Inside the Insolvency Service’s 2026–2031 Investigations and Enforcement Strategy

The Insolvency Service has unveiled a sweeping new five-year strategy that signals a fundamental evolution in its role from an insolvency-focused regulator to a central pillar in the UK’s fight against economic crime. 

With fraud now the most commonly reported crime in the UK, the Service’s 2026–2031 Investigations and Enforcement Strategy lays out a clear and ambitious roadmap. The strategy outlines an expanded role for the agency, including increased enforcement powers, use of data analytics and technology, and closer collaboration with other government bodies. 

From liquidations to law enforcement 

Traditionally viewed as a body focused on liquidations and disqualifications, the Insolvency Service is expanding its scope. Its new strategic priorities emphasise criminal enforcement, asset recovery, and fraud prevention, particularly in areas of systemic abuse, such as Covid-19 Bounce Back Loan Scheme fraud and the misuse of corporate entities as vehicles for laundering money. 

What’s changing? 

  • A broader investigative remit that extends beyond insolvency cases 
  • Greater use of AI and data analytics to uncover complex fraud 
  • Stronger ties with enforcement partners like NATIS, CPS, HMRC, and Companies House 
  • A clear mandate to recover proceeds of crime, including from crypto-assets 

The numbers behind the strategy 

The strategy follows a period of heightened enforcement activity. In the 2024–25 financial year, the Insolvency Service: 

  • Secured 77 criminal convictions 
  • Disqualified over 1,000 company directors 
  • Achieved more than £4 million in compensation orders 
  • Delivered over £50 million in estimated economic benefit by removing bad actors from the market 

The strategy sets targets to expand enforcement activities over the next 5 years. 

Protecting market confidence 

One of the central themes of the strategy is restoring confidence in the UK’s corporate ecosystem. The Service will play a more prominent role in deterring misconduct, ensuring directors understand the consequences of non-compliance and that victims of economic crime see accountability in action. 

This aligns with the government’s broader ambitions to make the UK one of the safest places in the world to do business, especially in the wake of recent reforms at Companies House and increased scrutiny on shell companies and nominee directors. 

Tackling emerging threats 

The strategy doesn’t just address known threats; it also anticipates emerging ones. The Service is investing in expertise to handle: 

  • Cryptocurrency-linked fraud 
  • Cross-border financial crime 
  • Sophisticated abuse of government funding schemes 

With specialist teams and better intelligence-sharing frameworks, it aims to disrupt criminal networks before damage is done, moving from reactive to preventative enforcement. 

Strategic collaboration 

Perhaps most significantly, the strategy emphasises inter-agency collaboration. It recognises that no single authority can tackle complex fraud alone. The Insolvency Service will work closely with other government bodies, using shared data, joint investigations, and aligned enforcement tactics to deliver faster, more effective outcomes. 

Looking ahead 

As someone who’s worked in risk management and investigations for over 3 decades, I see the 2026–2031 Investigations and Enforcement Strategy as a major turning point in the UK’s approach to corporate oversight.  

For risk professionals, compliance leaders, and directors, the implications are clear: regulators will expect more transparency, better governance, and faster responses to warning signs of misconduct.  

This introduces both challenges and opportunities; increased scrutiny, a more aggressive enforcement posture, and expanded data surveillance mean businesses must take internal controls more seriously than ever. At the same time, the strategy promises a fairer marketplace, where those who follow the rules are no longer undercut by fraudsters operating with impunity. 

At ESA Risk, we’ll be tracking how this strategy plays out in practice, how cases are investigated, which industries come under the spotlight, and what risk professionals can do to stay ahead. 

Fraud investigations by ESA Risk 

If you suspect that a fraud has occurred within your business and need advice or support on the next steps, we’re here to help. 

Contact us at advice@esarisk.com, on +44 (0)343 515 8686 or via our contact form to find out more. 

 

Crossing the line: From misfeasance to fraud

In the world of corporate governance, directors are entrusted with significant power and responsibility. But what happens when poor decisions cross the line into misconduct? When does bad management become something more serious, something unlawful?

Distinguishing between poor business judgment and fraudulent behaviour is not always straightforward. Yet, for companies, creditors, and stakeholders seeking redress, this distinction is critical. Understanding when a director’s conduct moves from misfeasance to criminal fraud – and how to prove it – is essential for holding individuals accountable and recovering losses.

Misfeasance vs. fraud

At its core, misfeasance refers to the improper performance of a lawful act. For directors, this might include poor oversight, failure to act in the company’s best interest, or neglecting duties under the Companies Act or equivalent statutes. While misfeasance can lead to civil liability, it generally falls short of criminal behaviour.

On the other hand, if a director engages in wrongful conduct or the commission of an unlawful act, with intent or recklessness, this is where the legal exposure deepens. Knowingly making false representations, concealing liabilities, or misusing corporate funds are actions that cross into the realm of fraud, triggering both civil and criminal consequences.

The challenge lies in proving not just that a decision was bad or harmful, but that it involved dishonesty, deceit, or knowing abuse of power.

