Jersey Registered 'Citizenship' Firm Aided Jho Low's Fugitive Life For Massive Payments - SPECIAL INVESTIGATION

Jersey Registered 'Citizenship' Firm Aided Jho Low's Fugitive Life For Massive Payments - SPECIAL INVESTIGATION

Sarawak Report, in a joint investigation with the Organised Crime and Corruption Reporting Project (OCCRP), has examined how at the height of the 1MDB scandal the Malaysian fraudster Jho Low utilised a network of services accessed through a company which describes itself as the “The Global Leader in Residence and Citizenship Planning” to continue to move himself and his money around the world.

Henley & Partners Holdings Limited (H&P) is based in the Channel Islands and operates  a web of mainly off-shore compani∂aes, boasting an estimated annual revenue of $73 million dollars assisting so-called ultra high net worth individuals seeking multiple citizenships. The group has repeatedly denied it ever signed up Jho Low as a client or received ‘direct payment’ from him.

“Henley & Partners rejected Mr Jho Low as a client in 2015. This was due to the contents of an external due diligence report that made it clear that he was a second-generation PEP, having been very close to the Malaysia government of
the day, which was correctly assessed as too high risk. He therefore did not pass our on boarding procedures.
[Statement from H&P 20th Jan 2021]

However, extensive evidence reviewed by this investigation and ultimately admitted to by the company shows H&P nonetheless referred the wealthy Malaysian fugitive to an established network of close business partners in return for at least 75% of the massive fees paid by Jho Low to obtain one such citizenship.

The arm’s length operation, which appeared to distance the company from this toxic client, netted H&P at least €700,000 from Jho Low’s acquisition of Cyrpiot citizenship through a property purchase organised through Henley’s business contacts on the island. We can also demonstrate that H&P, despite denials, were involved every step of the way.

In the process Jho Low obtained not only a €5 million property and a passport for himself, but likewise purchased homes and applied for passports on behalf of several members of his inner circle who are also on the run over 1MDB. These included his brother Low Taek Szen, Loo Ai Swan (Jasmine Loo), Tan Kim Loong (Eric Tan) and girlfriend Jesselynn Chuang Teik Ying, who applied for her papers as late as May 2019, more than a year after the prosecution of Najib over 1MDB began in Malaysia.

The matter is currently at the centre of a major official enquiry in Cyprus, which has suspended its citizenship programme under legal pressure from the EU following multiple reports of corruption and bribery. Last week the Archbishop of Cyprus was questioned by the enquiry after admitting that he had dinner with Jho Low at which the fugitive pledged what turned out to be a €300,000 donation towards a theological school.

Following the meeting, the Archbishop sent letters of recommendation to the Interior Minister urging he should be granted citizenship. Archbishop Chrysostomos now says he would be willing to return the money.

In January a Henley & Partners spokesman finally conceded that their company also benefitted from the fugitive’s citizenship transactions as a result of referring him to 3rd parties, but only after we provided evidence of at least three separate invoices paid to the company in September 2015 citing services to Jho Low and totalling €700,000:

“Jho Low was never our client. We never received payment from him. We did receive commission payments from independent 3rd parties following our referral of business to them.”
[H&P Communications Director, Paddy Blewer’s final amended statement to SR/OCCRP, 22nd Jan 2021]

Full statement:

We believe that our answer in this case has already been made very clear, however your language / terminology suggests a lack of understanding of how the investment migration industry works in practice and therefore we will reiterate our answer.

You refer to Fidescorp as “it’s agent”. By this I assume you mean “H&P’s agent”? I’d be grateful if you could explain what you mean by this, because in the investment migration industry, an “agent” is the organisation or person permitted to act
on behalf of the applicant and submit an application for citizenship (or residence) by investment. It would therefore be fundamentally factually incorrect to describe Fidescorp as “its (H&P’s) agent”.

Fidescorp is involved in this transaction because Henley & Partners rejected Jho Low. He was never a client of Henley & Partners and the firm never received any funds from this client. As has been
made clear, he was referred on to an independent third party – Fidescorp.

As previously stated, Fidescorp is a business in which we have no interest (and for the avoidance of doubt, never had an interest) and with whom we have previously had an ad hoc relationship due to the nature of the investment migration industry,
in that they largely provide complementary and non-competitive services to a similar client base to Henley & Partners.

Due to long standing contracts that were then in place, but are now amended, H&P was in the position to invoice Fidescorp for commission payment for the referral. This is what the invoices were for.

