The Vegas Trust - The Fraud that had everything! Part Two.

Back in the office, I started to unravel the mess that was The Vegas Trust. The first thing I did was to get statements from the two City Bankers who had brought the matter to the attention of the DTI in the first place, as I believed their evidence would be vital to proving the case, and would be very persuasive to a Jury.

Let me say that both men were utterly charming, and allowed me to visit them. However, neither man was keen to make a statement and it was very clear that neither of them wanted, under any circumstances, to be called to give evidence in Court. Both insisted that if necessary, they would require a witness order to be issued by a Judge to enforce their attendance!

They were content to say that the document was utterly reprehensible and in their view a complete breach of the PFI Act, but when it came to wanting to be involved personally, they were very reluctant.

One of them greeted me when I walked in to his office. He came over and shook my hand. He did so in a very peculiar way, his thumb pressing between my knuckles and rotating hard. I shook his hand as best I could in return. He started to walk back to his desk then turned around and said 'Let me check that handshake again'! He held out his hand and I took it. He then proceeded to press another set of knuckles, while pressing hard with his thumb between the web of my thumb and first digit, while I simply tried to give him my usual firm grip handshake. He seemed satisfied and returned to his desk.

He insisted on having his original statement looked at by his lawyers before he would sign it, which took time, but eventually he did send it back, with a covering letter explaining how busy he was, and that he only expected to be called to give evidence if it was absolutely vital to the case.

I was very intrigued by the handshake episodes, and having been a Scotland Yard detective for some years I was not unaware of the influence of Freemasonry within both the City and the Force. I am not and never have been a Freemason, believing their practices to be incompatible with dedicated police work. However, some of my friends did practice the craft, and I asked one of them who was open about his interests to explain the significance of the handshakes.

His answer was fascinating. '...First of all...', he said, '...he would have almost certainly expected you to have been a City Police detective, not a Met officer. He wanted to see if you were a Freemason and what rank you held. You would have conveyed this in your first handshake with him. His handshake was intended to tell you that he was of very senior rank indeed in the Order. You must have inadvertently given him the impression that you were on the Square as well, but as you are not, he would have been confused as to your standing so he came back a second time. In his second handshake (which I had described) he was telling you that he was in distress, meaning he was indicating that he did not want to be put in an embarrassing position, and if you had been a Mason, you would have understood this...'

I was learning that Freemasonry played a significant part in the way in which the financial sector was run! These important men were prepared to complain about others from behind cover, but they didn't want to stand up and be counted when the chips were down. They had power, no doubt of it, but without responsibility, the prerogative of the whore, and they used their undoubted power in the City to get out of difficult situations when it didn't suit them to come to notice. I would later learn that in the City it is not the done thing to be a whistle-blower, no matter how elevated your position or how great your power. The financial sector frowns on those who tell tales outside the magic circle. No wonder they didn't want to come to give evidence.

More importantly, I had discovered something momentous in the Vegas Trust papers. The first six month audit had been given and signed off by a leading firm of accountants. They had simply taken all the trading statements provided by the firm, checked them to see that the figures on the documents tallied with the accounts of the Vegas Trust, and signed them off as being accurate and truthful. This audit report had been sent to all the clients of the Trust. This was going to make things very difficult for my investigation.

The investments from the clients had been paid into a bank account in Guernsey. Monies from that account to fund the trading operation were ostensibly drawn down and used to pay the margin deposits with the various broking arms of the brokerages used by the metals broker (who had been appointed as a manager to the Trust through a company trading in the Turks and Caicos Islands). All client money balances were held in an account in Guernsey, and they were administered by a Guernsey Accountant.

The documents disclosed that the Trust was showing a profit in the first six months from trading Silver in its books in excess of £150,000. My first thought was that the trader might have just forged the trade statements like Michael Doxford had done. No, the account statements were all provided by a well-known and distinguished old London-based, commodities trading broker house, and they were patently not forgeries.

I was aghast! I had just turned over a company that despite its breaches of the PFI Act, was clearly trading at a significant profit, and that money was now out of reach of the creditors and I was being blamed for causing the company to fail. The company had issued press releases stating that despite being a profitable concern,  (please read our accountant's audit report), the highly improper and precipitate actions of the police had created an atmosphere of distrust in which the company could not trade successfully any more, and would need to be wound up. It was unlikely that any monies would be realisable at the end.

I had started to receive letters before action from angry clients threatening the Commissioner of the Metropolitan Police and myself with writs for damages for destroying their investment opportunities. I had senior officers crawling all over me like a rash, demanding that I account for my actions and suggesting that the case be taken from me and closed down and settlements agreed with the losers. Two middle management officers who particularly disliked me were vociferous in their condemnation.

They resented me because my Commander had earlier sent me on an extended study visit to the USA where I had studied financial crime and financial regulation with the SEC, the CFTC in Washington, and all the major trading exchanges in Chicago, Philadelphia and New York. These men had lobbied long and hard to be allowed to accompany me on this visit, not because they knew anything about financial crime (they didn't), and not because they were going to stay at the Fraud Squad (they weren't), but because they fancied an extended trip to the States courtesy of the British taxpayer, using the excuse of being there to 'supervise' me. My Commander had put them firmly in their place and indicated that it was his decision that I would go alone and report back. This decision caused an enormous amount of resentment among a group of men who were steeped in the theory of hierarchy, and thought that I was being given privileges above my rank. On my return they made it their business to make my life a misery, and this case was a good opportunity for them to turn the knife.

I simply could not believe that the Trust had made this money lawfully. I had analysed their earlier trading and almost without exception, they had made consistent losses. Frankly, the metals' trader wasn't at all good at his job, he was nothing more than a bad gambler, and he got things consistently wrong. But hey presto, just as the audit date was about to arrive, he engaged in a spectacular trade which made a huge profit.

The whole case now hung on evaluating this one trade. If he was right, then I and my Fraud Squad career were probably finished. If he was wrong, then the case was a wide open fraud, and everything would go well after that! Or so I thought!

The trade was a short sale of silver, buying at a specific price, waiting for the price to fall, and then closing the contract at an even lower price, but making a profit on the differential. The trade statement showed the contract being opened on 1st November selling a significant number of lots of silver at a price of £234 a lot. The closing trade statement showed the contract being closed out on 15th November at a closing price of £210 a lot, a profit of £24 per lot. The number of lots involved meant that the total profits from this one deal were sufficient to wipe out the accrued debts from previous losses, and leave a balance, after commissions of in excess of £150,000.

