Due diligence on Serious Fraud Office directors - James Thomson, Magnus Falk and Sanjay Bhandari
Testing their Register of Interests for completeness and accuracy and finding instances of misleading declarations and evidence of identity fraud.
This is a due diligence assessment of the accuracy of the Register of Interests of three non-executive directors of the Serious Fraud Office.
James Thomson
One of the Police and Crime Commissioners, James Thomson, is a non-executive director of the Serious Fraud Office. His register of interests is here: Declaration of interests - Serious Fraud Office (sfo.gov.uk):
MJ Gleeson plc, Non-Executive Chairman;
Common Councillor, City of London Corporation;
City of London Police Authority Board – Chair;
The Association of Police and Crime Commissioners – Non-Executive Director;
National CRC Group Limited – Non-Executive Chairman;
City of London Crime Prevention Association – Patron;
Bridge House Estates Board – Board Member.
He only has one identity registered in Companies House: James Michael Douglas THOMSON personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk):
Total number of appointments 85
Current appointments 5
NATIONAL CRC GROUP LIMITED (13027672) Active
Taxassist Accountants, 4 Quinton Parade, Coventry, England, CV3 5HW
Role ACTIVE Director
Appointed on 14 January 2022
GROCERS'TRUST COMPANY LIMITED(THE) (00928562) Active
Grocers Hall, Princes Street, London, EC2R 8AD
Role RESIGNED Director
Appointed on 1 August 2021 Resigned on 31 July 2023
Chief Executive
THE ASSOCIATION OF POLICE AND CRIME COMMISSIONERS (05214716) Active
PO BOX 270, Guildhall, London, England, EC2P 2EJ
Role ACTIVE Director
Appointed on 15 July 2021
Chief Executive
MJ GLEESON PLC (09268016) Active
6 Europa Court, Sheffield Business Park, Sheffield, United Kingdom, S9 1XE
Role ACTIVE Director
Appointed on 10 June 2019
CASELLA LIMITED (04064589) Active
28 Monmouth Road, London, W2 4UT
Role ACTIVE Secretary
Appointed on 4 September 2000
Investment Banker
CASELLA LIMITED (04064589) Active
28 Monmouth Road, London, England, W2 4UT
Role ACTIVE Director
Appointed on 4 September 2000
Accountant
In the Serious Fraud Office Register of Interest James Thomson failed to disclose his recently resigned position at GROCERS'TRUST COMPANY LIMITED(THE) and his current directorship of CASELLA LIMITED, where he describes himself as an investment banker.
His investment banker role presents potential conflicts of interest, particularly since it is not disclosed, and this compromises audits because the auditors only take into account, for related party transactions, the interests that are declared to them.
He may have other identities registered without the middle names or as a secretary. None stood out, in the search list, with the same date of birth.
Others at the SFO do have multiple identities, particularly Sanjay Bhandari. These shield interests from consideration by audits and audit software - multiple identities are created by false non-match errors and they induce them all along the lines of accountability.
James Thomson's biography on the Serious Fraud Office website reads (Biographies - Serious Fraud Office (sfo.gov.uk))
"James Thomson has held senior leadership positions across the private and public sectors and is currently chief executive of MJ Gleeson plc. He is also chair of the City of London Police Authority Board, chair of the National Cyber Resilience Centre Group and a board member for the Association of Police and Crime Commissioners. He is a councillor at the City of London Corporation, a board member of Bridge House Estates Trust and a governor at the City of London School. James is a chartered accountant and spent his earlier career in financial services with PwC, HSBC and Deutsche Bank."
Here James Thomson has also failed to disclose his interests as an active director and investment banker with Casella Limited and a recent director of GROCERS'TRUST COMPANY LIMITED(THE).