When does poor management become fraudulent?

Certain behaviours by directors, though cloaked in business decisions, may signal fraudulent intent. Common red flags include:

  • Concealment of material information from auditors or shareholders
  • Unexplained asset transfers to related parties or offshore entities
  • Falsified financial statements or backdated documentation
  • Use of company funds for personal benefit
  • Trading while insolvent, despite warnings from advisors or finance teams

These patterns often emerge in distressed or failing companies, where directors may take increasingly aggressive or deceptive actions to delay insolvency, protect personal assets, or cover up earlier misconduct.

Legal framework and thresholds

Legal remedies vary by jurisdiction, but in the UK, for example, key mechanisms include:

  • Section 212 of the Insolvency Act 1986 (UK) – misfeasance claims against directors for breach of fiduciary duty.
  • Fraudulent trading (Section 213) – requiring intent to defraud.
  • Wrongful trading (Section 214) – where directors continue trading when they knew (or ought to have known) there was no reasonable prospect of avoiding insolvency.

Courts will closely examine directors’ knowledge, intent, and the steps they took to fulfil their duties. Mere incompetence is not enough; litigants must demonstrate dishonesty, recklessness, or wilful disregard of responsibilities.

How investigations bridge the gap

Identifying and proving director misconduct requires more than suspicion. It demands a rigorous investigation, often under time pressure and with limited access to internal records.

This is where corporate investigation and litigation support teams play a vital role. Key tactics include:

  • Forensic accounting: Tracing financial flows, identifying anomalies, and uncovering misappropriation or fictitious transactions.
  • Digital evidence review: Recovering emails, deleted files, and metadata that reveal internal decision-making and intent.
  • Interviews and affidavits: Building timelines through witness statements and internal testimony.
  • Asset tracing: Locating diverted funds or property held through complex corporate structures or offshore vehicles.
  • Data analytics: Identifying trends or irregularities across vast datasets, such as procurement, payroll, or supplier contracts.

Done effectively, these efforts convert concerns into admissible evidence, laying the foundation for legal action.

When directors face personal consequences

In recent high-profile insolvency cases, courts have not hesitated to hold directors personally liable where misconduct is proven.

An example of this can be seen in the collapse of BHS (British Home Stores). In 2024, the High Court found that former directors had wrongfully continued trading when it was clear the company had no realistic prospect of avoiding insolvency, leading to worsening losses for creditors.

The court held them personally liable under Section 214 of the Insolvency Act and introduced the concept of “trading misfeasance” to address serious management failures short of fraud. The directors were ultimately ordered to pay over £150 million in compensation, reinforcing that failure to act in creditors’ interests during financial distress can result in significant personal liability.

Another striking case involved Liam Francis Wainwright, director of Rawdon Asset Finance, who was sentenced to seven years in prison in 2023 for a £20 million investment fraud.

Wainwright knowingly sold secured loans to investors while the company was insolvent and unable to meet its obligations. He used investor funds to support personal ventures, including racehorse ownership, and falsified documents to conceal the company’s financial reality. The case highlights how the misuse of company funds, falsified records, and trading while insolvent can combine to form a compelling criminal fraud prosecution.

Similar outcomes have been seen in cases where directors were found to have concealed liabilities, falsified documents to secure loans, or misled creditors. The common thread: dishonesty and intent to deceive.

Prevention, detection and response

To minimise risk and ensure accountability:

  • Strengthen internal controls around financial reporting and approvals.
  • Encourage whistleblowing with safe and confidential reporting channels.
  • Conduct periodic forensic reviews, especially in high-risk areas like procurement and cash management.
  • Act early: when concerns arise, instruct independent investigators to preserve evidence and assess risk.
  • Engage litigation support teams to assist legal counsel in evidence development and trial preparation.

While not every bad business decision is fraudulent, some cross the line, and those that do can cost stakeholders millions. The distinction between misfeasance and fraud lies in intent, concealment, and personal gain. By recognising the signs and deploying the right investigative tools, companies and creditors can hold directors accountable and support effective legal action.

Corporate investigations by ESA Risk

Our team of experienced corporate investigators is ready to support you with your investigation needs – from assistance with internal investigations to full-scale corporate investigations as an external investigations agency. We have access to digital forensics and data management technology, to aid investigations that involve large numbers of documents.

To instruct us on an investigation or for more information on our services, contact us at advice@esarisk.com, on +44 (0)343 515 8686 or via our contact form.

 

The new face of corporate fraud

The digital transformation of business has unlocked unprecedented efficiencies, but it has also opened the door to sophisticated new forms of fraud.

Among the most concerning developments are the emergence of synthetic identities, deepfake corporate officers, and AI-generated document forgeries. Deceptions that are increasingly difficult to detect with traditional due diligence methods.

These developments are not theoretical. Investigations in jurisdictions around the world are now revealing how generative AI is being actively used to fabricate corporate actors, forge documents, and move illicit funds through legitimate-looking entities.

