July 2022

Alexander David Securities in Liquidation.

The disgraced financial services firm, Alexander David Securities Ltd – LINK to Companies House, has placed itself into voluntary liquidation.  The company has been accused of assisting scammers in carrying out several scams and of obstructing insolvency firms and the authorities in the subsequent investigations. In late April the FCA made this announcement – LINK.

On 1st July 2022 the only two remaining officers, Sandra Scott and David Alexander Hill Scott, resigned leaving the company with no directors. The company had failed to comply with a Court Order to hand over financial records involving Simon Whittley-Ryan’s Win River Developments scam. We covered that in our article on the Green Swan Holdings Bond Scam – LINK just three days before Alexander David Securities threw in the towel. This is what we had to say:

“What is clear from Simon Whittley-Ryan’s previous companies is that he likes to sell fixed-interest, fixed-term products such as bonds.  The investors’ money is always paid to third party organisations.  For example, in Win River Developments Ltd (a Whittley-Ryan company which is in liquidation) he used Alexander David Securities Ltd (“ADS”) which is a FCA-regulated company.  It was being run at the time by a man called Angus Fredrick Rose.

Payment to a third party allows company funds to be disbursed to other third parties and to bank accounts owned by a company director without those transfers showing up in the accounts of Win River Development Ltd.  This provides a way for a company director to unjustly enrich himself and others.

WRD was wound up by the High Court in January 2020.  The liquidator of the company is entitled to receive all the company records and full disclosure from company directors, officers and any third party which holds records relating to the company.  The WRD liquidator requested records from Simon Whittley-Ryan, Alexander David Securities Ltd and an unnamed individual who we believe to be Angus Fredrick Rose because he was the director of ADS at the time.  The liquidator has advised creditors that all three parties have failed to fully co-operate.

WRD has now been in liquidation for 2 ½ years and the liquidator still hasn’t received all the company records.  This is typical Simon Whittley-Ryan behaviour which he has replicated in his other liquidated companies.  Failure to disclose records is generally an indicator that there have been dishonest transactions that they do not want investigated.  Honest parties with honest business transactions would have no reason not to hand over company records to a liquidator”.

It remains to be seen which insolvency firm has been appointed by the former directors and whether the victims of ADS will now be able to find out what happened to their money. There is an insolvency practitioner that Simon Whittley-Ryan would be very keen to have appointed because this man has a history of being sympathetic to scammers. We’ll be watching closely to see whether ADS has chosen this man and whether he will attempt to block attempts to disclose information which would help investors.

Alexander David Securities in Liquidation.

Moorwand and UPayCard Update.

Last week we published an article on UPayCard describing how it acted as a money mule for at least one binary option scam – LINK to article.  UPayCard was operating under the licence of FCA-regulated company, Moorwand Ltd which, until only a few months before the money mule operation began, used to be called UPayCard Ltd.

The article described how Moorwand was very reluctant to provide information on the party or parties which ran UPayCard under its licence. Now we understand why. One binary option scam victim trying to recover his money pales into insignificance when compared to Moorwand’s other problems. We came across this Bloomberg Report from January of this year – LINK.

To quote: “A tiny lender in Denmark with which Moorwand had developed a close relationship flagged hundreds of suspicious transactions involving the payments firm….” 

“Moorwand, controlled by Moldova-based businessman Wael Sulaiman Almaree, hasn’t been accused of wrongdoing and is still authorized to move client funds. Neither Almaree nor Moorwand responded to repeated requests for comment”. Well, if Moorwand isn’t prepared to respond to the mighty Bloomberg that explains why it won’t answer the simple questions of one of their scam victims.  It also explains why they’re not bothered about him calling in the FCA. They haven’t done anything about the “hundreds of suspicious transactions” so one more won’t make any difference.

The article is scathing about the way in which the Financial Conduct Authority failed to check many of the Electronic Money Institutions, including Moorwand, when it granted them licences to operate:

“Now questions are swirling around dozens of EMIs regulators licensed as part of a move to boost London’s reputation as a fintech center and promote banking competition. Hundreds of regulatory, legal and corporate filings reviewed by Bloomberg sketch an unsettling picture of this new corner of the City. And they point to oversight weaknesses at the U.K.’s Financial Conduct Authority.