He has a duty to declare these interests in the RoI, and biography, and on both counts he has not. This is evidence of concealment of private interests that he has a duty to disclose. I’ll send this in, as a complaint. I already know the likely outcome: It'll be found to be substantive, he'll be asked about it and he'll say, “it was an oversight” and update the register. He’ll get away with the fact that fraud by failing to disclose information is the definition of Section 3 of the Fraud Act 2006. Thereafter, future audits will at least have to take these interests into consideration and perhaps they'll find he has a conflict of interest.
Let's take a look at another of the NEDs.
Magnus Falk
"Magnus Falk has spent most of his career developing ways to exploit technology to improve business performance, first at Accenture and later at Credit Suisse, where his last role was Managing Director and Chief Information Officer for EMEA countries. He served as deputy Chief Technology Officer to the UK Government in 2014-15. More recently he has served on the boards of a bank and a data centre provider as well as being a Senior Advisor to the Financial Conduct Authority. He is currently a CIO advisor at Zoom."
In his register of interests he discloses:
Magnus FalkDirector of Magnus Ironside Ltd;
Advisor to CIO at Zoom;
Appointed as a Non-Executive Director to Nomura’s companies in the UK:
Nomura European Holdings plc
Nomura Bank International plc
Nomura International plc
Instinet Europe Ltd
Instinet International Ltd
In Companies House Magnus Falk has one identity with the following information:
Magnus Henry Peter FALK
Current appointments 5
Total number of appointments 9
Date of birth December 1963
INSTINET EUROPE LIMITED (01915961) Company status Active Correspondence address 1 Angel Lane, London, EC4R 3AB Role ACTIVE Director Appointed on 26 April 2023 Nationality British Country of residence England Occupation Company Director
INSTINET INTERNATIONAL LIMITED (01428443) Company status Active Correspondence address 1 Angel Lane, London, EC4R 3AB Role ACTIVE Director Appointed on 26 April 2023
NOMURA EUROPE HOLDINGS PLC (03536674) Company status Active Correspondence address 1 Angel Lane, London, EC4R 3AB Role ACTIVE Director Appointed on 13 March 2023
NOMURA BANK INTERNATIONAL PLC. (01981122) Company status Active Correspondence address 1 Angel Lane, London, EC4R 3AB Role ACTIVE Director Appointed on 13 March 2023
NOMURA INTERNATIONAL PLC (01550505) Company status Active Correspondence address 1 Angel Lane, London, EC4R 3AB Role ACTIVE Director Appointed on 13 March 2023
MAGNUS IRONSIDE LIMITED (09869343) Company status Dissolved Correspondence address Wilson Field Limited, The Manor House, 260 Ecclesall Road South, Sheffield, S11 9PS Role Director Appointed on 12 November 2015 Occupation Business And Technology Consultant
MHPF CONSULTING LTD (08427698) Company status Dissolved Correspondence address The Manor House, 260 Ecclesall Road South, Sheffield, South Yorkshire, S11 9PS Role Director Appointed on 4 March 2013 Occupation Business Consulting
CROWN HOSTING DATA CENTRES LIMITED (09274699) Company status Active Correspondence address Spring Park, Westwells Road, Hawthorn, Corsham, Wiltshire, England, SN13 9GB Role RESIGNED Director Appointed on 10 March 2015 Resigned on 24 November 2015 Occupation Civil Servant
FALK ASSOCIATES LIMITED (01560256) Company status Dissolved Correspondence address Clarendon House, Granville Park, London, SE13 7EA Role RESIGNED Director Appointed before 23 February 1992 Resigned on 3 September 2000 Nationality British Country of residence England Occupation Bank Director
Magnus Falk correctly declares all his appointments in Companies House, in his Register of Interest. The auditors will have checked that there are no conflicts or related party transactions. No worries, here. Except, he declares in his RoI, Magnus Ironside Limited as active, when it was dissolved on 18 December 2020 (MAGNUS IRONSIDE LIMITED overview - Find and update company information - GOV.UK (company-information.service.gov.uk)). His Register of Interest could enable a permission that should be denied, if it is relied on for due diligence. It's a red flag from an audit point of view.
