Investigative Support and Evidence Discovery for UK Regulator

Traditional old style UK red phone boxes in London


A UK regulator received a request from an Eastern European financial entity for a license to operate in the UK. The regulator was aware of several media allegations against the applicant that suggested association with a criminal network involved in, inter alia, money laundering, VAT fraud, tender rigging and intimidation. The regulator retained Orbis for several months to undertake a multi-phase investigation to explore these allegations; to obtain probative evidence to support their decision-making on the application; and subsequently to support the formulation of a legal defence for refusing the application in anticipation of an appeal for judicial review.


In the first phase of intelligence gathering, Orbis undertook a forensic analysis of the complex and largely opaque accounting and corporate structure surrounding the financial entity, which comprised in excess of 200 companies across diverse jurisdictions. Through this process we were able to map out and demonstrate wholesale breaches of the national and European regulatory environment by entities legally associated with the applicant. Concurrently Orbis deployed several associates to the region in which the applicant company was active, to conduct discreet source enquiries across several levels of government, industry and regional grey market networks to verify the allegations in the public domain. In preparation for a potential court hearing, Orbis identified and prepared an international panel of expert witnesses willing to testify in court on behalf of the regulator in support of their decision, along with a body of human source and acquired documentary evidence demonstrating a degree of impropriety and a pattern of conduct by the owners of the applicant entity, which justified the client’s refusal of the license.


On the basis of intelligence gathered by Orbis, the regulator was able to refuse the application with confidence. When the applicant was made aware that the regulator was confident in their decision and that they had sufficient evidence to defend it in a tribunal setting, the applicant chose to withdraw their application and avoid the negative publicity that the case might have attracted.

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