Among the companies approved by the FCA, Bloomberg’s review found, are ones with executives or shareholders tied to Baltic money-laundering scandals, alleged financial wrongdoing in Russia and Kyrgyzstan, health-care fraud in the U.S. and suspected wrongdoing in Luxembourg and Australia. Dozens of firms are controlled by investors in jurisdictions far beyond the U.K., including the British Virgin Islands, Cyprus, Ukraine and the United Arab Emirates. Some openly boast of doing business with high-risk customers”.

“Transparency International U.K., the British arm of the global anti-corruption group, sounded an alarm in a report last month saying more than one-third of EMIs licensed by the FCA have red flags related to their activities, owners or directors”.

A website operating under the name FinTelegram claims to have reported on the activities of the Moorwand directors two years ago:

“FinTelegram reported on this network of companies around Robert Courtneidge and Guy El Khoury in February 2020, nearly two years ago. FinTelegram has noted many times that there is a massive money laundering problem around FCA-regulated financial institutions. Many of them make their money by supporting cybercrime activities, scammers, and high-risk businesses”.

“The report also confirms connections between Courtneidge and the disappeared crypto queen RUJA IGNATOVA, who ran the gigantic $4-billion crypto scam ONECOIN”.

This has added relevance because last week Ruja Ignatova was put on the FBI’s list of top ten most wanted criminals – here is a report on that by the BBC – LINK. 

Moorwand and UPayCard Update.

To view a more recent article on Moorwand’s involvement in binary option investment frauds click on this LINK.

FF Returns Scam Alert.

A group of scammers operating under the name of FF RETURNS is contacting the victims of collapsed investment schemes promising to be able to recover all of their money in return for a fee.  There is a genuine company called FF Returns Ltd which has been in existence since 2005, but these people are not part of that company.  They are just using that company’s name.  At the moment they are contacting victims of the High Street Group scam, but it can be expected that they will branch out to contact victims of other scams.

As is standard practice in these kinds of follow-on-frauds, the scammers are using money mules to collect the fees from anyone who is taken in by them.  A money mule is normally a limited company with a bank account, but it can sometimes be a bank account in an individual’s name.  The scammers have taken control of that bank account so that as soon as any money is paid in it can be immediately transferred out, generally to an offshore account which means neither the bank nor the Police are going to be interested in trying to recover the money.

In the case of this FF Returns scam, one of the money mule accounts they are asking their intended victims to pay into is an account in the name of J.S. DEVELOPMENT SERVICES LTD.  The bank account details are:

Account Name:  J.S. Development Services     Account Number: 20425629     Sort Code: 82-61-37  This is an account at Clydesdale Bank.

A check on this company at Companies House – LINK  shows that it was incorporated on 13th April 2022.  It is less than three months old.  It’s registered office is 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE which is a virtual office.  This means that there are tens of thousands of companies using that office address and if you were to visit the premises you will be told that they have never heard of J.S. Development Services Ltd.  The company has one one director, a 26 year-old man called JOVAN SINGH SAHOTA.

Acting as a company director and allowing others to control the company’s bank account for fraudulent purposes is a criminal offence which carries a prison sentence upon conviction of up to 14 years.  It’s a crime which is not punished enough because without money mules these scams could never get off the ground. Mr Sahota might view his involvement as harmless, but he is assisting in the theft of thousands of pounds from members of the public. If someone broke into a house and stole thousands of pounds they would expect to go to prison if caught.  This is no different.  Mr Sahota might only have received a small payment for allowing his company to be involved in money-laundering, but that’s no excuse.

Follow-on-frauds are rarely operated by one-man bands.  They are normally run by organised crime gangs and operated on a very large scale using lots of different money mules. Money mules can take in a lot of money in a very short period of time.  We are working one case where a money mule company took in £1.3m in less than 9 months.

Money mules are a key element in a lot of scams and the problem will only be brought under control when there is a concerted effort to prosecute offenders. In the meantime, if you are contacted by FF Returns you should report the matter to your local law enforcement organisation.  In the UK that would be Action Fraud – LINK.

FF Returns Scam Alert.

UPayCard Scam and Moorwand Ltd.