The rise of deepfake directors and synthetic ID fraud

In the past, fraudulent incorporations often relied on stolen or recycled identity documents. Today, malicious actors can use generative AI to fabricate entire identities, complete with hyper-realistic facial images, counterfeit passports, social media profiles, and digital footprints.

With minimal oversight in many corporate registries, these synthetic individuals are slipping through the cracks.

This creates a critical challenge for compliance teams and investigators: how do you verify an individual who doesn’t exist?

AI-powered document forgery

Just as deepfake technology enables false identities, AI tools are now being used to forge documents, from invoices and contracts to bank statements and audit letters, with alarming realism.

Where traditional fraud requires basic Photoshop skills or rudimentary manipulation, generative AI tools can now:

  • Recreate logos, watermarks, and signatures with high fidelity.
  • Mimic writing styles, layout consistency, and document metadata.
  • Generate false invoice histories that align with legitimate-looking supply chains.

These fake documents are often used to:

  • Support fraudulent loan or trade finance applications.
  • Validate fictitious revenue in accounting fraud schemes.
  • Obscure money laundering transactions via fake vendor invoices.

According to Experian’s UK Fraud and FinCrime Report 2025, 35% of UK businesses were targeted by AI-related fraud in Q1 2025 – up from 23% in the same period last year, a surge fuelled by increasingly sophisticated techniques, including deepfakes, identity theft, voice cloning, and synthetic identities.

Warning signs and red flags

While synthetic IDs and AI-generated documents are hard to detect, several forensic red flags can help:

For synthetic directors:

  • Inconsistent or missing public records of the individual.
  • Digital photos that lack EXIF metadata or show visual signs of AI rendering (e.g., asymmetrical eyes, blurred backgrounds).
  • No verifiable employment or education history.
  • Repetition of similar director names or details across unrelated entities.

For AI-generated documents:

  • Uniform pixel patterns under magnification (suggesting image-based generation).
  • Metadata inconsistencies or overwritten PDF/XMP fields.
  • Signatures that appear identical across multiple documents.
  • Too-perfect formatting or terminology mimicking templated contracts.

How to protect against AI-driven corporate fraud

As AI-driven corporate fraud evolves, businesses and investigators must adapt. Here are several actionable steps:

Enhance KYC/onboarding protocols: Introduce biometric verification, reverse-image search, and cross-referencing of director identities with reliable databases.

Deploy AI against AI: Use AI-based document forensic tools that detect synthetic generation patterns, inconsistencies in text generation, or cloned signatures.

Audit high-risk entities: Conduct periodic deep dives into entities showing abnormal transaction patterns, limited physical presence, or rapid incorporation behaviour.

Work with experts: Partner with investigative firms skilled in digital forensics and open-source intelligence (OSINT) to proactively identify emerging threats.

ESA Risk investigations and due diligence

The illusion of legitimacy has never been easier to fake, or more dangerous to ignore. Deepfake directors and AI-generated documents are not science fiction, they’re happening now.

If you’re unsure whether a document or company is real, or if you need help investigating a suspicious entity, our team is here to help.

For further details of these services or to instruct us on a matter, contact us at advice@esarisk.com, on +44 (0)343 515 8686, or via our contact form.

The role of social media and OSINT in litigation support

In high-stakes litigation, the difference between success and setback often comes down to the quality and completeness of intelligence. Increasingly, that intelligence is found not behind closed doors, but in plain sight. Open-source intelligence (OSINT), particularly from social media and other publicly accessible data, has become an invaluable asset during corporate investigations and litigation support.

At ESA Risk, we see first-hand how the strategic application of OSINT can uncover hidden asset trails, expose inconsistencies, and flag reputational vulnerabilities. As clients face increasingly complex legal and regulatory environments, the ability to extract actionable insights from public data sources is more critical than ever.

What is OSINT and why it matters in litigation

OSINT refers to the collection and analysis of publicly available information, including social media activity, corporate registries, property databases, online forums, media coverage, and more. In the context of litigation support, this intelligence can help verify claims, identify undisclosed assets, establish behavioural patterns, and assess the risk profile of opposing parties.

Unlike privileged or court-ordered data, OSINT is both legally obtainable and court-admissible when gathered ethically and handled correctly. For law firms, general counsel, and private clients, OSINT provides a strategic advantage by uncovering what traditional discovery might miss or overlook.

Social media: A powerful lens into behaviour and wealth

Social media platforms have become digital diaries, revealing where people go, what they buy, who they associate with, and how they live. These platforms often provide more than just personal expression; they can offer evidence.

We have conducted investigations where individuals claiming financial distress were actively posting about luxury purchases or international travel. In other cases, LinkedIn profiles revealed undisclosed business interests relevant to disputes involving contract breaches and fiduciary obligations.

Importantly, the subject’s own posts are not the only data points that matter. Friends and family often tag or mention individuals in ways that place them in specific locations or contexts, creating a rich ecosystem of information that can support or contradict legal narratives.

