On 14 June 2023 the SFO charged the former Directors of Ethical Forestry Limited, namely; Matthew Pickard, Stephen Greenaway and Paul Laver, with the following offences:
• Two counts of conspiracy to commit fraud by false representation and one count of fraudulent trading.
• On 28 June 2023 the former directors attended their first hearing and the case has been referred to Southwark Crown Court.
  

Additional notes:

• The Proceeds of Crime and International Assistance Department of the SFO, who are a team of specialist lawyers and financial investigators, has also opened a confiscation investigation into all suspects.
  

Year of allegation(s)/offence(s): 2011-2017

Enforcement body: SFO

Summary of allegation(s)/offence(s): Fraud

• Investigation into Capita Oak Pension and Henley Retirement Benefit schemes and Self-Invested Personal Pensions (SIPPS) sold through Sycamore Crown Ltd, Jackson Francis Ltd, TPS Land, CLP Brokers or PFR Services. The investments were made into storage pods and the investigation includes the Trafalgar Multi Asset Fund which invested in other products.
• Over 2000 individual investors are thought to have been affected by an alleged fraud, all of which involved the investment of their pension funds. The amounts invested total approximately £120m.

Stage of enforcement action/investigation: Ongoing

Additional notes:

• Investors continue to be invited to complete a secure on-line questionnaire.
  

Year of allegation(s)/offence(s): 2012-2013

Enforcement body: SFO

Summary of allegation(s)/offence(s): Fraud and fraudulent trading

• In September 2022, four individuals were charged with fraud offences.
• Nasser Alaghband and David Spriddell were each charged with two counts of fraudulent trading.
• Alaghband was additionally charged with six counts of conspiracy to defraud various financial institutions.
• Louise Worsell and Melis Erda, executives, were both charged with one count of fraudulent trading. Erda was also charged with six counts of conspiracy to defraud various financial institutions, Worsell with five counts of the same charge.

Stage of enforcement action/investigation:

• In February 2023, following a 20-week trial, the SFO secured convictions for Louise Worsell and Melis Erda on multiple counts of conspiracy to defraud. Alaghband had pleaded guilty to fraudulent trading prior to trial.
• In April 2023, Nasser Alaghband was sentenced to six and a half years in prison, while Louise Worsell and Melis Erda were sentenced to over three years each in prison.

Year of allegation(s)/offence(s): 2010-2015

Enforcement body: SFO

Summary of allegation(s)/offence(s): Fraud

• Mr Skeene and Ms Bowers defrauded investors of £37 million in a fraudulent green investment scheme.
• The SFO charged them both with:
• Three counts of conspiracy to defraud;
• Four counts of using a copy of a false instrument;
• Misconduct in the course of winding up of a company; and
• Making a false statement without oath.

Stage of enforcement action/investigation:

• All defendants found guilty on all counts.
• 11 years’ imprisonment for both individuals.

Year of allegation(s)/offence(s): 2012-2015

Enforcement body: SFO

Summary of allegation(s)/offence(s): Conspiracy to defraud

• Mr Strubel, Jolan Saunders and Spencer Steinberg defrauded investors of £72.5 million by exaggerating electrical supply contracts in the hotel industry.
• They were also found to have lied about a non-existent contract to supply the Olympic Village for the London 2012 Olympics.

Stage of enforcement action/investigation:

• Saunders pleaded guilty in July 2015 to one count of conspiracy to defraud and one count of acting as a director of a company whilst disqualified.
• Saunders was sentenced to seven years in prison for the conspiracy to defraud charge and one year, to run concurrently, for acting as a director whilst disqualified.
• Strubel and Steinberg, who were both tried and found guilty by a jury in February this year, were sentenced to seven years and six years and nine months respectively.

Additional notes:

• Renewed applications made by Saunders, Strubel and Steinberg for leave to appeal against sentence and for Strubel and Steinberg against conviction, were heard at the Court of Appeal on 11 April 2017. All applications were refused.
  

Year of allegation(s)/offence(s): 2003-2007

Enforcement body: SFO

Summary of allegation(s)/offence(s): Conspiracy to defraud

• Mr Revell-Reade used entities to pressure-sell shares in US-listed companies. Investors bought shares but were restricted from selling them for 12 months. They then found the shares were worthless as they belonged to shell companies or non-operating entities.
• Anthony May administered the processing of shares distributed to investors and managed the finances of the conspiracy, using off-shore bank accounts to distribute the funds obtained as part of the conspiracy.

