On 1st October, investigative site Bellingcat published an update on the situation regarding Scottish Limited Partnerships (SLP).  It refers back to a Bellingcat and Transparency International UK joint report in 2017, saying that since then SLP have continued to be implicated in further scandals, including the huge Azerbaijani Laundromat – though in 2017 SLP became obliged to register their Person of Significant Control (PSC) at Companies House, and the boom in registrations ended and SLP registrations are at their lowest level since 2010.  However, it points out that we still do not have the details of the business activities of the SLP involved in the pre-2017 period, who controlled them, or who their true beneficial owners were or are.  Bellingcat now says that it has been involved in an examination of 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 – finding large numbers of SLP with controlling partners in secrecy jurisdictions, PSC disproportionately situated outside of the UK (largely in Ukraine and Russia), and thousands of SLP registered at mailbox addresses and virtual offices.  It also says it found SLP trading in high-risk money laundering areas, operating unregulated trading and gambling websites, in business as trade intermediaries (which is a high risk sector for trade misinvoicing), appearing in the Ukrainian criminal courts, involved with generic websites with no clear details of their trading activities (possibly set up to bypass money laundering checks), for sale online as shelf companies, involved in political lobbying, and others more directly involved in large-scale criminal activity.

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

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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