Jho Low was never our client. We never received payment from him. We did receive commission payments from independent 3rd parties following our referral of business to them.

Kind regards

Explaining the company’s disassociation from Jho Low, whilst at the same time receiving the lion’s share of the fees paid by the fugitive to gain citizenship, the spokesman, Communications Director Paddy Blewer, had described “investment migration” as a “niche and complex business”:

“It is therefore entirely understandable that those from outside the industry can make honest mistakes in their analysis of how transactions are managed, who is advising and who is compensated and by whom etc.”

However, Blewer maintained it was important to understand that the company to which H&P had referred Jho Low in Cyprus, a service provider named Fides Corp, was entirely independent of themselves, “an external and independent consultant” and just one of “multiple advisors” used by H&P:

“The best way to describe the relationship with FidesCorp Limited is one of several ad hoc collaborations on shared clients. This is an independent service provider who does for the most part its own accounting, corporate service provider, handling their own applications for their own clients, and similar business. We otherwise have nothing to do with FidesCorp Limited”

“To be very clear, Jho Low was never a client of Henley & Partners. Henley & Partners was not mandated by Jho Low.

We can however understand a level of confusion from outside observers as to the nature of the relationship. It can be explained as follows:

  1. Jho Low was rejected by Henley & Partners as an investment migration advisory client
  2. Jho Low was referred without prejudice to an external and independent consultant
  3. Jho Low (it should be assumed) was advised by the independent consultant as regards Cyprus Citizenship by Investment Application………. At no point did any person or entity within the H&P Group structure, including Henley Estates, ever
    contract or receive income directly from Jho Low. They contracted and received income from long standing corporate real estate partners.

Nonetheless, documents and emails obtained by the investigation provide a very different picture. They show that H&P senior officers did directly engage with Jho Low to assist in his property purchases and citizenship application claiming by far the largest share of the payable fees in the process.

And far from being an ‘external independent consultant’ H&P’s representative in Cyprus, Yiannos Trisokkas, described Fides Corp to Jho Low himself as their “exclusive local service provider” on the island.

Moreover, whilst invoices were channelled through Fides Corp, payments were made direct to H&P’s Malta bank account from a personal escrow account arranged for Jho Low in Cyprus by Yiannos Trisokkas in his capacity as “Director of Henley & Partners Cyprus Limited”.

In one direct email sent by Trisokkas to Jho Low 21st June 2015, Trisokkas advised the supposedly rejected client:

“Dear Mr Low, We have already instructed our exclusive local service provider and the companies are ready with the nominee services included as well. Once the contract of sale is signed for the villa between the seller and the buyer (your company) then the nominee will be signing further to your written instructions….. the same trust will be submitted for the citizenship application”

Trisokkas advised in the same email that he had organised for Jho Low to personally open the local escrow account specifically to finance the application costs:

“a client escrow account is opened further to our directions, please see attached. For application purposes the ministry of finance accepts client accounts specifically opened for each client”

The total fees for the house purchase were listed as €5,960,000, however Trisokkas warned in that this “does not include anything related to your citizenship application”.

Trisokkas then addressed another H&P senior figure copied into the email, Jennifer Lai, Managing Partner and Head of Business for H&P North Asia, adding the comment:

“Jennifer, please advise if you have invoiced Mr Low for the citizenship application.”

3rd party referrals and no payment from Jho Low?

Rejected Client?

H&P duly invoiced Fides Corp immediately after the property purchase was completed in September for a total of €54,000 out of the €80,000 that Fides Corp charged Jho Low for his “citizenship fees”.

Jho Low paid H&P's Cypriot business partner Fidescorp €80k for 'citizenship services' - of which €56k was then paid to two H&P branches

Jho Low paid H&P’s “exclusive local service provider” Fidescorp
€80k for ‘fees & expenses’ – of which €54k was then paid to two H&P branches       (see beneath)

'Third party' referral fees paid by local Cypriot agency Fidescorp Ltd to H&P totalled €54k - 70% of the total of €80k charged to Jho Low

‘Third party’ referral fees paid by local Cypriot agency Fidescorp Ltd
to H&P totalled €54k – 70% of the total of €80k charged to Jho Low

x


Citizenship Fee payable to Jennifer Lai’s office in Hong Kong where Jho Low’s Jynwel Capital was based

Whopping Real Estate Commission

Days later a further €650,000 was also paid to H&P’s Malta bank account direct from the same Jho Low ‘client escrow account’ that Trisokkas had arranged through Fides Corps as a whopping 13% commission on the €5 million property purchase made by Jho as part of the same citizenship transaction.