My cop's instincts told me this was hooky, it just screamed 'Fraud' at the top of its voice and my detective's gut reactions were to continue to follow the evidence wherever it led. I had always been a huge fan of Sherlock Holmes, and Conan Doyle's brilliant creation was often a source of solace and instruction for me. I often quoted him to myself; '... It is a capital mistake to theorize before you have all the evidence. It biases the judgment...' or '... It is easier to know it than to explain why I know it...'  and even '... In solving a problem of this sort, the grand thing is to be able to reason backward. There are fifty who can reason synthetically for one who can reason analytically...'    But I particularly relied upon Holmes's most famous adage,  '... How often have I said to you that when you have eliminated the impossible, whatever remains, however improbable, must be the truth..?'

I rang the brokers and asked them if the first trade with its reference number had been undertaken by them and on their book. 'Yes' was the reply, 'we did this trade on the day in question.' I then asked if they had undertaken the other trade referred to on its specific date. 'Yes' came back the answer, 'they had done that trade also on the date referred to.'

Fuck! I put the phone down, I knew when I was beaten. It was only a question now of trying to save face and get us out of this mess with the least cost to the Commissioner and try and work out how I was looking forward to being a school crossing patrol constable in South Mimms for the rest of my career.

And then, a simple but highly unlikely thought struck me, as yet another of Holmes's philosophies came through to me. Here I was thinking about the imponderable and I still hadn't finished the main enquiry. Holmes once said '... Before turning to those moral and mental aspects of the matter which present the greatest difficulties, let the inquirer begin by mastering more elementary problems...'

I rang the brokers once more, was there just a chance? I could tell the guy at the brokerage was getting fed up with my calls.

'...Are these two trades directly related..?' I asked him, '...does the opening statement refer to a deal done which was closed by the second trade...?

'...I'll check...'

He was back on the phone. 'No, there is no connection between them. The first short position is the closing trade of an earlier long position on which they lost a lot of money. The second  long closing position is the first of two undertaken in a wash trade...' They just spent a lot of money on commission for nothing. By the way we have closed their account and issued a statutory demand for payment, they owe us a lot of outstanding money...'

(A wash trade is where a trade is opened and closed for the same price in the same transaction. It is a purposeless transaction but it exists to provide necessary documentation when a broker needs a convenient trade statement to close an open position. Its legality is dubious but was quite openly used in those days.) What the Vegas Trust had done was to use the back end of the first trade and the front end of the latter wash trade. Then discard the first and last documents and back the second and third documents together and call them a profit. As long as nobody asked any awkward questions, no-one would be any the wiser.

I sat back as an indescribable wave of relief flowed through me. The whole thing was a complete fraud. It wasn't just a case of some dodgy documents, the whole bloody shambles was a fraud from start to finish. They hadn't even paid their brokers, they were so greedy. My first concern was for the money in the accounts. The problem was, they were in Guernsey, and I had no powers there! I rang a colleague (and a mate) in the Guernsey Fraud Squad  

'It was more than his job was worth' to ask questions about a bank account he told me!' '... I will do what I can...'

He was back on the line, the accounts were empty and had been for some days, ever since the search of the premises.

But now, my enquiry was wide open and I could do what I wanted without hindrance. I was dealing with a major fraud case, the documents proved the whole operation to be a series of lies, the audit was hugely negligent because the accountants hadn't reconciled the bank accounts with the documents, but they simply wanted a quick fee for 5 minutes work, and hadn't asked the right questions. More importantly, these so-called forensic experts had no experience or gut reactions to recognise a fraud when it was in front of them. I was ecstatic, but my joy was to be short-lived.

I had learned that even the most elevated people in the City would prefer to play by their own rules rather than engage with the ordinary rules of social responsibility that apply to the rest of us. They considered themselves to be a class apart, and saw no reason why they should be required to conform. They knew the DTI Secretary of State personally, they met him at high City functions, and they were just passing on some information on an informal basis. They never ever expected to be required to step forward and become accountable. I began to learn that this attitude applied to everything that they engaged in. I was learning that the City had its own ways of doing things and the City did not believe that it was anybody's business but their own how they behaved.

I also learned that accountants will do anything for money. The old joke is true! What happens when you ask an accountant what two and two makes? His answer will be 'What do you want it to make?'

But then my problems really started, which I will deal with in the next posting.

Why Barclays Bank needs to be completely reconstructed!

Unless you have been completely out of reach of any form of media source in the last week or so, you cannot have helped learning of the growing scandal which is engulfing Barclays Bank for their part in the manipulating of LIBOR.

Even so, you might be still asking yourself why I have used the title above for this piece.

It is my contention that Barclays Bank has become a serial criminal enterprise, and it most closely resembles an organised crime group. I have used this phrase before, but now I am going to back it with evidence.

In January 2011, The Financial Services Authority (FSA) fined Barclays Bank (Barclays) £7.7 million for failures in relation to the sale of two funds. Barclays were ordered to contact customers and pay redress where appropriate.

Between July 2006 and November 2008 Barclays sold Aviva’s Global Balanced Income Fund (the Balanced Fund) and Global Cautious Income Fund (the Cautious Fund) to 12,331 people with investments totalling £692 million.

However, there were a number of serious failings in the way the funds were sold. These include:

·         Failing to ensure the funds were suitable for customers in view of their investment objectives, financial circumstances, investment knowledge and experience;

·         Failing to ensure that training given to sales staff adequately explained the risks associated with the funds;

·         Failing to ensure product brochures and other documents given to customers clearly explained the risks involved and could not mislead customers; and

·         Failing to have adequate procedures for monitoring sales processes and responding promptly when issues were identified.

The FSA’s investigation revealed that even though Barclays had itself identified potentially unsuitable sales as early as June 2008, it did not take appropriate and timely action.

In fact, of the 12,000 or so investors, most of whom were retired or nearing retirement, 1,730 complained about the advice they were given to invest in the funds. This equated to approximately one in seven investors.

As a result Barclays had already paid approximately £17 million in compensation and the FSA estimated up to £42 million further could be paid to customers who received unsuitable advice.

Margaret Cole, the FSA’s managing director of enforcement and financial crime, said:

“The FSA requires firms to have robust procedures in place to ensure any advice given to customers is suitable. Therefore, when recommending investment products, firms should take account of a customer’s financial circumstances, their attitude to risk and what they hope to achieve by investing.