Asset tracing through public clues

OSINT is particularly effective in asset tracing and financial investigations. A photo of a yacht on Instagram might lead to maritime ownership records, which in turn connect to offshore entities or nominee directors. A seemingly innocuous mention of a new residence could be cross-referenced with property databases to identify undeclared holdings.

When combined with corporate filings, sanction lists, court records, and cryptocurrency transactions, OSINT investigations can help map the lifecycle of an asset – how it was acquired, hidden, or transferred. This intelligence becomes vital in matters involving fraud, judgment enforcement, high-net-worth divorce, or cross-border insolvency.

Reputational risk in litigation strategy

Reputation is often a silent but influential factor in litigation outcomes. OSINT allows us to identify potential reputational risks before they impact the legal process, or the client’s broader interests.

By analysing news coverage, digital sentiment, online forums, and historical content, we can assess how a party is publicly perceived and how that perception could influence negotiations, regulatory scrutiny, or judicial attitudes. For clients concerned with brand protection or stakeholder trust, this intelligence is crucial.

Tools, ethics and best practices

While the sources are public, OSINT investigations demand rigor and professionalism. Our analysts use a suite of advanced tools, such as link analysis platforms, metadata extractors, image geolocation tools, and archival search engines, to collect and validate findings. But it’s not just about the tools; it’s about how the data is used.

We ensure that all intelligence is ethically obtained, thoroughly documented, and clearly contextualised. When requested, we preserve digital evidence in a forensically sound manner that supports admissibility in court proceedings.

The future: AI-enhanced OSINT and evolving litigation needs

Emerging technologies are expanding the reach and efficiency of OSINT. AI-driven tools now assist in pattern recognition, behavioural forecasting, and large-scale content analysis. These capabilities uncover connections and anomalies that manual review might miss, accelerating decision-making for legal teams and their clients.

AI-powered OSINT investigation tools offer powerful capabilities, but considerations must be made around privacy concerns. These include the automated inference of sensitive personal attributes (such as health status or political views), the risk of amplifying private information by linking seemingly unrelated data points, and the potential for bias or inaccuracies in AI-generated profiles.

Additionally, opaque or “black box” AI systems can make it difficult to explain how conclusions are reached, posing challenges in legal contexts. Critically, all of this must align with data protection laws like GDPR, which require a clear legal basis for processing personal data and robust safeguards to protect individual rights.

As litigation becomes more global and data-rich, firms that can fuse investigative skill, open-source intelligence and AI-tools whilst understanding the associated risks, will remain indispensable.

ESA Risk investigations

In today’s digital world, everything leaves a trail, and we know how to follow it.

Whether you’re preparing for litigation, conducting due diligence, or seeking to enforce a judgment, our investigations can uncover the evidence you need to move forward with confidence.

Our experienced team are ready to help you navigate complex cases with precision and discretion. Let us show you how we utilise open-source intelligence to deliver clarity, uncover truth, and give you the strategic edge your case demands.

For further details of these services or to instruct us on a matter, contact us at advice@esarisk.com, on +44 (0)343 515 8686, or via our contact form.

 

Bounce Back Loans: April – June 2025 roundup

We’re now 5 years on from the pandemic and cases of Covid-19 Bounce Back Loan Scheme (BBLS) related fraud show no sign of slowing down. A further 8 cases were reported in the last 3 months.

We continue our coverage on the Insolvency Service’s initiative to uncover financial wrongdoing connected to the Bounce Back Loan Scheme.

Bankruptcies and bans

Joseph Harrison, a car dealer from Wrotham, Kent, and director of Southeast Commercials Ltd, has been banned from acting as a company director for 12 years starting 6th May 2025, after abusing the Covid Bounce Back Loan Scheme. Harrison’s company applied for and received 2 £45,000 loans in 2020, violating scheme rules that limited businesses to 1 loan. Investigations revealed that Harrison falsely declared the second loan application as the company’s first.

His company, which sold used cars and motor vehicles, was later dissolved in January 2025. Harrison claimed the first loan application was submitted by a third party, but no evidence supported this. He has been ordered to repay £38,295 remaining from the second loan.

Carl Barnes, the director of Central Plumbing & Heating Lincoln Ltd, has been disqualified as a company director for 11 years after fraudulently obtaining a £47,500 Covid Bounce Back Loan. Barnes falsely claimed that his company had a turnover of £340,000 in 2019, when its actual turnover was £0. Central Plumbing & Heating Lincoln Ltd, incorporated in April 2016, had filed dormant accounts for several years after initially posting a small profit in its first year.

Insolvency Service investigations revealed Barnes’s dishonesty in exploiting the Bounce Back Loan Scheme, which was intended to support small businesses during the pandemic. The company went into liquidation in October 2022, and Barnes’s director disqualification was made official on 17th April 2025, beginning on 8th May 2025.