Stage of enforcement action/investigation:

• On 6 June 2014, Jeffery Revell-Reade and Anthony May were sentenced to a total of 17 years in prison.
• Both convicted fraudsters attended a confiscation hearing on 19 April 2016 and were ordered to pay a total of around £11 million for their roles in the boiler room fraud.
• Mr Revell-Reade was disqualified from being a director of a company for 12 years.
• Mr May was disqualified from being a director of a company for 10 years.
  
• Mr Revell-Reade and a third defendant, John Robert Manning, were found not guilty of separate counts of corruption arising from the conduct of the fraud.

Additional notes:

• More than £1 million will be returned to more than 200 victims.
  

Year of allegation(s)/offence(s): 2003-2007

Enforcement body: SFO

Summary of allegation(s)/offence(s): Fraud

• The six defendants formed the senior management and operations team for three Madrid boiler rooms and conspired with Mr Jeffrey Revell-Reade and Mr Anthony May to defraud investors with or through the entities Tresaderns & Partners SL, Price Stone Group SL and Anderson McCormack SL.

Stage of enforcement action/investigation:

• Daniel Gooding was sentenced to 7 years imprisonment. Shaun Rumsey, Philip Morris and Jon Emery were sentenced to 5 years imprisonment. Ian Hughes and Emma Farmer were sentenced to 4 and 3 years imprisonment respectively. Michelle Coleman was sentenced to 21 months' imprisonment, to be suspended for two years.
• All were also given confiscation orders ranging from £8,000-981,280.78.
  

Additional notes:

• Daniel Gooding had his confiscation order, originally made on 11 December 2014 for the amount of £725,968.51, uplifted to £981,280.78 by Southwark Crown Court, on 17 November 2016.
  

Year of allegation(s)/offence(s): 2021-2022

Enforcement body: SFO

Summary of allegation(s)/offence(s):

• Investigations ongoing in relation to the business practices of the individuals associated with the company.
• 3 sites were searched by the SFO on 23 Feb 2022 with support from the NCA. At the search, 2 individuals were arrested and questioned.

Stage of enforcement action/investigation: Ongoing

Year of allegation(s)/offence(s): 2011-2015

Enforcement body: SFO

Summary of allegation(s)/offence(s): Bribery

• An SFO investigation exposed that Glencore had paid bribes to maximise its oil trading profits in five African countries. Bribes were disguised as a “service fee”, “signing bonus” or “success fee” in financial reports and totalled $29 million dollars.

Stage of enforcement action/investigation:

• In May 2022, the SFO charged Glencore Energy (UK) Ltd with seven counts of bribery in connection with its oil operations. In June 2022, Glencore was convicted on all charges after the company admitted to multiple counts of paying bribes to secure access to oil and generate illicit profit.
• In November 2022, as a result of conviction, Glencore was sentenced to pay:
• A penalty of £182,935,392;
• A confiscation order of £93,479,338.95; and
• Investigation/prosecution costs of the SFO of £4,550,362.
• Investigations into the individuals involved are ongoing.

Additional notes:

• Glencore’s bribery generated a financial benefit of approximately £93.5 million for the company.
  

Year of allegation(s)/offence(s): N/A

Enforcement body: SFO

Summary of allegation(s)/offence(s): Suspected bribery, corruption and related offences.

• The SFO entered into a Deferred Prosecution Agreement (DPA) with Amec Foster Wheeler Limited (AFWEL) relating to the use of corrupt agents in the oil and gas sector.

Stage of enforcement action/investigation:

• Under the terms of the DPA, AFWEL paid a financial penalty and costs amounting to £103m in the UK, which formed part of the US$177 million global settlement with UK, US and Brazilian authorities. The amounts paid by AFWEL in the UK include payment of the SFO’s costs of £3.4 million and payment of compensation to the people of Nigeria of £210,610.

Additional notes:

• The SFO has informed those connected with the investigation that it will not be pursuing prosecutions against individuals.
• Press releases indicate that the SFO investigation is not expected to impact the $2.2 billion takeover by Wood Group.
  

Year of allegation(s)/offence(s): 2012-2021

Enforcement body: SFO

Summary of allegation(s)/offence(s): Fraud

• Investigation of suspected fraud in relation to activities including the companies Buy2Let Cars, PayGO Cars, Rent2Own Cars and Raedex t/a Wheels4Sure.
• The company offered car leasing schemes where investors were given the opportunity to invest in cars to be leased out.

Stage of enforcement action/investigation: Ongoing

Additional notes:

• In April 2021, the SFO raided two properties, arrested one individual and conducted interviews of two unnamed suspects.
• In October 2021, the SFO arrested and interviewed a further unnamed suspect.
  