“On this occasion however, Barclays failed to do this and thousands of investors, many of whom were seeking to invest their retirement savings, suffered. To compound matters, Barclays failed to take effective action when it detected the failings at an early stage.

“Because of this, and given Barclays’ position as one of the UK’s major retail banks, we view these breaches as particularly serious and fully deserving of what is a very substantial fine.”

Let us be absolutely clear, where a person solicits an investment in a product but fails to give the correct information to the person being solicited, whereby the investor makes an investment he or she would not otherwise have made, based on the misleading information, that is the criminal offence of fraud. Every single one of these misleading sales was a fraud, and Barclays personnel involved in this scandal should have been prosecuted for fraud.

This is a reason why Barclays have paid back significant losses caused to their clients by the mis-selling of PPI policies. In addition they have been the subject of regulatory investigations over the way they mis-sold interest-rate swap derivatives. The phrase mis-selling is merely a politically correct form of words which in any other walk of life would be called 'fraud'!

Again in January 2011 The Financial Services Authority (FSA) fined Barclays Capital Securities Ltd (Barclays Capital) £1.12 million for failing to protect and segregate on an intra-day basis client money held in sterling money market deposits.

Under the FSA’s client money rules, firms are required to keep client money separate from the firm's money in segregated accounts with trust status.  This helps to safeguard and ring-fence the client money in the event of the firm's insolvency.

For over eight years, between 1 December 2001 and 29 December 2009, Barclays Capital failed to segregate client money maturing from its sterling money market deposits on an intra-day basis.  Such client monies were segregated overnight but matured into a proprietary bank account and were mixed on a daily basis with Barclays Capital’s own funds, typically for between five and seven hours within each trading day.

The average daily amount of client money which was not segregated increased from £6 million in 2002 to £387 million in 2009. The highest amount held in the account and at risk at any one time was £752 million. Had the firm become insolvent within the five to seven hours each day in which the funds were unsegregated, this client money would have been at risk of loss.

Funnily enough, the man in charge of Barclays Capital at this time was Bob Diamond. It might be argued that such activity was not criminal per se, but one of the purposes of the client money rules is to ensure that banks protect their client's monies, and by failing to do this, Barclays were dealing with the money as if they were the owners and outside the lawful remit of their powers.

In August 2010, Barclays was forced to pay $298m (£190m) in fines to the US authorities for "knowingly and willfully" violating international sanctions by handling hundreds of millions of dollars in clandestine transactions with banks in Cuba, Iran, Libya, Sudan and Burma.

The bank agreed to pay financial penalties to settle two criminal charges laid by the US department of justice, which accused Barclays of violating a "trading with the enemy" act which prohibits business with certain countries viewed as threats to national security.

Documents filed at a federal court in Washington accused Barclays of handling money transfers totalling $500m from banks in prohibited countries through its dollar clearance branch in New York between 1995 and 2006. Barclays is not alone in facing such charges: Lloyds TSB and Credit Suisse both settled with the US government last year over similar dealings with institutions in repressive regimes.

"For more than a decade, Barclays knowingly and wilfully engaged in practices outside the US that caused its New York branch and other financial institutions located in the US to process payments in violation of US sanctions," said an affidavit filed by the US government, which described Barclays as a London-based institution employing 144,000 people in 50 countries with 48m customers.

Under a deferred prosecution agreement signed by Barclays' general counsel, Mark Harding, the bank had agreed to a string of measures to improve training and tighten internal procedures, and to co-operate with any further investigation by the US authorities. The bank paid $149m to the US department of justice and a further $149m to the office of New York's district attorney.

The deal went before a Washington judge for approval. But judge Emmet Sullivan adjourned the hearing, saying he wanted Harding to appear in person: "He's the one who signed the pleadings and he should be here."

The US government has vowed to come down hard on sanctions-busting. Cuba has been barred from business with the US since President Kennedy's tenure in the White House in the early 1960s. Sanctions have been in place against Iran since 1995 and were imposed on Sudan and Burma in 1997. Libya was on a list of "state sponsors of terrorism" until 2006, although relations have since thawed.

Prosecutors contend that foreign banks with a presence in the US have colluded in giving institutions in these repressive regimes a back-door route into the American financial system. Lloyds TSB agreed to pay $350m in January 2009 for its dealings with Libya, Sudan and Iran, while Switzerland's second biggest bank, Credit Suisse, struck a deal in December paying $536m for violating sanctions against Iran.

Finally in recent days, Barclays has been fined £290m ($450m) for trying to manipulate a key bank interest rate which influences the cost of loans and mortgages.

Its traders lied to make the bank look more secure during the financial crisis and, sometimes - working with traders at other banks - to make a profit. Barclays said the actions "fell well short of standards".

Barclays' misconduct related to the daily setting of the London Interbank Offered Rate (Libor) and the Euro Interbank Offered Rate (Euribor).

These are two of the most important interest rates in the global financial markets and directly influence the value of trillions of dollars of financial deals between banks and other institutions. They can also affect lending rates to the public, for instance, with some mortgage deals.

Between 2005 and 2008, the Barclays staff who submitted estimates of their own interbank lending rates were frequently lobbied by its derivatives traders to put in figures which would benefit their trading positions, in order to produce a profit for the bank.

And between 2007 and 2009, during the height of the banking crisis, the staff put in artificially low figures, to avoid the suspicion that Barclays was under financial stress and thus having to borrow at noticeably higher rates than its competitors.

The FSA pointed out that Barclays traders were quite open in their routine attempts to lobby their colleagues who submitted the bank's estimate of its borrowing costs to the BBA. It was particularly concerned because it appeared to be "accepted culture" amongst some staff.

Both UK and US authorities were also critical of Barclays' lack of internal controls over its system of submitting information on Libor and Euribor. This, along with inadequate supervision of trading desks, "allowed this conduct to occur", US regulators said.

Barclays' record fine for rigging Libor interest rates should be a "watershed" moment for the wider financial industry to clean up its act and restore public trust, The FSA said . The Libor penalty and last week's news that Britain's top four banks mis-sold interest rate swaps to small businesses compounds the stereotype of a sector that cannot be trusted and left to its own devices, said Tracey McDermott, acting head of enforcement at the Financial Services Authority.

"Instead, it sells products to the wrong people at the wrong time in the wrong way. To change things in the future, to restore that trust and confidence... requires tough action from the regulator but it's not our job alone," McDermott told an FSA conference.