Sanjay Bhandari
"Sanjay Bhandari had a 29 year career in professional services. He spent the first 15 years of his career as a lawyer specialising in fraud and white collar crime at Herbert Smith Freehills and Baker McKenzie. He then had a number of leadership roles in forensic technology, compliance and innovation at KPMG and EY, where he was a Partner for 12 years before taking up a portfolio career as an independent board member, adviser and charity trustee."
His Register of Interests reads:
Receive honorarium from Premier League as a panel assessor;
Trustee of Aleto foundation;
Trustee of Greater Sport (based in Manchester);
Trustee of Kick It Out (a football charity funded by the FA, Premier League, EFL and PFA);
Previous EY role worked on matters unrelated to investigations by the SFO declared at board meetings (BAT, Barclays);
NED of the Lawn Tennis Association;
Chair of the Space Catapault.
Searching for his name in Companies House we find he has several identities registered, with date of birth May 1968, instead of just one https://find-and-update.company-information.service.gov.uk/search/officers?q=sanjay+bhandari
Total number of appointments 1: Date of birth May 1968
SATELLITE APPLICATIONS CATAPULT LIMITED (07964746) Company status Active Correspondence address Electron Building, Fermi Avenue, Harwell, Didcot, Oxfordshire, OX11 0QR Role ACTIVE Director Appointed on 1 July 2021
Total number of appointments 1 Date of birth May 1968
LAWN TENNIS ASSOCIATION LIMITED (07459469) Company status Active Correspondence address The National Tennis Centre, 100 Priory Lane, Roehampton, London, SW15 5JQ Role ACTIVE Director Appointed on 1 August 2021
Total number of appointments 1 Date of birth May 1968
LTA OPERATIONS LIMITED (07475460) Company status Active Correspondence address The National Tennis Centre, 100 Priory Lane, Roehampton, London, SW15 5JQ Role ACTIVE Director Appointed on 1 August 2021
Total number of appointments 1 Date of birth May 1968
PEBBLES PERFORMANCE LIMITED (12631454) Company status Active Correspondence address Diamond House, Diamond Court, Bakewell, United Kingdom, DE45 1EW Role ACTIVE Director Appointed on 29 May 2020
Total number of appointments 1 Date of birth May 1968
GREATER MANCHESTER SPORTS PARTNERSHIP (03258930) Company status Active Correspondence address Greater Manchester Moving, House Of Sport, Rowsley Street, Manchester, England, M11 3FF Role ACTIVE Director Appointed on 13 July 2019
Total number of appointments 1 Date of birth May 1968
KICK IT OUT (03388001) Company status Active Correspondence address PO Box 6963, North Warwickshire, Nuneaton, Nuneaton, United Kingdom, CV11 9PA Role ACTIVE Director Appointed on 12 September 2019
Total number of appointments 1 Date of birth May 1968
THE WORLD REIMAGINED LIMITED (12501914) Company status Active Correspondence address The Clock House, Station Approach, Marlow, Buckinghamshire, England, SL7 1NT Role ACTIVE Director Appointed on 1 September 2021
Total number of appointments 2 Date of birth May 1968
ERNST & YOUNG LLP (OC300001) Company status Active Correspondence address 1 More London Place, London, , , SE1 2AF Role RESIGNED LLP Member Appointed on 24 September 2007 Resigned on 28 June 2019
ERNST & YOUNG EUROPE LLP (OC338303) Company status Active Correspondence address 1 More London Place, London, , , SE1 2AF Role RESIGNED LLP Member Appointed on 12 January 2009 Resigned on 28 June 2019
Testing the accuracy of Sanjay Bhandari’s declaration of interests
Looking at each of the interests Sanjay Bhandari declared in his Register of Interests, in turn:
Receive honorarium from Premier League as a panel assessor; not checked.