Year of allegation(s)/offence(s): N/A

Enforcement body: SFO

Summary of allegation(s)/offence(s): Fraud, fraudulent trading and money laundering

• Allegations in relation to the financing and conduct of the business of companies within the Gupta Family Group Alliance (GFG), including its financing arrangements with Greensill Capital UK Ltd.

Stage of enforcement action/investigation: Ongoing

Year of allegation(s)/offence(s): 2013-2019

Enforcement action: SFO

Summary of allegation(s)/offence(s): Suspected fraud and money laundering.

• Relates to investments offered in care homes and hotels.

Stage of enforcement action/investigation: Ongoing

Additional notes:

• The SFO has asked UK-based investors into the suspected fraudulent schemes to complete a questionnaire and interviews will be undertaken to identify information.
  

Year of allegation(s)/offence(s): 2014-2019

Enforcement body: SFO

Summary of allegation(s)/offence(s): Fraud

• Suspected of fraudulently misleading investors into purchasing leaseholds for student accommodation across the UK.
• Suspected of misleading investors into purchasing leaseholds for holiday accommodation in Devon.
• Linked to the conviction of a former executive at the airline Garuda Indonesia.

Stage of enforcement action/investigation: Ongoing

Additional notes:

• Approximately £150 million was invested through leasehold schemes on the promise of 8-10% guaranteed returns.
  

Year of allegation(s)/offence(s): 2014-2016

Enforcement body: SFO

Summary of allegation(s)/offence(s): Bribery and Money Laundering

• The individuals were charged in relation to offences related to payment of bribes to win contracts in the construction sector.

Stage of enforcement action/investigation:

• The individuals were acquitted of all charges on 24 January 2023. The payments in question represented legitimate introduction fees, which were commonplace in the industry.
• The position was that the payments in question represented legitimate introduction fees, which were commonplace in the industry.

Year of allegation(s)/offence(s): 2011-2017

Enforcement body: SFO

Summary of allegation(s)/offence(s): Bribery

• Seven separate offences of failing to prevent bribery.
• The bribes were to secure contracts in the oil and gas industries in Iraq, Saudi Arabia and the United Arab Emirates and amounted to £32 million to win over £2.6 billion in contracts.

Stage of enforcement action/investigation:

• Following a plea agreement with the SFO, Petrofac Limited pleaded guilty to each offence on Friday, 1 October.
• Petrofac was ordered to pay confiscation of £22,836,985, pay SFO costs of £7 million and fined over £47,197,640.
• Global Head of Sales for Petrofac, David Lufkin, was sentenced to two years custodial sentence, suspended for 18 months.
  

Additional notes:

• Complex and deliberately opaque methods were used by senior executives to pay agents across borders, disguising payments through sub-contractors, creating fake contracts for fictitious services and passing bribes through more than one agent and one country.
  

Year of allegation(s)/offence(s): 2007-2012

Enforcement body: SFO

Summary of allegation(s)/offence(s): Corruption

• GPT, Jeffrey Cook, former Managing Director of GPT, and John Mason, the financial officer and part owner of the foreign-registered companies Simec and Duranton, subcontractors to GPT, were charged with corruption in relation to contracts awarded to GPT in respect of work carried out for the Saudi Arabian National Guard.

Stage of enforcement action/investigation:

• GPT pleaded guilty to corruption between December 2008 and July 2010.
• The Judge ordered the company to pay a confiscation order of £20,603,000, fine of £7,521,920, and costs of £2,200,000.
  

Additional notes:

• Jeffrey Cook was also charged with misconduct in public office between September - November 2008 in relation to commission paid to him on contracts he placed with ME Consultants Ltd for the Ministry of Defence, by which he was employed.
• Terence Dorothy was additionally charged with aiding and abetting that offence. In April 2022, the SFO obtained a Nolle Prosequi for Terrance Dorothy from the Solicitor General, meaning he will no longer be prosecuted alongside Mason and Cook.
  

Year of allegation(s)/offence(s): N/A

Enforcement body: SFO

Summary of allegation(s)/offence(s): Bribery and corruption

• In relation to contracts and/ or orders from Garuda Indonesia.

Stage of enforcement action/investigation: Ongoing

Year of allegation(s)/offence(s): 2010-2012

Enforcement body: SFO

Summary of allegation(s)/offence(s): Fraud, Fraudulent trading and transferring criminal property

• Timothy Schools and Richard Emmett were accused of carrying out a multimillion pound scheme to divert money from the fund for their own benefit. Richard Kennedy was also charged.