Romain McLean, a management consultant and sole director of RMC Associates Limited in Wimbledon, has been banned from serving as a director for 11 years following fraudulent activities related to the COVID Bounce Back Loan scheme. McLean deceitfully secured 2 loans totalling £80,000 by significantly overstating his company’s turnover on 2 occasions. Initially, in May 2020, he applied for and received £30,000, despite his company being entitled to only around £12,000, based on its authentic turnover which he inflated by over £100,000. Subsequently, in July 2020, McLean wrongfully secured an additional £50,000 by falsely claiming it was his sole application and overstating his turnover once again.

During the Insolvency Service investigation, McLean admitted to exaggerating his turnover to maximise the loan amounts, expressing a desire to get as much money as he could. As a result of the investigation, he agreed to an 11-year disqualification from acting as a company director, which began on 30th May 2025, and offered a £60,000 settlement repayment.

RMC Associates Limited, founded in 2008, faced a winding-up petition in 2023.

Suspended

Gary Wright, a former pub landlord from St Helens, applied for a £25,000 Bounce Back Loan in 2020 to support his business during the pandemic, but failed to disclose that he was bankrupt at the time. Wright owned the Talbot Ale House, which ceased trading in 2019. He was declared bankrupt in February 2020 due to debts owed to a utility company but applied for the loan in June 2020, falsely claiming the pub’s turnover was £400,000. Bankrupt individuals are legally required to disclose their status when applying for loans exceeding £500.

Wright repaid the loan in full prior to sentencing but was handed a suspended 2-year prison sentence at Liverpool Crown Court on 24th April 2023. He was also ordered to complete 150 hours of unpaid work and pay £1,500 in costs. Wright remains an undischarged bankrupt, meaning he is still subject to bankruptcy restrictions.

Rico Iheagwara, a 36-year-old recruitment consultant from Hertfordshire, has been sentenced to an 18-month suspended prison term for fraudulently obtaining £40,000 in Bounce Back Loans during the 2020 COVID-19 pandemic. His company, SJR Recruitment Limited, was not operational at the time he applied for 2 separate £20,000 loans, against the rules that permitted only 1 loan per business. Following his court appearance at St Albans Crown Court on 16 May, Iheagwara was also mandated to complete 120 hours of unpaid work and 15 days of rehabilitation activities.

SJR Recruitment Limited, incorporated in January 2017 and directed solely by Iheagwara, was later liquidated in April 2021 with over £67,000 in liabilities. Investigations revealed Iheagwara transferred the loan amounts to his personal account immediately upon receipt, using them for personal expenses, including rent and family support, rather than for business purposes as intended by the loan scheme. The Insolvency Service is actively seeking to recover the misappropriated funds under the Proceeds of Crime Act 2002.

Jagoda Rubaszko, a 37-year-old woman from Northolt, was found guilty of fraudulently claiming a £50,000 Covid Bounce Back Loan by inventing a non-existent administrative service business. Despite claiming a business turnover of £210,000, investigations revealed her actual tax returns were no higher than £15,100 annually between 2019 and 2021. Rubaszko admitted to being influenced by a man named Daniel, whom she could not prove exists, to apply for the loan and falsely declare bankruptcy to evade repayment.

She received the loan on 28th April 2021, after applying on 26th April 2021, claiming her business started on 1st March 2020. Instead of utilising the funds for business purposes, she transferred £50,000 in 22 smaller amounts to 5 different bank accounts in Poland over 2 months. These actions were in stark contrast to her declaration of paying Daniel a £17,500 commission, for which no evidence was found in her bank records.

For her fraudulent actions, Rubaszko was sentenced to 18 months in prison, suspended for 21 months, coupled with a 6-month curfew and a requirement to complete 175 hours of unpaid work. Subsequently, she was subjected to a 10-year Bankruptcy Restrictions Undertaking (BRU), effective until 2033, which limits her ability to manage a limited company.

Zahid Afzal, the director of Phone Bits Ltd and Phones Onn Ltd, which operate mobile phone shops in the UK, received a 2-year suspended sentence for fraudulently claiming £150,000 in COVID-19 Bounce Back loans. Initially, Afzal secured legitimate loans totalling £52,500 for his 2 businesses. However, he subsequently applied for 3 additional loans of £50,000 each by falsely claiming they were the first loan applications and inflating his companies’ turnovers.

Afzal transferred most of the fraudulent funds to his personal accounts, despite claiming the money was for business purposes. He was sentenced at Swansea Crown Court on 12th June 2025 for 3 counts of fraud by false representation. The Insolvency Service is now working to recover the funds under the Proceeds of Crime Act 2002.

Sentenced

Shohid Ahmed, a 40-year-old man from Bradford, was sentenced to 2 years in prison for fraudulently securing £100,000 in Bounce Back Loans. Ahmed used his wife’s identity to apply for 3 loans for his Indian restaurant, Red Square Restaurants Limited, despite not being the company’s named director and having previously claimed the business was no longer trading.

Ahmed also attempted to mislead investigators by using the personal details of a woman who was his father’s tenant, falsely registering her as the director of his company. He further produced a fake invoice for £15,000, claiming it was for a restaurant refurbishment.

