• Pension Liberation & Pensions Regulator Investigations

    The Pensions Regulator (TPR) and enforcement agencies including the Serious Fraud Office (SFO), Financial Conduct Authority (FCA) and HM Revenue and Customs (HMRC) are actively pursuing directors, trustees and scheme sponsors suspected of criminal activity in a coordinated approach. How you respond at the early stages of an investigation can have a striking effect on the outcome.

Investigations into pension liberation and other pension frauds are extremely complex and often involve a coordinated approach involving several enforcement agencies.

Allegations of widespread fraud and criminal activities surrounding pension schemes saw the formation of ‘Project Bloom’. Chaired by The Pensions Regulator, ‘Project Bloom’ is a multi-agency group which includes the SFO, FCA, HMRC, the Insolvency Service and local police forces to coordinate government, law enforcement and regulatory agencies’ response to alleged pension frauds.

Our Lawyers

Our lawyers can help untangle these complex and interlinked investigations. Our focus in on you and winning your case. We understand the intricacies of each enforcement agency and have successfully represented company directors, pension trustees, financial advisers and other professional individuals in high-profile pension liberation and fraud cases. We are currently defending the first criminal investigation brought by The Pensions Regulator.

Our Approach

While criminal fraud investigations often start suddenly with dawn raids, arrests and interviews under caution, the genesis of a pension investigation can be much more subtle.

Clients may face initial questions from their regulatory body long before they are aware of possible criminal action being taken. The provision of information by a client at that early stage, often under powers of compulsion, can have a significant impact on the development of the investigation.

Understanding the flow of information and evidence between agencies and the powers and constraints of each investigative body is vital. Our reputation for challenging the demands of regulatory and enforcement agencies is unrivalled and we regularly advise on abuse of the prosecution process, legality of orders and judicial reviews of decisions made by public bodies.

We have links to specialist experts in the fields of computer forensics and asset tracing to put together a highly skilled, multidisciplinary team to investigate and defend your case.

Our Work

  • Acting for an individual who is a focus of TPR’s first criminal investigation. Our client is said to have created a fraudulent pension scheme in which member funds were invested. The allegation is that the investment was a sham which could not have generated sufficient yields to give a return for the investors
  • Advising a prominent businessman who is under investigation by the SFO in respect of his suspected involvement in an alleged pension fraud. The investigation is multi-jurisdictional and the lead case in a coordinated operation involving the FCA, HMRC, and led by the SFO under ‘Project Bloom’
  • Advised four directors under investigation by HMRC in respect of “Pension Carousel Fraud” and “Pension Liberation”. After making substantial written representations, no further action was taken against our clients, although others were prosecuted. The case against the others eventually collapsed at trial
  • Representing individuals in respect of both Supervision and Enforcement investigations by the FCA arising from advice given in relation to the transfer of defined benefit pension schemes to overseas Qualifying Recognised Overseas Pension Schemes (QROPS)
  • Successfully represented a defendant in a high-profile pension liberation and fraudulent claim of tax relief at source on allegedly sham pension contributions. The court ruled that the client, a director of the companies running one of the pension schemes in question, had no case to answer. The Crown appealed that decision to the Court of Appeal which upheld his acquittal and issued guidance on the meaning of “sham” in the context of pension schemes
  • Represented four directors of a pension trustee company in a multi-agency investigation into alleged pension liberation fraud. Regulators included the FCA, HMRC and TPR. All allegations were withdrawn at the end of a three-year investigation
  • Representing an independent financial adviser and company director accused of operating a fraudulent pension
  • Representing a pension trustee investigated for dissipating funds where a third-party firm had conducted the sales operation and many investments were legitimate unregulated investments. We worked to safeguard our client’s position in the face of both criminal and regulatory agency investigations


Anthony Barnfather

Founder and Director

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Simon Morgan


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For initial consultation please call us to make an appointment on 0333 202 6445, or if you prefer contact us online


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