"Perhaps the reaction to the penalty imposed last week on Barclays will be a watershed moment, the point when the industry realizes that it also has to rise to the challenge and to recognize that things have to change," she said.

McDermott said "wave after wave of mis-selling scandals" meant the role of regulators must be rethought and warned firms which fail to improve despite repeated requests.

"We need to have a low tolerance for firms that constantly bump along the bottom. We will be much more prepared to intervene and limit business," McDermott said.

All these examples demonstrate that there is an ingrained culture in Barclays Bank to ignore the law, both civil and criminal, where it doesn't suit Barclays' ambitions or agenda. These examples are evidence of a wholesale culture of criminogenisis, or a potential to engage in criminal conduct. It has gone on for so long that many Barclays' employees are simply unaware when they are doing right and when they are doing wrong. They have developed their careers in an institutionalised atmosphere of 'anomie', or a state of avoidance of all conventional norms of honest conduct.

It is too late now to reverse this trend because it is too entrenched. The only way that this pariah bank can be turned round is for a series of targeted prosecutions to be brought against some of the more elevated serial offenders, and harsh penalties imposed upon conviction.

A new board must be employed, and the existing members dismissed without compensation. They have presided over this culture of condoned criminality for too long, and it would be a travesty of justice if they were allowed to remain in post, picking up their inflated compensation.

The new board must start by requiring all employees to re-apply for their own jobs, so that the more egregious and recalcitrant offenders can be rooted out. A full programme of ethical reconstruction must be applied, and not one provided by the usual suspects in the big consulting firms

The retail and the casino arms of the bank must be rigidly segregated. Then, and only then can Barclays be permitted to continue doing any financial business again. The only alternative is to close it down by removing its banking licences, on the grounds that it is too dishonest to be allowed to continue in business. We must be prepared to confront the full implications of such an event, but banks can no longer be permitted to believe that they are a protected species, and too big to fail. When the Government is willing and ready to show that no financial institution is above the law, we will begin to see the much desired sea-change in attitudes towards banking that this country so badly needs.

The Vegas Trust - The Fraud that had everything! Part One.

In the 1980s under Margaret Thatcher's attempts to open up the London market to the beneficial influence of international capital flows, London became the fraud capital of Europe. Every dodgy con-man, snake-oil salesman, share pusher, bunko merchant, Ponzi scheme promoter, and even US mafia-connected securities dealers, boiler room operators and 'paper hangers' flooded into London to take advantage of the big financial free-for-all that Mrs Thatcher's philosophies regarding free markets would unleash.

The Vegas Trust case for me probably encapsulated everything that was wrong with the entire financial sector and those who regulated it, operated it, legally advised it, judged it, and yes, who policed it, sadly.

It involved straightforward criminals, dubious investment promoters, bent solicitors, amoral barristers, pathetic DTI officials, cowardly senior City bankers, a bunch of terrified solicitors in a City law firm, some arrogant and incompetent middle-ranking police officers, off-shore companies and trusts, and one of the biggest perversions of the course of English justice that I had ever personally witnessed. After the Vegas Trust case, I no longer believed that literally anything was sacrosanct, and that everything could be bought and sold, including the highest levels of the English legal and judicial system.

The case involved a dodgy Dutch 'investment promoter', a British metals broker and a bent solicitor. They came up with a scheme to solicit investments from public investors in a pooled commodity futures trust fund, which they christened 'The Vegas Trust' and which they would ostensibly trade and make a profit, which they would then distribute among the investors.

Where was the harm in that you might well ask?

Well, under the law as it then stood, The Prevention of Fraud (Investments) Act 1958, (PFI) prohibited such investment schemes, on the grounds that they were simply too risky for ordinary investors to understand and appreciate the risks involved, so they were outlawed.

The law also outlawed the possession or the circulation of any document soliciting any such investment, the view being that if the existence and possession of such documents were prohibited, then they couldn't be sent to unwary investors.

It is one the biggest ironies to me that in its time, the PFI Act was roundly denounced at the time of the introduction of the Financial Services Act, but with the benefit of a lot of very cynical hindsight, I now realise that it was a really rather sensible and simple law, and should have been left well alone.

The law did permit the sending of such circulars to certain legally-defined professional investment advisers, under the proviso that the person doing the sending would themselves be authorised to deal in securities by their possession of a licence granted by the DTI.

In or about late 1983, what this bunch of adventurers decided to do was to create a document which they hoped would somehow allow them to get their investment proposals out into the public domain, but appearing all the while to possess a spurious claim to be complying with the law. It was a transparent attempt to circumvent the criminal law, it was deliberate, it was blatant, it was dishonest, and it was typical of the kind of investment scam of which so many were then proliferating in London.

The metals broker, was really a patsy in this fraud, albeit he knew exactly what was intended to happen and what was going to go on. The real fingers in the pie were the Dutchman and his close friend the solicitor, a flamboyant man who was a partner in a City law firm in Fleet Street. It was he who organised and set up the relevant off-shore constructions designed to give the scheme an air of sophistication, while crucially assisting in providing a major barrier to any meaningful investigations that might take place. The money would be held in a Trust called the Vegas Trust, whose head offices were claimed to be in Panama, although it was really registered in Guernsey, one of the many off-shore tax havens which sheltered a wide variety of dodgy investment promoters in those days. The company created to administer the affairs of the Trust was named the Baraquesa Finance Corporation, and registered in Panama.

It was the solicitor who brought in a seedy former fund manager to be the Managing Director of the Baraquesa Finance Corporation, and who also introduced a near bankrupt Peer of the Realm as Chairman. The intention was to pay this hapless man a fee of £60,000 per annum for the use of his name and title, a sum which he was pathetically grateful to accept.

Together, these characters drew up a circular which contained the usual inflated puffery and investment blurb, and stating that the Trust funds would be audited every 6 months by a leading City accounting firm, just to give an added air of authenticity.

The plan then was to seal the document inside a plain brown envelope, with the following words printed in red on the front;

"... WARNING - Opening this envelope could be a criminal offence if you are not authorised to do so. Please pass this envelope unopened to your professional adviser..."

This envelope was then placed inside a second larger envelope which was then addressed to a list of names they had acquired from a City listing service of City Liverymen.

Before sending off these letters however, the solicitor sought advice from Leading Counsel as to the legitimacy of such an action. This was an extremely clever move and it nearly had the desired effect, and had the letter not landed on the doormats of certain august City figures, it might have succeeded.