He pleaded guilty to several offences and has only repaid £5,000 of the fraudulently obtained funds. The Insolvency Service is pursuing the recovery of the remaining money under the Proceeds of Crime Act 2002. Despite his claims, investigations found that the loan money was not used for the benefit of the business as required by the loan scheme. Ahmed was already disqualified from acting as a company director for 11 years due to his misconduct.

Insolvency and debt investigations

Seeing the whole picture in insolvency and debt cases is key to maximising returns to creditors. For more information on how ESA Risk can help to identify hidden assets or locate targets who have gone to ground, contact Mike Wright, Investigations and Risk Management Consultant, at advice@esarisk.com, on +44 (0)343 515 8686 or via our contact form.

You can also learn more from our Insolvency & Debt Investigations brochure:

 

Manchester networking event – June 2025

On Thursday 12th June, The 500 Club returned to Manchester for another vibrant evening of networking. Our second Manchester event of the year, following an equally fantastic gathering in February.

Alongside regular hosts Chris Jones of Asertis, Mike Sheath and Nicola Hainey of CAPA, Mike Rose, Liam Geoghegan and myself at ESA Risk, we welcomed a special guest host for this event, 18 St John Street Chambers.

This time, the backdrop was the stylish Rain Bar, a venue that proved to be as much a talking point as the conversations themselves. The setting created the perfect atmosphere for meaningful engagement.

As ever, the turnout exceeded expectations and the room bustled with a diverse mix of professionals, including representatives from prominent firms such as Bermans, CG & Co, Fieldfisher, JMW, Kuits, Moorfields, Quantuma, RSM, Weightmans and more, each bringing a unique perspective to every conversation.

From sharing insights on current challenges across sectors to identifying aligned goals between firms and individuals, the evening offered real value beyond business cards and pleasantries.

It was the kind of evening that sums up what The 500 Club is really about—creating opportunities for professionals to connect in an authentic, meaningful way.

We’re proud to be building a trusted network across the UK that enables people to build relationships, open doors, and support each other in an ever-evolving professional landscape.

Next up is Nottingham (19th June), a brand new city in our event line up and one I’m very much looking forward to hosting.

With events regularly held in Manchester, London, Leeds, Liverpool and more new cities joining the calendar throughout 2025, there’s never been a better time to get involved.

If you’re working in insolvency, restructuring, law, finance or related sectors and want to grow your network, deepen industry relationships, and be part of a forward-thinking community, we’d love to see you at a future event.

Follow us on LinkedIn to stay up to date with upcoming events or explore the 2025 calendar to find an event near you.

To join the invite list, email events@the500club.co.uk.

Gone quishing: The rise of QR code scams

During a time of rapid digital transformation, new forms of cyber threats constantly emerge. One such threat increasing in the world of cyber security is known as ‘quishing,’ a term derived from QR codes and phishing.

What is quishing?

Similar to classic phishing strategies, quishing exploits Quick Response (QR) codes to deceive individuals into divulging sensitive information or downloading malicious software.

It involves scammers creating these two-dimensional barcodes, that when scanned, lead unsuspecting users to fraudulent websites or prompts the download of malware directly onto your device.

This form of scam capitalises on the QR code’s popularity, convenience, and the public’s growing comfort with using them for everything from restaurant menus to payment systems.

The rise in QR code related scams

The BBC recently reported that QR code related scams are continuing to rise, with instances up 14-fold over five years.

These scams are primarily orchestrated by organised crime groups and have seen a sharp increase from 100 reports in 2019 to 1,386 in the previous year, as recorded by the national fraud reporting centre, Action Fraud.

The consequences of these scams can be severe, with victims sometimes losing substantial amounts of money, which in turn finances further criminal activities. Scammers have diversified their methods, using QR codes on printed flyers, in emails, and on social media, duping people into handing over sensitive information like bank details.

There are concerns that this type of scam is underreported, and figures could be even higher. This is because people scammed out of smaller amounts of money are less likely to report. However, money may not be the sole target, with further risks of sensitive data being lifted from devices then sold on or used for more complex fraud later down the line.

How to spot and prevent quishing

To protect yourself from quishing scams, here is what to look for and preventive measures to take:

Examine the URL: Before scanning a QR code, make sure the surrounding context seems legitimate. If you can, preview the link that the QR code will direct you to. This feature is available on some smartphones and third-party QR code scanning apps.

Look for tampering: A legitimate-looking sticker or code might be placed over the original one, directing you to a malicious site. Stay vigilant about where you find these codes.

Avoid downloading apps directly: If a QR code prompts you to download an application, it is safer to go through the official app store on your device.

Use trusted QR scanners: Some apps check the safety of a website before opening it and can offer an additional layer of security.

Employ cybersecurity tools: For businesses, it’s crucial to have cyber security systems in place that can detect and block malicious web content.

Given the rise in both the use of QR codes and the sophistication of scammers, quishing is expected to become a more significant threat. Awareness campaigns are crucial, as informed users are the first line of defence against these types of scams.

Individuals need to remain cautious, especially as scammers continue to target mobile devices with QR codes in ever more cunning ways. A recent example involved fraudulent parking meter codes, an industry where QR codes are utilised frequently, leading users to pay parking fees via a fraudster’s account.