We have been working for some time with an investor who lost a lot of money in a binary option scam and have been tracking down the money mules which took in money for the scammers and enabled the scam to operate.  We have been having some success against some of the money mules and recently turned our attention to another one which went under the name of UPayCard.

The investor paid his money to UpayCard in March 2017.  A UK company called UPayCard Ltd had been operating under that name until November 2016 at which point it changed its name to Moorwand Ltd.  Here is a LINK to the Moorwand website.  The company is regulated by the Financial Conduct Authority and provides banking and card services amongst others.

UPayCard Scam and Moorwand Ltd.

In April 2021 the investor wrote to Moorwand requesting information on the UPayCard transactions.  In May 2021 he received a reply which included these statements:

“With regard to UPayCard this entity was a Programme Manager that operated under Moorwand’s licence that was acquired by a Cypriot firm Pap OnPoint in April 2019. We understand that UPayCard is no longer trading.  As much as we wish to, we are unfortunately unable to assist you further in this matter due to the fact that we  merely provided payment services with regard to the 2 payments you refer to”.

We admit to being confused by this reply.  A few months before the investor paid his money, Moorwand Ltd was called UPayCard Ltd and now it seems to be saying that somebody else took over the UPayCard business under their FCA-regulated umbrella.  They refer to the person or company which allegedly took over the UPayCard business as “this entity” but they don’t give the name of who took it over.  We found it odd that Moorwand was willing to inform the investor that in 2019 the unknown entity transferred UPayCard to Pap OnPoint i.e to give the name of the party which acquired UPayCard in 2019, but not to give the name of the entity which operated UPayCard under Moorwand’s licence up to that point i.e between 2017 and 2019.  That seemed a bit fishy to us.  The binary option scam for which UPayCard was a money mule involves quite a few Cypriot companies.  Cyprus was one of the scammers’ favoured jurisdictions for laundering money.

UPayCard Scam and Moorwand Ltd.

We have to say that Moorwand’s Anti-Money Laundering page is one of the best we have ever seen.  It is worth a look.  Here is a section from it:

Who Can be Liable for Money Laundering Charges?

Money laundering is a complex crime that requires more than one person for it to be successful. Consequently, if a money laundering charge is brought against a suspected criminal the following people can also be liable to be charged in conjunction:  

— Financial institutions

— Credit Institutions

— Accountants

— Tax Advisers

— Legal firms

— Casinos

— Auctioneers

It’s important to note that in many cases ignorance will not be an adequate defense, therefore it’s vital that any of the above people are up to date with money laundering tactics so as to not fall foul of the law.

Words which are very relevant to this investor’s case.

Moving forward to last month and there has been significant progress in finding the scammers and the money mules involved in this binary option scam.  We will write a separate article on that when it is appropriate to do so.  The investor, with our assistance, tried again to find out who was behind the UPayCard money mule operation at the time he paid it.  He appears to have been stonewalled by Moorwand.  He wrote:

“I am advised to pose two very simple related questions to you, requiring a “yes” or a “no”. Regarding my two payments, recorded as both being paid to Upaycard…… to account number 19244710 sort code 83-04-25 …… are those details of the account correct in being an account of Moorwand or not ?  To explain, I know that Upaycard Ltd changed its name to Moorwand Ltd on 11th November 2016, but did you keep the same bank account as held under the previous name or not?”

This was the investor’s first request for Moorwand to answer two questions with a simple YES or NO.

The Moorwand reply was:

“In relation to your questions:  The payments made in 2017 were made by you to an account operated by UPayCard and which were held in the name of UPayCard.  UPayCard operated, at the time, under permission from Moorwand.  UPayCard is no longer an active business; and

UPayCard was a business separate from Moorwand Ltd. UPayCard, at the time, had access to its own bank accounts.  I trust that the above assists. Please do not hesitate to contact us should you have any further questions.”