Trustee of Aleto foundation; Not encountered in Companies House; there is a company with this name but he isn't, and has never been, a director THE ALETO FOUNDATION LIMITED people - Find and update company information - GOV.UK (company-information.service.gov.uk), nor is he a trustee of the charity with this name Trustees, THE ALETO FOUNDATION LIMITED - 1138699, Register of Charities - The Charity Commission. “Trustee of Aleto foundation” appears to be a false registration of interest and could enable a permission incorrectly. This represents a risk to the public interest.
Trustee of Greater Sport (based in Manchester); If this is a reference to his directorship of GREATER MANCHESTER SPORTS PARTNERSHIP, held in identity 5, he has failed to use the correct name and this could be evidence of obfuscation. He is a trustee of the charity with the name Greater Management Sports Partnership, the same name as the company registration, but not the name he has registered in the RoI, Trustees, GREATER MANCHESTER SPORTS PARTNERSHIP - 1059115, Register of Charities - The Charity Commission. This is a red flag for potential fraud.
Trustee of Kick It Out (a football charity funded by the FA, Premier League, EFL and PFA); He has declared the trusteeship of the charity Trustees, KICK IT OUT - 1104056, Register of Charities - The Charity Commission but not registered the company with this name, held in identity 6.
Previous EY role worked on matters unrelated to investigations by the SFO declared at board meetings (BAT, Barclays); This is not an accurate declaration that he was a director of ERNST & YOUNG LLP (OC300001) Appointed on 24 September 2007 Resigned on 28 June 2019 and ERNST & YOUNG EUROPE LLP (OC338303) Appointed on 12 January 2009 Resigned on 28 June 2019, held in identity 8.
NED of the Lawn Tennis Association; This directorship is held in identity 3, LAWN TENNIS ASSOCIATION LIMITED, and is correctly declared.
Chair of the Space Catapault (sic). This spelling mistake of catapult would induce a false non-match error in audit software, this is a red flag for fraud. This is an inaccurate reference to his directorship of SATELLITE APPLICATIONS CATAPULT LIMITED, held in identity 1. This could be evidence of obfuscation.
He has failed to declare the interest held in identity 3, LTA OPERATIONS LIMITED, PEBBLES PERFORMANCE LIMITED, identity 4, and THE WORLD REIMAGINED LIMITED, held in identity 7.
Sanjay Bhandari purports to be eight people in Companies House. He registers only one of his interests correctly. He fails to register three interests held in three separate identities. He registers an interest for which no evidence could be found, "Trustee of Aleto Foundation". Companies House, as a result of the multiple registrations, makes 8 material misstatements relating to the "Total number of companies" with which Sanjay Bhandari is associated.
Multiple inconsistencies and inaccuracies have been identified with Sanjay Bhandari’s register of interests. These are red flags for fraud. Establishing multiple identities creates the potential for concealing interests. If interests have not been declared, this is evidence that the multiple identities were created with the intention of committing fraud by failing to disclose information. I allege that Sanjay Bhandari is a fraud for registering multiple identities in Companies House, confounding audits and due diligence, and for failing to register his interests, which conceals them from the public and auditors.
This lends weight to the theory that the reason I have been unable to get the Serious Fraud Office to address this method of identity fraud, is because there is at least one director of the SFO who is complicit in this behaviour.
Funding Both Sides: How Jewish Money Controls British Politics . . .
“During the previous Labour government, Tony Blair and Gordon Brown were ardent Zionists because they accepted the justice of Israel’s cause, not because Labour’s chief fund-raisers were first the Jew Michael Levy and then the Jew Jonathan Mendelsohn (both are now members of the House of Lords). And during the current Conservative government, David Cameron, Theresa May and Boris Johnson have been ardent Zionists because they too accept the justice of Israel’s cause, not because the Conservatives’ chief fund-raisers have been first the Jew Sir Mick Davis and then the Jew Sir Ehud Sheleg.”
https://www.theoccidentalobserver.net/2021/10/04/funding-both-sides-how-jewish-money-controls-british-politics/