He chose a very eminent and senior commercial silk who would later go on to achieve highly elevated status indeed in the English legal firmament. They made an early appointment with this man at his chambers in the Temple and they took the letters down to show hm.

What follows was admitted to me by the Metals Broker when he was later arrested. He stated that the eminent barrister made the following observations. When asked to opine on the legality or otherwise of the proposed letters he said;

"... The law in this regard is a grey area. While what you propose may indeed be in breach of the Act, the chances of the DTI doing anything about it, even if they were to find out about it, is highly unlikely. If I were you, I would give it a try and see how you get on...’

I will return to this point later.

The letters were posted, and I want you to imagine the scenario. A City liveryman, who could have been and often was a non-City practitioner, being doctors, academics, accountants and other assorted members of the Great and the Good, is having breakfast. The letter lands on his mat. He opens it, only to be confronted with the proviso not to open the letter. I can imagine that hundreds of men nearly burst a blood vessel tearing open the second envelope to read its contents, and it had the desired effect, because a lot of people did send in money to open an account in this entirely illegal enterprise.

Unfortunately for the Vegas Trust promoters, two of the letters landed on the mats of very senior City bankers indeed, the then Chairman of Kleinwort Benson Ltd, and the Director General of the Council for the Securities Industry, who immediately complained to Cecil Parkinson, the then Minister at the DTI about the marketing practices of ‘The Vegas Trust', as being the very kind of dodgy scams the City was trying to stamp out! The letters were immediately passed to the DTI Investigations Branch for action.

The DTI Officials were perturbed by this document. They couldn't do what they would have done in most cases, and quietly ignored it, hoping it would quietly fail after a few months and after a few stupid punters had been fleeced. This had been referred to them by their own Secretary of State who was demanding action.

On the other hand, this case contained certain dangerous ramifications, because it looked like the villains had come up with a rather novel wheeze, and there was significant unwillingness to take on the investigation for fear that a prosecution might possibly fail, which would adversely influence the promotion prospects of the officer recommending the prosecutorial course of action! In the file which I was later allowed to inspect, the following comment appeared.

"...‘While the persons involved are obviously in breach of the PFI Act 1958, it is clear that they have identified a novel way of offending against the Act. If a prosecution was brought which was subsequently unsuccessful, the officer concerned could be deemed to have made an error of judgment which might adversely affect their future career...

Let us therefore pass this matter to the police for further action. If they are successful, this Department will be deemed to have made a successful judgment. If they are unsuccessful, any criticism will attach to their handling of the case, and will not impact upon this Department..."

So the ever-vigilant heroic regulators of the DTI came up with their own clever scheme. They would pass the papers to the Fraud Squad to investigate. In their covering referral letter, they used the excuse that '... ‘....however, though Vegas’s head office is, according to its literature, in Panama, it is not a company registered there. Without proof of incorporation the Department cannot exercise its investigatory powers...and your assistance is sought...’

It took me one visit to the offices of the Vegas Trust to ascertain that the Trust was registered in Guernsey, so well within the investigatory remit of the DTI. How did I know? It was written in gold on the window of the offices! However, the DTI regulators were not well known for getting out of their offices to conduct such complex investigations, so the case was now firmly in the hands of the Fraud Squad.

Search warrants were sought and executed, and all the company's papers and documents taken back to the Fraud Squad. The Dutchman went on the run to Holland and never returned. The solicitor wrote to all the investors informing them that the precipitate actions of the police meant that the company had to cease trading and all their investments should now be considered as lost. Threats of writs for damages were received by me at the Yard, and I began to investigate the dealings of the Vegas Trust.

The case had already acquired the status of what our US detective colleagues would have called 'High JIngo', which meant that from now on, it was going to have dirty politics written all over it!

I had already learned that a corrupt solicitor can cause difficulties out of all proportion for investigations of fraud cases. I had experienced at first hand the brick wall thrown up by the use of offshore tax havens to criminal investigators. I had witnessed, yet again, the spinelessness of the regulators in the DTI, and I had seen how a commercial barrister would be willing to give any legal advice which his client wanted to hear, for a fat fee, naturally. Above all, I was beginning to learn that London, as a financial centre, was wide open for every kind of fraud going, and that all the different branches of the professional services providers were perfectly happy to play their part in a thoroughly dishonest enterprise, just by turning a blind eye to the possible consequences of their actions.

In the next posting I shall deal with the investigation and its impacts.

David Langford - Cutting the incompetent Regulators down to size!

One of the constantly recurring leitmotifs that mark out most major white-collar criminal activities is the negligence and more often, the incompetence of the regulators put in place to oversee the relevant market sector. Prior to the introduction of the regime of statutory self-regulation introduced in the original Financial Services Act 1986, the financial market in the UK was regulated by the Department of Trade and Industry (DTI), later christened the Department of Timidity and Incompetence. The civil servants who comprised this huge Department were very much imbued with the need to focus on 'Policy', which all civil servants love, while being remarkably unwilling to get involved with the more basic elements of dealing with the criminal elements of their brief.

Not all DTI officials should be included in this group. One, a brilliant investigator called Chris Cooke sought to make a significant difference, but he was a man on his own, and I never felt that his robust methods were fully appreciated by his departmental colleagues.

In the case of David Langford, the incompetence and yes, arrogance of the DTI was laid bare, and for once, the good guys got the right result in this case. Its outcome however, would have ramifications in years to come which did not bode so well for financial losers in later criminal cases.

David Langford was what was called a financial intermediary, and he operated as a financial adviser by dint of his possession of a licence to deal in securities, issued by the DTI. In order to qualify for such a licence, Langford had to show that he was a 'fit and proper' person to handle other people's money, and he had to be regularly assessed by the DTI officials who were part of the Licensing Branch, to ensure his continued suitability for the licence.

I shall not dwell on Langford's business tactics, as they were remarkably mundane, and ironically, did not have a huge bearing on the case or its outcome, except in the one area of his lack of capital adequacy.

More financial intermediaries, and financial businesses, including banks get themselves into trouble and slip down into criminality because their capital adequacy is insufficient for their business needs. They start 'borrowing' from their client accounts, always firmly intending to pay back the money at some stage. I do believe that when such a practice begins, most practitioners genuinely do believe they will pay it back, and that they are only 'borrowing' the money in the short term, to tide them over a temporary difficulty in cash-flow.

This is where the regulators need to be punctilious in ensuring that the capital adequacy levels are maintained scrupulously, and not merely in a series of dubious accounting practices designed to give an impression of solvency whereas the reality is that the firm is going down the tubes!