Now, to a lot of people this would seem to have answered the questions the investor asked, but in fact they don’t.  They gave a “Politician’s Answer” i.e when asked to give a simple YES or NO they avoided it by providing information that the investor did not ask for.  The first part of the answer (about whether the account belonged to Moorwand) was not answered with a YES or NO.  It was answered with UPayCard this and UPayCard that, but not a YES or NO.  The second part states that UPayCard was a business separate from Moorwand and that UPayCard had access to its own bank accounts.  That’s fine, but they haven’t said who actually owned or controlled UPayCard.  It was being operated under their licence, but by who ? For all we know it could have been the people behind Moorwand.  Also, to say that UPayCard had access to its own bank accounts is a clever way of avoiding the question.  We’re not interested if UPayCard had 1, 10 or 100 bank accounts of its own.  We’re only interested in the one which received the investor’s money.  A simple YES or NO would have answered that question.

So, to give Moorwand the benefit of the doubt and allow it a second chance to answer the questions with a YES or NO, the investor tried again.  He wrote:

“I have noticed that there are at least two unknown facts which are far from clear in your response.  First of all, can you please be specific saying yes or no, was account number 19244710 sort code 83-04-25 one of your company’s bank accounts?

Secondly, I note that UPayCard is a trading name, not a company name. You say that the company was issued a licence. Please can you advise me of the name of the company which entered into the licensing agreement with you”.

He received another reply.

“In answer to your questions:

1. This question was answered in our earlier email.
2. UPayCard was never licensed. This was never stated in the email communication between us”.

So that’s a second time when he asked for a simple YES or NO to the question of the bank account and he didn’t get it.  Also, it has been clarified that UPayCard was never licensed, but according to an earlier email above, it “operated under Moorwand’s licence”.  That’s useful because Moorwand would have a responsibility to ensure that this mysterious new entity, the ownership of which they are very reluctant to reveal, was compliant with FCA regulations.  For a second time Moorwand declined to give details of “the entity” which was operating under their licence.  They just ignored that aspect of the question.  We’re beginning to suspect that “the entity” which operated UPayCard under Moorwand’s licence was not an arms’ length independent entity and that it may have been associated with Moorwand and its directors in some way.

So the investor tried a third time. He wrote:

Thank you for your email, but you have not answered my questions. A YES or NO will be sufficient for the first question:  

Can you please be specific saying yes or no, was account number 19244710 sort code 83-04-25 one of your company’s bank accounts?

Can you clarify your response to question 2.

I note that UPayCard is a trading name, not a company name. You say that the company was issued a licence.  Please can you advise me of the name of the company which entered into the licensing agreement with you. Moorwand gave permission for some entity (you haven’t said who or what that entity was because “UPayCard” is just a trading name) to provide regulated services under the UPayCard name. As UPayCard was carrying out a regulated activity this makes you responsible for their conduct.

I note that you have not registered any entity as being an Appointed Representative of your company. Please can you tell me which entity was given the permission or I will be obliged to make a complaint against Moorwand, report this matter to the FCA and seek compensation from Moorwand through the FOS.”

He received another reply:

“The answers we have provided are perfectly clear. We will not be drawn into these matters further, which in our view are irrelevant as to the nature of your grievance. This will be our final response. Of course you are welcome to complain about Moorwand to the FOS (and/or report this matter to the FCA). This was mentioned in our correspondence to you back in May 2021. 

Please ensure that you include a copy of all our correspondence to the regulator should you choose to make a complaint.”

That’s the third time the investor asked for a simple YES or NO.  If the answer is NO then why not just say it and then the matter is done?  The more they avoid using YES or NO the more suspicious it looks.  Also, they have yet again declined to provide any information on “the entity” which was operating UPayCard under their license.  Instead they have invited the investor to report the matter to the FOS and/or the FCA, presumably because they think he won’t bother – but he will.  Dealing with the FOS and the FCA is going to be much more time-consuming and cause more damage to their reputation than simply writing YES or NO and giving details of the entity which was operating UPayCard.  We think Moorwand is hiding something.

UPayCard Scam and Moorwand Ltd.

What is clear is that UPayCard was a money mule which was laundering money for scam operations.  We are certain that many more ordinary investors will have paid money to UPayCard and we would like to hear from anyone who paid money to UPayCard from 2017 onwards and feels that they were a victim of a scam.

This article was sent to Moorwand for their comments prior to publication. We did not receive a response.

UPayCard Scam and Moorwand Ltd. 

We received some additional information just as this article was being published.  We will review and publish a follow-up article next week.