The grand total received by H&P in return for this one Cypriot citizenship for Jho Low was therefore at least €700,000. It is understood that in the event the other passport applications for his entourage failed to be processed.

€650,000 referral fees to H&P transferred by Fidescorp relating to Jho Low's purchase of a €5million property as part of his citizenship transaction.

€650,000 paid from Jho Low’s escrow account to H&P as
commission on his  purchase of a €5million property as part of Cyprus’s citizenship for property investment scheme

It is therefore clear that despite H&P’s repeated claims that they received no payment directly from Jho Low and that they were rewarded only for referrals to independent third parties who autonomously handled the case, the Malaysian fugitive was in touch with H&P senior staff throughout his citizenship application to Cyprus through the island’s controversial passport for property scheme and paid directly.

What’s more, following the successful application and the payment of those fees Trisokkas and his colleagues were to continue to assist Jho Low according to later documents we have also obtained.

Client Agreement

Just four months before obtaining his Cypriot citizenship Jho Low signed a direct ‘Client Agreement’ with H&P dated 7th May 2015. As part of the Client Agreement H&P had required Jho Low to sign a due diligence pledge that he would the ultimate source of all funds payable to H&P.

Jho Low's recognisable signature was on the Client Agreement on the H&P form

Jho Low’s recognisable signature was on the Client Agreement on the H&P form

H&P claim that the above agreement was cancelled following a negative KYC (Know Your Customer) report in June 2015, however they have so far provided no evidence of the cancellation.

A ‘One-Off’ Transaction

When asked to explain the €650,000 property commission received by their Malta head office from an allegedly rejected client, H&P claimed that it owed to an inherited real estate arrangement that Jho Low had made with another previously ‘independent’ consultant, Andrew Taylor, who later joined the company

H&P explained Taylor’s own company, Taylored Estates, had a licence from an H&P Malta subsidiary called Henley Estates (only operational under that title since May 2014) to utilise the company name for property transactions. H&P has so far failed to provide evidence of this transient licensing agreement.

Taylor became a partner and Group Vice Chairman of H&P in March 2015, explains Paddy Blewer, thereby absorbing his previously ‘autonomous’ business along with the prior arrangement with Jho Low into the company. This entitled H&P to receive the commission,  the company argues.

On the other hand, Blewer admits such practices should no longer continue.

Since the original exposes in 2019 about the company’s connections with Jho Low (in 2019) there has been a thorough review of corporate governance and a reform of company procedures. “Henley and Partners in 2021 is not the Henley of Partners of 2010, or of 2015-17″ he said:

“this transaction was identified as a one off that should not be repeated and is contrary to our adjusted corporate governance post integration of Henley Estates…. Henley & Partners has both enhanced its governance standards and altered its contracts with external parties to ensure that if it rejects an individual for any reason, it can no longer benefit even indirectly from that individual’s possible subsequent transactions in any way.
[H&P Statement January 13th]

When Sarawak Report/OCCRP then alerted H&P to the growing body of evidence showing that, far from being a “one off” transaction, senior H&P staff – namely Trisokkas and H&P’s Head of Business Development, Jennifer Lai – had continued as late as November 2016 to engage and assist Jho Low in his property transactions (Jho Low later swapped his property to a larger more exclusive plot) H&P further updated its response.

Rejected as a client June 2015, continuing to receive service November 2016

Rejected as a client June 2015, continuing to receive service November 2016

H&P explained in its updated statement that although the firm maintains it “did nothing wrong” some “individual members of staff” might have failed to “exercise sufficient levels of judgement“.

Spokesman Paddy Blewer further revealed that all the staff we identified as having continued to perform services for Jho Low are now no longer with the company, including Andrew Taylor and the former CEO at that time:

“We remain entirely certain that this firm did nothing wrong. It may be that some individual staff members involved at that time did not act as one team or failed to adhere to the new procedures, or did not exercise a sufficient level of judgment as to their interaction with real estate partners.

To reiterate this important point, anyone involved in this transaction at a senior level is no longer with the firm today. Yiannos Trisakkos, Jennifer Lai, Andrew Taylor and the previous CEO have all subsequently left the company.”
[Statement by H&P 20th January]

Despite this move to effectively blame and disassociate the company from these senior former staff members, Sarawak Report has noted that both Jennifer Lai and Yiannos Trisokkas continued to be advertised as existing employees on the company website until the day after H&P issued us that statement – at which point their names were both removed. Meanwhile, Trisokkas continued to remain as the registered director of the H&P Cypriot subsidiary, Henley & Partners Cyprus (as of January 20th last checked).