Langford offered a form of investment strategy to people with limited means who needed to earn capital for their living needs. One technique was called 'Bond Washing'! He would offer to sell Local Authority Bonds ( normally a very secure form of investment) to clients, but instead of holding these investments for a full 12 months, when they would pay income tax on the full amount of the income from the bond, he would sell them after 6 months, and roll the proceeds over into a new bond. The profits from the half-year investment would only attract tax at capital gains rates, and this legitimate form of tax avoidance, made the practice very attractive to small investors.

What Langford's clients did not know however, was that he was already in deep financial trouble arising from the financial collapse of an earlier company, which had gone down owing significant sums of money to investors, and some very shady City spivs as well! He was already under investigation by another Department of the DTI regarding the collapse of this company.

The full facts of this sorry case can be read in my earlier book 'Fraud In The City - Too Good To Be True', but the most important element in this brief synopsis is that Langford had early on, admitted to a DTI investigation, stealing money from an existing client of his present company, to reimburse a former client in his earlier collapsed company. He admitted the theft during his interviews with DTI officials, but for some unknown reason the investigation department of the DTI did not pass this information on to the Licensing Branch of the DTI , and they renewed Langford's licence permitting him to carry on trading. In this latter period, Langford solicited a considerable amount of new investor's money, all of which was unlawfully diverted and used to defray the debts owed to yet further investors. He was robbing Peter to pay Paul at an alarming rate.

All in all the DTI investigated Langford's two companies from October 1980 until February 1983, generating a voluminous amount of correspondence, a vast edifice of buck-passing, hand-washing, denials of responsibility, assertions of the need to protect Langford's civil rights to possess a licence to deal in securities, but at no stage did anyone bother to concern themselves with the interests of the investors from whom Langford was busy stealing even more money.

Later, an official of the DTI would assert that the information about the thefts could not be used in the departmental investigation because it had was privileged information and should not have been disclosed. While the relevant officials of the DTI argued about this minutiae and how many angels could dance on the head of a pin, Langford finally burned the entire contents of his office in a skip behind his premises, and closing the building, went on the run!

I wasn't unduly worried about Langford's disappearance, although even that aspect is a whole story in itself, I always knew he would come back to notice again, so having posted him as a wanted man, I set about re-constructing the books of his business. It took me five and a half months in total, (we didn't have computers in those days), painstakingly identifying every payment, every security, every client, every client's individual funds, until I knew Langford better than I knew myself.

I was forced to undertake the enquiry on my own and without any help from the DTI, even though they had all the relevant files and papers. They claimed that these documents were privileged and that they could not be shared with Police because that would completely countermand the element of trust that company directors were permitted to expect in their dealings with the DTI. Throughout, they refused to assist me in any way, even though they must have known that their documents would have been of untold value to me.

I would later learn that their refusal was an attempt to cover up their own ineptitude and incompetence, because once these documents became police evidence, they would at some stage see the light of day in a Court of Law. So they turned their backs on my requests and ignored me. When I tried to suggest that they might be standing in the way of my getting recompense for the losers, they accused me, sneeringly, of engaging in petty 'consumerist' thinking. It was not their job to be concerned with the interests of investors, they told me, all investors needed to operate on the basis of 'caveat emptor', and they were on their own. If they lost money with Langford, that was their own stupid fault!

What had truly scandalised me were the losses caused to the latest group of investors who were solicited after the second re-granting of the licence to deal. The vast majority were men and women who had invested their life's savings, or their pension funds in Langford's schemes, believing that his possession of a licence issued by the Government meant that he was an utterly trustworthy person to handle their money. The schemes he offered were not madcap speculation, but money deposited in the bonds of municipalities, as safe, literally, as the houses they built. What they didn't know was that as soon as their money hit Langford's bank account, it was paid out to other shadowy figures to whom he owed a great deal more money arising out of some seriously speculative share dealings he had undertaken on behalf of a group of crooked merchant bankers and financiers, who were putting immense pressure on Langford to reimburse their losses.

Two of the losers and my witnesses, were elderly Welsh miners from South Wales, who had invested some significant part of their savings in Langford's schemes. They had written to the relevant Parliamentary Under Secretary of State for Corporate and Consumer Affairs, asking for official assistance in getting an investigation and recompense for their losses. The answer they received was that having reviewed the facts of the case, the Department's actions were considered to be reasonable throughout, and no assistance could be offered or would be forthcoming.

I will admit that these men, so close in background, culture, geography, and dangerous occupation to members of my own family, brought out an almost unreasoning anger in me for the attitude of the civil servants towards them and their losses. I decided that If I was going to be accused of 'consumerist' thinking, then I would do it properly.

I advised them to seek the assistance of their own M.P, and having later visited him in the House of Commons I gave him all the facts in my possession, and he then agreed, at my request, to refer the whole case to the Parliamentary Commissioner for Administration, more commonly known as the Ombudsman.

This excellent gentleman made a full enquiry into the affair, the DTI were forced to hand over all their files and papers which had been denied to me, and his report contained a series of bombshells which had never before exploded underneath the complacent DTI with such devastating force.

He found their conduct 'surprising', other actions were described as 'extraordinary', he criticised the whole Department for 'their poor performance here and for their apparent lack of regard for the protection of the public interest'. He found other failings which he believed 'merited criticism', and he considered their overall handling of matters to be 'ineffective and ill-judged'. His most telling phrase was saved for the end when he opined that '...the Department showed a lamentable lack of concern for the interests of those members of the public who had a right to assume that the DTI's licensing system offered them a reasonable measure of protection for their investments...'

David Langford re-appeared one day as I had always predicted, and he was sentenced at the Old Bailey to one years' imprisonment for various offences arising out of his management of his companies.

As a result of the Ombudsman's report. all the investors in Langford's companies were reimbursed their losses in full, together with full interest. The report had the effect of a nuclear explosion inside the DTI. I don't believe any senior civil servants' career was damaged by it unduly, no-one, as far as I know was ever disciplined for their part in this scandalous case, but it had long-lasting repercussions.

The decision in Langford's case would later be used to reimburse all the victims in the Barlow Clowes investment fraud case, and it was the catalyst for the inclusion of certain elements of the Financial Services Act 1986, which made certain that no further such cases which occurred after the Act came into force, would be allowed to be referred to the Ombudsman, but would have to take their chances under the Investors' Compensation Scheme, and even more scandalously, regulator incompetence would no longer be a reason for recompense!

