On 1st October, the investigative website Bellingcat published an article reflecting on its 2017 report (with Transparency International), “Offshore in the UK”, which revealed the use of Scottish Limited Partnerships (SLP) and their use as a mechanism in global money laundering scandals and a range of illicit activities.  Then in 2017, SLP became obliged to register their Person of Significant Control at Companies House, and the boom in registrations ended and currently, SLP registrations are at their lowest level since 2010.  Nevertheless, the article says, a lack of regulation allowed thousands of opaquely owned partnerships, typically with no tangible link to the UK, to flourish over a 7-year period, and despite the apparent decline stories surrounding SLP and their misuse continue.  The article reports on research into existing SLP, with Bellingcat examining the filings for 14,658 SLP and the groups of presenters who have been responsible for bulk registering thousands of anonymously owned partnerships between January 2015 and July 2019.  It is said to have found SLP trading in high-risk money laundering areas, operating unregulated trading and gambling websites, a large proportion of identifiable SLP in business as trade intermediaries (which is a high-risk sector for trade misinvoicing), SLP appearing in the Ukrainian criminal courts, generic websites with no clear details of their trading activities (possibly set up to bypass money laundering checks), SLP for sale online as shelf companies, SLP involved in political lobbying, and others more directly involved in large-scale criminal activity.  It found that the most prolific controlling partners of SLP are also active elsewhere in the UK company registry, typically as partners of LLP.

The report can be found at –


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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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