For businesses, the consequences of quishing scams can be serious, leading to data breaches, financial loss, reputational damages and eroded customer trust. As such, it remains essential for organisations to educate employees on the dangers of QR code scams and to implement systems like Web Application Firewalls (WAFs) and Secure Email Gateways (SEGs) that help in sifting out phishing attempts.

Quishing is just one of the many dangers in the cyber landscape, and both individuals and businesses must take proactive steps to guard against such deceptive practices.

By staying informed, sceptical, and utilising security tools, we can fend off the malicious intent hidden behind those seemingly innocuous pixilated squares.

Cyber security support from ESA Risk

At ESA Risk, we offer a broad range of cyber security services that can help you secure systems and data, become more cyber-aware, identify breaches, and prepare for and respond to attacks.

For advice and support on making your business cyber secure please contact us at advice@esarisk.com, on +44 (0)343 515 8686 or via our contact form.

 

Bounce Back Loans: January – March 2025 roundup

Our coverage continues on the Insolvency Service’s initiative to uncover financial wrongdoing connected to the Covid-19 Bounce Back Loan Scheme (BBLS), amid sustained efforts to identify businesses and individuals who exploited the scheme intended solely for vulnerable businesses during the pandemic.

There were 7 updates from the Insolvency Service on BBLS-related fraud in the last 3 months.

Sanctioned

Zhongqing Li, the former owner of the Silver Sea Chinese takeaway in Gillingham, Kent, has been sanctioned with a nine-year disqualification from acting as a company director after wrongfully claiming a £50,000 Bounce Back Loan during the Covid pandemic.

Despite the business not meeting the eligibility criteria for the scheme, Li applied for the loan in June 2020. The Official Receiver discovered, following Li’s bankruptcy in June 2024 still owing the loan amount, that Silver Sea had not been trading by the required date of 1st March 2020 to qualify for the loan.

Li accepted a Bankruptcy Restrictions Undertaking (BRU) without disputing the claim that he obtained the loan improperly, leading to restrictions on his financial and business activities, including acting as a company director or borrowing over £500 without disclosing his sanctions, effective until 27th January 2034.

The Silver Sea takeaway is currently trading under new ownership while the Official Receiver investigates the possible recovery of the funds.

Huseyin Houssein, a 55-year-old former London minicab driver from Edmonton, North London, has been subjected to an 11-year sanction due to the abuse of the Covid Bounce Back Loan scheme.

In his application in August 2020, Houssein falsely claimed his business had a turnover of £200,000 the previous year to obtain the maximum loan of £50,000. However, it was discovered during his bankruptcy in February 2024 that the actual turnover was only £11,446, meaning he was entitled to just £2,861. Houssein spent the entire £50,000 between October 2020 and May 2021 on non-business related expenses.

As a result of giving false information and misusing the funds, Houssein has agreed to a BRU.

Suspended

Jordan Allen, a plasterer from Lancashire, fraudulently obtained a £50,000 Covid Bounce Back Loan in 2020 by exaggerating his business’s turnover by more than £200,000. His actual business turnover was only around £20,000 annually, making him eligible for just £5,000. Despite this, he claimed a turnover of £225,000. Allen spent the loan on personal expenses, including supermarket shopping, gambling, and fantasy football.

After declaring bankruptcy in 2021, he faced legal consequences and was sentenced at Preston Crown Court to a 16-month suspended prison term, 200 hours of unpaid work, and 10 days of rehabilitation activity, along with a mandate to pay £3,600 in compensation. Additionally, Allen agreed to a 10-year BRU.

Sentenced

Arti Deda, a Berkshire construction company director, was sentenced to 2-and-a-half years in prison and disqualified from acting as a company director for 10 years after fraudulently obtaining 2 maximum-value Bounce Back Loans, each worth £50,000, for his company Knight Workers Limited during the COVID pandemic.

The company, entitled to only one loan, falsely claimed annual turnovers of £390,000 and £495,000 to receive the loans which were never used for the benefit of the business as required. Instead, significant amounts were transferred to associates and third parties.

Following an investigation by the Insolvency Service, Deda was convicted of fraud and other criminal offences and ultimately failed to repay the loans. Knight Workers was liquidated in November 2021, with efforts now to recover the funds under the Proceeds of Crime Act.

Devon taxi driver, Murat Dogantekin, was sentenced to 2 years and seven months in prison for fraudulently securing 2 Bounce Back Loans totalling £100,000 during the Covid pandemic. By falsely claiming his turnover was over £350,000 more than his actual earnings, Dogantekin, aged 50, received far more financial support than he was entitled to, over £95,875 more. He transferred the fraudulent funds to a close family member and an offshore account, showing no intention of using the money for legitimate business purposes or making any repayments.

Residing in Exeter, and declared bankrupt in November 2021, Dogantekin ignored multiple attempts from Insolvency Service investigators to clarify his financial activities. His flagrant abuse of pandemic support measures has led to efforts to recover the funds under the Proceeds of Crime Act.