For me personally, the case earned me the lasting enmity of certain senior civil servants inside the DTI, elements of which would re-appear later in my career when I dealt with another appalling DTI handling of yet another investment fraud case, of which more later. As a mere detective, I had, for the very first time, managed to shake the very foundations of arrogance and privilege which these complacent civil servants considered to be nothing more than their due, and in so doing had exposed them to public ridicule and even worse, the public exposure of their incompetence.

The case taught me another series of important lessons about the white collar criminal dimension. It taught me that no matter how elevated the public servant, he or she will fight like a cornered alley cat if their cloistered privileged existence becomes threatened. It taught me that in order to cover up their ineptitude, they will go to any lengths to deny others access to documents or papers needed to bring criminals to justice. It taught me that no regulator has the monopoly when it comes to active professional knowledge, and that they will always seek to lay claim to greater wisdom and understanding, but will never be willing to share it with other agencies. It taught me that Ministers and Parliamentarians are in so many cases, very badly served by their civil servants, but they will always defer to them and protect them rather than expose them. It taught me that civil servants actively despise the police, viewing them as a bunch of 'Plods', and will never share their information unless it is absolutely forced out of them, and it taught me that all these problems are widely exploited by white collar criminals, because they know just how ineffective the civil servants are, and they are not frightened of them!

I also learned that civil servants are not predisposed to undertake criminal investigations, despite their possession of special powers to do so in certain cases. They do not like conducting criminal investigations, they don't like dealing with criminals, and they are no good at it. They feel it puts them on a par with mere 'Plods', which they so resent, and whom they so despise. The jury system to them is a dangerous lottery and they don't like the odds of possibly losing an important case, and being subsequently criticised in the department or in the press, because it might have bad influences on career development. (We shall see this element re-appear in the Vegas Trust case). So, they will avoid bringing criminal cases wherever possible, unless absolutely forced so to do.

Their successors live on in the FSA today, and in reality, very little has changed, despite the changes in the law and the processes. Many elements of financial crime enforcement may change, but the culture of general ineptitude and a lack of willingness to use the criminal powers entrusted to them, still lives on today, the Department of Timidity and Incompetence has become the Frankly Supine Authority. They may be changing the names of the relevant Departments, but that is only to protect the guilty!

Michael Doxford - The well-heeled tax evaders' best friend!

In 1981, the Commodity Broking firm of M.L.Doxford Ltd went into liquidation. Nothing very unusual about that, you might think,, and indeed, to me it was just another small story in the financial press. Little did I know at the time, but this case would be my introduction to City White Collar Crime at the highest level.

One of the first actions undertaken by the incoming Conservative Government under Margaret Thatcher in 1979 was the repeal of Exchange Control regulations. As a result, this put pressure on the company of Michael Doxford Ltd, which was a futures-trading company and which, as a result was collapsing in 1980,and finally went down early in 1981. M.L.Doxford Ltd was the brainchild of a minor ‘aristo’, Michael Doxford, who together with two friends, traded soft commodities in the 1960’s and 1970’s, when it was fashionable for such men to have a job in the racier circles of the financial milieu.

The case was something of a minor embarrassment to the newly elected Tory Government, because Michael Doxford was a well-known socialite and minor playboy, and his downfall from his well-heeled lifestyle was seen by the Labour benches in Parliament as typical of the kind of spiv element being increasingly seen in the City. Margaret Thatcher immediately called in the Metropolitan Police to bring an end to further embarrassing questions in the House of Commons, because the matter could now be defined as being sub-judice as the police were investigating.

I was called on a Friday evening in my detective's room in a busy South East London Police Station, and told by my Divisional Commander that I was being posted to the Fraud Squad the following Monday to work on this case. The Commander said '...It's all about Tin, Lead, Zinc, Copper, Wheat, Sugar and Coffee as far as I can make out. Doesn't really sound like real police work to me, lad, but you've got the whole week-end to mug up on it...'

The following Monday, I was helping to search Doxford's deserted offices in St James Street. The place was in a shambles with papers everywhere. The first job was simply to tidy up the papers and put them in some kind of semblance of good order.

What became clear to us was that first we had to learn the arcane language of the commodities markets before we could even begin to understand the contents of the account statements, contract notes, monthly reconciliation statements et al that we were finding in every nook and cranny. I was lucky because I knew a few old contacts from University (I was the sole graduate in the office in those days), who had gone into the City and they were able to 'educate' me in this new language.

The first thing that became clear to me was that I had got my sense of policing priorities completely about-face. Here I had been, chasing young men armed with sawn-off shotguns who robbed Post Offices and Security Vans around South-East London, but whose criminal take rarely amounted to more than a few thousand pounds if they were lucky. I was now investigating the affairs of men who thought nothing of spending thousands of pounds just entertaining their clients at the race track or a day's power-boat racing.

I was experiencing the same absence of recognition that the City regulators , Courts, Judges, Civil Servants and Parliamentarians  suffered from. At first, I couldn't believe that these well-brought up gentlemen would have possiby committed bare-faced crimes, so I didn't start off by treating the crime possibility too seriously. Perhaps my Commander had been right after all, maybe this wasn't real police work! It took me some time before it dawned on me that this was where the real crime was going on, not in Peckham or Brixton!

Because there was a real crime being evidenced here, it just took us some time to spot it, and it wasn't where we expected it to be.

What we did not and could not know at first was that Doxford had quickly obtained something of a reputation for being able to launder the contents of the deposit accounts of his wealthy socialite contacts. Doxford and his friends had been operating at a time when the Labour Government had been imposing punitive wealth taxes on the rich, in an attempt to 'squeeze them until the pips squeaked'. Many wealthy individuals were desperate to get their wealth out of the reach of Dennis Healy, but at that time the UK had Exchange Control Regulations which prohibited the export of UK capital of more than about £50 at any one time.

Doxford was able to show them a way to get round this irritating law and this was largely Doxford's day-to-day business and he was making a great deal of money from it.

Using the existence of a contact ( a failed gambler who had been drummed out of the UK for not being able to pay his gambling debts) living in Bahrain, Doxford would create false discretionary trading accounts for non-existent Arab sheiks, who would apparently deposit large sums of money with him, ostensibly to trade futures. The money would in fact come from the wealthy British tax evader, but as there was no means of showing the provenance of the entry of the money except by its appearance in the bank account of the trading company, no-one was any the wiser. The relevant paperwork would be telexed to Doxford’s London office from Bahrain, giving the impression of being the instructions from a genuinely wealthy Arab.

