
When Responsibility Becomes a Hot Potato
Victims of pension fraud—often robbed of their life savings and left emotionally scarred—expect at the very least one thing from the authorities: accountability.
Instead, what they get is a game of regulatory pass-the-parcel.
As exposed through recent correspondence shared by campaigners, victims who report fraud find themselves bounced between HMRC, the Financial Conduct Authority (FCA), and the Serious Fraud Office (SFO). Each agency claims it’s the responsibility of the other. Meanwhile, the frauds continue, the schemes remain active, and the victims are left to pick up the pieces.
Three Regulators, No Accountability
The FCA tells victims that overseas pension schemes—QROPS—fall under HMRC’s remit. HMRC, in turn, refers victims to the FCA if they were misadvised. The SFO remains silent despite repeated submissions of evidence pointing to fraud and money laundering.
This is despite the existence of a Memorandum of Understanding between the FCA and HMRC, designed to enable coordinated action.
In one case, the result was devastating. A fraudster adviser—neither FCA-regulated nor qualified—transferred the member’s pension into a scheme “approved” by HMRC. When the fraud was uncovered, HMRC claimed no responsibility. So did the FCA. The Slovakian authorities—where the adviser was registered—told the member to submit a complaint in person. He’s now left with no viable route to justice.
Victims Doing the Work of Investigators
The tragic irony is that victims are doing more to expose these scandals than the regulators themselves.
Campaigners have spent years gathering evidence, challenging QROPS registrations, and contacting MPs and journalists. They’ve written repeatedly to both HMRC and the FCA. Most of the time, the replies contradict each other—or don’t come at all.
In one email, the member highlights a damning quote from the FCA:
“We have advised that QROPS fall outside our remit, and are approved by HMRC.”
Yet HMRC tells the member that he should complain to the FCA.
This is not just miscommunication. It is a systemic failure that enables fraud to flourish.
What Is at Stake
These aren’t technical oversights—they’re life-altering events. People have lost their pensions, their homes, and in some cases their health. As shown in the “Enough is Enough” march, the emotional toll on families is immense.
Many believed—reasonably—that HMRC-approved schemes were safe. That a UK-regulated financial system wouldn’t allow criminal advisers to move millions offshore unchecked. That if fraud happened, the perpetrators would be prosecuted, and regulators would step in.
Instead, they’ve found themselves gaslit, stonewalled, and in many cases, blamed.
The Urgent Need for Action
This crisis demands more than polite correspondence. It calls for systemic change.
1. An Independent Public Inquiry
As with the Post Office Horizon scandal, only an inquiry can uncover the extent of the regulatory failure and the harm caused to victims.
2. Unified Regulator Accountability
A formal roundtable—bringing together HMRC, FCA, SFO, MPs, and victims—must be convened. The era of regulatory silos must end.
3. Immediate Delisting of Sanctioned Schemes
Why are pension schemes sanctioned by the Maltese regulator still listed as “approved” by HMRC? Transparency is urgently needed.
4. Victim-Led Reform
Victims must be at the heart of shaping reform. Their experience is not a footnote—it’s the front line.
Final Word: Enough Deflection, Enough Damage
The letters, evidence, and lived experiences are clear. This is not a one-off. It is a deep-rooted structural failure, hiding in plain sight.
What happens now is a test—not only of our financial system, but of our moral one.
The victims have done more than enough. It’s time for the regulators to do their part.
Exploring HMRC’s Public Disclosures on QROPS
In light of the ongoing concerns regarding HMRC’s role in the approval and oversight of QROPS, it’s instructive to examine the department’s public communications. The WhatDoTheyKnow (WDTK) platform archives numerous Freedom of Information (FOI) requests and responses related to QROPS.
For instance, in response to a 2012 FOI request, HMRC clarified that inclusion on the QROPS list is based solely on information provided by the schemes themselves and does not constitute an endorsement or verification by HMRC. This distinction is crucial, as many victims were led to believe that HMRC’s listing implied a level of scrutiny and approval that, in practice, was absent. www.slideshare.net
Further, a 2015 FOI response highlighted that HMRC does not routinely assess the compliance of overseas schemes with UK pension rules, relying instead on the schemes’ self-certification. This self-reporting mechanism raises questions about the robustness of HMRC’s oversight, especially when considering the significant financial implications for UK pension holders.
These public disclosures underscore a systemic issue: the reliance on self-certification without rigorous verification may have inadvertently facilitated the operation of non-compliant schemes, leaving UK pensioners vulnerable.
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Ian Davis fought not just for himself, but for all of us.
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