Nelson Clark, a 34-year-old taxi driver from Dartford, Kent, has been sentenced to 2-and-a-half years in jail for fraudulently obtaining £130,000 through three Covid Bounce Back Loans.

Clark significantly inflated his business turnover in the loan applications during 2020, misleading the banks on 2 separate occasions for his businesses, N Clark Taxis, Nelson Clark Management, and Rosewood Motors. Despite claiming an annual turnover of £120,000 for N Clark Taxis and £200,000 each for the other 2 businesses, investigations by the Insolvency Service revealed these figures were grossly exaggerated.

Clark misused the funds for personal benefit, including transferring £80,000 to a third party. Following his bankruptcy declaration in August 2021, he accepted a 10-year Bankruptcy Restrictions Undertaking in March 2022, limiting his financial activities. Again, The Insolvency Service is actively seeking to recover the fraudulently obtained funds under the Proceeds of Crime Act 2002.

Ilhan Kekec, a restaurant owner, has been ordered by the court to repay the full amount of a fraudulently secured £30,000 Covid Bounce Back Loan plus interest, totalling £37,426, or face an additional 18 months in prison.

Kekec, aged 36, had previously received a 2-and-a-half-year jail sentence in March 2024 for overstating his company’s turnover to obtain the loan and attempting to dissolve his business without notifying creditors. He was also ordered to pay £15,900 in costs. Kekec had admitted to using the loan to pay off personal debts instead of for the economic benefit of his business as claimed in his loan application. He further breached his duty by not informing creditors of his intention to dissolve Hizirali Ltd, the company set up to run Derwish Kebab Restaurant. Additionally, Kekec was banned from acting as a company director for three years.

Insolvency and debt investigations

Seeing the whole picture in insolvency and debt cases is key to maximising returns to creditors. For more information on how ESA Risk can help to identify hidden assets or locate targets who have gone to ground, contact Mike Wright, Investigations and Risk Management Consultant, at advice@esarisk.com, on +44 (0)343 515 8686 or via our contact form.

You can also learn more from our Insolvency & Debt Investigations brochure:

 

Leeds networking event – March 2025

Last week (13th March) Chris Jones from Asertis, Nicola Hainey from CAPAMike Wright, Mike Rose and I hosted The 500 Club in Leeds for the first time this year.

Following the incredible turnout at our Manchester, London and Birmingham events in the weeks prior, Leeds maintained the momentum, with an equally well attended evening at a favoured venue, Sky Lounge.

With fantastic views over Leeds, I enjoyed a wonderful couple of hours with professionals from many different firms, including Bishop and Sewell, Freeths, Irwin Mitchell, Keystone Law, Primas Law, Opus, Markel and Walker Morris. The conversation (and drinks) were flowing, with ample opportunity for introductions to new contacts, and overdue catch ups with friends.

It was an added bonus, and apt following International Women’s Day only a few days before, to meet some of the phenomenal women working within law, finance, insolvency and related sectors who were in attendance.

The 500 Club is next in Leeds on Thursday 10th July. Before then, you’ll find us in London (twice), Bristol, Liverpool, Newcastle, Glasgow, Edinburgh, Manchester and Nottingham. See the full 2025 event calendar.

Next up is Bristol (10th April) where my colleagues Caitlin Duncan and Mike Rose will be hosting for ESA Risk.

Join The 500 Club community online and stay informed about event updates throughout the year on our LinkedIn page.

Email events@the500club.co.uk to get your name on the invite list.

London networking event – February 2025

Hot on the heels of the very successful return of our networking series in Manchester last week, we continued on a high, with an equally well-attended London event on Thursday (13th February).

Joined by co-hosts Roger Dugan and Hannah Proctor of Asertis, Mike Sheath and Tony Sweeney of CAPA, my colleague Caitlin and I enjoyed a fantastic few hours of networking with some incredibly interesting professionals from firms such as 3 Paper Buildings, Arafino Advisory, Birketts, CBW Recovery, Dentons Howman Solicitors, Markel, Moore Kingston Smith and more.

As always, it was a pleasure to catch up with new and long-standing friends and introduce ourselves, and our events, to newcomers on the scene.

We stuck with a tried and tested venue for the occasion, Davy’s, a central meeting point that can cater to our need for good wine and a great atmosphere.

We’re overjoyed at the overwhelming response from individuals across the legal, finance, insolvency and related sectors interested in becoming part of our growing community,  not to mention our established contacts continued participation in networking events all over the country.

I’m looking forward to a jam-packed schedule and even more valuable connections in 2025.

The 500 Club is next in London on Thursday 24th April.

Upcoming events include Birmingham on Thursday 6th March, Leeds on Thursday 13th March and Bristol on Thursday 10th  April. Check out the full 2025 schedule. 

If you’d like to join our mailing list and receive invites to events near you, let us know. You can also join over 1,000 of your peers who keep up-to-date with The 500 Club on our LinkedIn page.

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