The investigation 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 JF 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.

Karl Dunlop, Stuart Grehan and Ian Dunsford accepted disqualification undertakings for their management roles within the group of companies involved in the transfer of pension funds.

Grehan, director of Sycamore, agreed to a nine-year voluntary ban as a result of false and misleading statements made to encourage investors to transfer their pension pots.

Dunlop, director of Imperial Trustee Services Ltd, and Dunsford, director of Omni Trustees Ltd, agreed to voluntarily bans of nine and seven years respectively for failing to act in the best interests of pension members and subsequently failing to ensure investments were adequately diverse.

Dunlop was found to have failed to ensure that adequate accounting records had been maintained, in particular relating to member transfers in of over £4m when he was director, or to ensure that over £9m investments were sufficiently diverse.

He also failed to take sufficient steps to safeguard returns on investments promised to members resulting in potential losses to the scheme of at least £1.6m.

Dunsford was found to have failed to take sufficient steps to safeguard returns on investments promised to members resulting in potential losses to the scheme of at least £560,000. He also failed to take sufficient steps to prevent the transfer of £3.7m of scheme assets to a third party outside the jurisdiction.

Additionally, and despite not formally being appointed a director of TWH, Stephen Talbot accepted a nine-year disqualification undertaking for failing 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 £37m were for a purpose connected with the business, the reason over £740,000 was paid out to Talbot himself, or the reason why £7.5m was paid out to a Panamanian foundation of which Talbot was protector.

Nor was it possible to 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.

Ken Beasley, official receiver for the Insolvency Service’s public interest unit, highlighted an increase in cases where members of the public have been persuaded to transfer their pension pots into new schemes on the basis of unsubstantiated promises of higher returns which inevitably never materialise.

Beasley said: ‘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.’

The Pension Regulator has 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.

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. 

The SFO questionnaire is here

Report by Pat Sweet