Stage of enforcement action/investigation:

• On 9 August 2022 Timothy Schools was found guilty on 3 counts of fraudulent trading, one count of fraud, and one count of transferring criminal property. He was sentenced to 14 years' in prison and handed a Serious Crime Prevention Order in place until 5 years after his release, and a directors’ disqualification for 15 years.
• Richard Emmett was acquitted of one count of fraudulent trading and one count of being concerned in an arrangement which facilitate the acquisition, retention, use or control of criminal property by another.
• The jury was unable to reach a verdict regarding David Kennedy, charged with one count of fraudulent trading. He is due to be retried on 18 March 2024.
• Confiscation proceedings have started and a hearing was listed for 7 September 2023.
  

Additional notes:

• Mr Schools’ appeal against his 14 year sentence was dismissed by the Court of Appeal on the 29 March 2023.
  

Year of allegation(s)/offence(s): 2015

Enforcement body: SFO

Summary of allegation(s)/offence(s): Bribery

• ASL was charged with three counts of failure to prevent bribery arising from the company’s use of an agent to win three contracts worth over £7.3million.

Stage of enforcement action/investigation:

• DPA approved.
• ASL was required to pay a penalty of £1,238,714.31 and disgorgement of profits representing the gain of criminal conduct of £990,971.45.
  

Additional notes:

• Contracts were to refit Lufthansa airliners. The agent acting for ASL was working as a project manager for Lufthansa, as a consultant and then employee.
• He used this position to provide an illicit competitive advantage for ASL.
  

Year of allegation(s)/offence(s): N/A

Enforcement body: SFO

Summary of allegation(s)/offence(s): Fraud and money laundering

• On the 16th May 2019, the SFO announced its investigation into certain aspects of biodiesel trading at Greenergy and various third parties.

Stage of enforcement action/investigation:

• On 8 December 2020, biodiesel trader and former employee at Greenergy, Gianni Rivera, was charged with fraud and money laundering. The trial is expected to commence in April 2024.
• Investigations ongoing.
  

Additional notes:

• Greenergy and its current employees are no longer suspects in the investigation.
  

Year of allegation(s)/offence(s): 2004-2012

Enforcement body: SFO

Summary of allegation(s)/offence(s): Corruption and bribery

• Charges of corruption and failure to prevent bribery in relation to the systematic use of bribes to secure contracts for the company which had a total value of £17 million.
• Three individuals were charged in 2016 for conspiring with various agents to agree bribes in relation to 27 overseas contracts.

Stage of enforcement action/investigation:

• Ordered to pay £6,201,085 in disgorgement of gross profits and a £352,000 financial penalty.
• In 2019, a DPA was entered into between the SFO and Sarclad. Relevant individuals were also acquitted.

Additional notes:

• £1,953,085 was paid by Sarclad’s US registered parent company as repayment of a significant proportion of the dividends that it received from the company over the indictment period.
  

Year of allegation(s)/offence(s): 2004-2006

Enforcement body: SFO

Summary of allegation(s)/offence(s): Bribery

• Senior executives conspired to pay $350,000 in bribes to an Angola state oil company agent to secure shipping contracts worth $20 million.
• Six executives were convicted for their roles in the scheme.

Stage of enforcement action/investigation:

• Bertling was fined £850,000 for its conviction.

Additional notes:

• Joerg Blumberg, Dirk Juergensen and Marc Schweiger were convicted for conspiracy to making corrupt payments. Each was given 20 month sentences, suspended for 2 years, and a £20,000 fine.
• Giuseppe Morreale, Stephen Emler and Ralf Petersen also pleaded guilty to making corrupt payments and were sentenced in the Jasmine case.
  

Year of allegation(s)/offence(s): 2010-2013

Enforcement body: SFO

Summary of allegation(s)/offence(s): Corruption and bribery

• Stephen Emler and Giuseppe Morreale were investigated for their part in a corrupt scheme to secure a £16 million ConocoPhillips freight forwarding contract.
• Christopher Lane and Colin Bagwell were investigated for a separate bribery scheme, involving ConocoPhillips staff waving through inflated prices it charged for additional services.
• Over £350,000 was paid in bribes and facilitations payments.

Stage of enforcement action/investigation:

• The individuals involved were sentenced to various lengths of imprisonment for the Angola and Jasmine operations ranging from 6 months through to 2 years. They were also ordered to pay fines ranging from £5,000 to £20,000 each.