At the same time, the real UK client would also have a discretionary trading account opened. All the relevant paperwork would be available for inspection if needed.

Doxford would then create a false paper flow of purported trades being conducted on the respective London futures’ markets, all of which would result in the real UK ‘client’ suffering a trading loss. The profits from trades would then be booked to the Arab client's account. When the UK client's money had been satisfactorily passed to the Arab's account, this in turn would be the signal for the fictitious Arab client to send another telex, requesting that the trading account be closed, and the balance remitted to his bank account in Zug, Zurich, Geneva or wherever!

Doxford would then engineer the relevant paperwork to close the account, and would place all the trading statements and account documentation into a file, together with the respective telexes, and he would then make an appointment with an official in charge of the Exchange Control department within the Bank of England, and having shown him the evidence of the file, (usually over a lengthy and alcoholic lunch) would request permission to remit the balance of the trading account to the relevant bank account in Switzerland.

As Exchange Controls did not apply to foreign citizens, and in particular, wealthy Arabs, there was no bar to their funds being remitted anywhere in the world, with the permission of the Bank of England. As there was no way in which the bank official could say whether or not the trading accounts were genuine, and because the paperwork would always provide an accurate and recognisable audit trail, permission was inevitably granted for the export of the relevant sums of money, which would then be paid out of Doxford’s trading accounts and remitted to the Swiss bank.

As the Bank official would not ever suspect Doxford of behaving in a dishonest fashion, no suspicions were ever raised as to the legitimacy of these trading accounts. Doxford was well known to act for lots of wealthy Arab clients, so any such request was not surprising to the Bank officer.

In this example, the documents were entirely false, no trading was ever undertaken on behalf of the client at all. However, because all trades on futures exchanges are undertaken on a ‘market to principal’ basis, all brokers being principal to their own contracts, there was no way of showing whether the documents provided for each client were false or true. It would only need Doxford to have to undertake a small number of legitimate trades for the purposes of his own trading accounts, which could be attested to and which could be identified by the clearing broker, for him to be able to allocate such trades to any client he wished.

In many such cases, our investigations uncovered examples of trades being allocated, on paper, to discretionary clients, but in circumstances where the legitimate trades were being re-allocated, many times over. In other words, the broker was buying five lots of September sugar, for which he would receive a genuine contract note, but he would be re-allocating that single contract of five lots, to as many customers as he cared. As long as the customer lost at the end of the day, so that he did not ask for any money, the broker was unlikely to be discovered. At the same time, as long as two clients of the same broker did not compare trading notes, this thoroughly dishonest method of trading would remain undetected.

It was only after we had spent some considerable time unravelling and analysing the trade documentation that the similarity and the 'symmetry' of the profits and losses became obvious, and we began to focus on these apparent anomalies.

Our life was made easier when the wife of the failed gambler in Bahrain, was thwarted in a divorce application for additional maintenance from her former husband, and she came to the Fraud Squad to confess her husband's role in this scam. Truly is it said, 'hell hath no fury like a woman scorned!'

The Bahrain police were then able to confirm that no real Bahraini citizens existed with the names and at the addresses claimed, and after that we were able to quickly wind up the investigation.

In the course of so doing, we then focused on the actions of the wealthy UK citizens, who were now all deeply implicated in a massive conspiracy to cheat and defraud the Inland Revenue. Many of our interviews were conducted in some of the leading drawing rooms in Mayfair and Belgravia, or in ancient country seats deep in the heart of the Cotswolds or the Mendips. If we had difficulty finding addresses or telephone numbers we only had to look in Debretts Peerage or the Almanach de Gotha to find our witnesses.

A long list of shame-faced aristos and debs delights were interviewed and their statements taken. All of them admitted that they knew that their actions were criminal because they were defrauding the Inland Revenue. The company directors who had been engaged in fraudulent trading, coupled with a range of conspiracies to defraud the Revenue, declined to answer any questions on the advice of their lawyers.

The papers were then all passed to the Director of Public Prosecutions to determine what charges should be brought against the company, the directors, and the UK tax fraudsters. Eventually, there was a lengthy conference with the DPP's officers, where the police were informed that the decision had been taken at the highest levels that it was not in the public interest to prosecute anyone involved in the case!

No-one stood in the dock as a result of this lengthy investigation, and the company's affairs were wound up leaving a welter of bad debts.

My colleagues and I were astonished and incredibly angry. It was obvious that Doxford and his co-directors could not be prosecuted without the evidence of the well-connected UK tax evaders, and it was clear that the Establishment did not want to drag these eminent and socially-elevated people through the Courts. So the whole thing was dropped and covered up.

I was incoherent with rage and fury. Coming from a Welsh mining and small farming background, and aware of the near-poverty that my mining grandparents had been forced to endure during times of great hardship, I felt that what was being allowed to happen was completely unacceptable. The rich and powerful were being allowed to get away with their crimes because of their power and their associations, and it seemed to me to be utterly wrong. It seemed wrong then and I still think it was wrong today.

I had started my education in the understanding of the role of white collar crime in the financial sector. I had learned that even if a man comes from an elevated social status, he will behave like an any ordinary criminal when the opportunity arises. Such men are capable of committing the most basic of crimes, regardless of background or class. I learned that he will lie, try to cover up evidence, and use every dirty tactic at his disposal to avoid being prosecuted. I had learned that the crimes of the powerful are the same to  investigate, but are much harder to achieve prosecutions for, because they will always reach out and use their influence to avoid being charged with crimes. I learned that the white collar criminal fears the thought of being charged with a criminal offence, because it means social oblivion and commercial ostracism, and that is why they will use every privilege at their disposal to achieve their ends of being excused the need to stand in the dock. Above all, it taught me that such people are a 'protected species' which is why, many years later when a main board Barclays director used those very words to me to explain why he and his ilk would never be prosecuted, I knew he was telling the truth!

I also learned that public officials and regulators will not necessarily look beyond the face value of documents provided to them, they will not seek to look behind the purported story. I learned that regulators did not want to do anything that might be seen to be rocking the boat, and that in many cases, their inaction is really incompetence and laziness.

I later challenged the DPP's officer that his office had been subjected to significant political interference in the Doxford case. He laughed and said to me;

'...We don't get political interference in this office, we get guidance as to the pubic interest...'