Likewise, until we notified Henley of the documents in our possession, Andrew Taylor continued to represent his primary employment on his Linked In page as working for H&P …  since 2009 “till present”.

His Linked In page was subsequently altered to announce he had left H&P in 2018 and had started a new company in 2019. These changes to the details on his CV also appeared on 13th January 2021, the same day H&P issued the above statement to Sarawak Report and changed their own website.

Andrew Taylor's LinkedIn site claimed he was working for H&P and still Group Vice Chairman when researched Jan 4th 2021

THEN – Andrew Taylor’s LinkedIn site
claimed he was still working for H&P and still Group Vice Chairman when viewed Jan 4th 2021

In amending his Linked In CV Andrew Taylor not only added a new company he has headed since 2018 but altered the stated dates of his past employment with H&P.

However, both versions claim that Andrew Taylor in fact became H&P Group Vice Chairman in June 2014, which is a full year before March 2015 when H&P say he merged his prior business with Jho low into the company and also pre-dates the May 2015 Client Agreement which Jho Low directly signed with H&P itself.

NOW - different dates, altered CV

NOW – different dates saying he ceased working for H&P in 2018 and a new company position and an altered CV appeared on January
13th after we queried the details of the payments from Jho Low

Blurred Relationships

Andrew Taylor’s relationship with H&P in fact predates Henley Estates and appears far reaching.  Close ties with the Chairman of H&P, Christian Kalin, in the immigration business are evidenced by their publication of a jointly authored book the “International Real Estate Handbook” in September 2013 under the imprint of H&P and Henley Estates.

Joint projects

Joint projects

H&P’s Paddy Blewer explained that the company’s business and expertise is immigration and citizenship law only and it therefore plays no direct role in real estate transactions linked to citizenship – hence the partnership with Taylor and his
company ‘Taylored Way’ and the merger in 2015.

“Henley & Partners, as a pure play investment migration advisory firm, had neither the experience or appetite to engage in the management or operation of a real estate company, or provide credible advice on real estate investments. It was therefore necessary to source and develop a more structured formalised global agreement with an external organisation …. As a result, Taylored Way changed its name to Henley Estates, and Andrew Taylor (the managing director) led the expansion
from 2013 onwards” 
[Paddy Blewer].

Yet despite the stated lack of expertise, it is notable the original edition of the International Real Estate Handbook book was published in 2005 by Christian Kalin as the sole author. The publisher describes Kalin as “an international real estate, tax and estate-planning specialist and a partner at Henley & Partners, Zurich”,  making for a complex web indeed of professed autonomy and expertise.

Equally confusingly, Taylor states in his own CV that he actually worked as a managing partner of Henley Estates as early as 2009 (amended to 2012 in the updated Linked In). In the absence of documentation from H&P it is unclear if this position was for the actual group or under another licence to use the name of Henley Estates.

Blurred lines of autonomy and expertise comprise H&P's explanation for denials over doing business with Jho Low

Blurred lines of autonomy and expertise comprise H&P’s explanation for denials over doing
business with Jho Low

Do Not Use Our Changing Statements Against Us

H&P has emphasised that the company now contributes to various charitable initiatives linked to “UNHCR, UNICEF, Andan Foundation and many others” assisting poor migrants. Yet, despite the references to later reforms and staff removals, the company still rejects any wrongdoing or inconsistency on its part regarding its handling of Jho Low or its earlier statements. Neither has Henley said it will return any money to 1MDB:

“It would be disingenuous for you to cast aspersions [against H&P] that simply do not exist…. This is particularly so were you to suggest that previous statements issued by us were untrue. To carry such false allegations would risk causing serious harm to our business.”
[Statement H&P 30th December]

However, there has been a problem with changing statements from H&P, who have plainly altered their explanations in response to escalating leaks about their business (direct or indirect) with Low Taek Jho.

For example, the €650,000 fee that was paid to H&P in September 2015 as a commission for Jho Low’s property purchase was, according to documents and information, originally paid through a Cyprus company named Donnica Management 23rd September 2015.

However, the payment was then returned from the H&P’s Malta bank account and was later re-sent on 30th September 2015, this time directly from the escrow Fides Corp client account for Jho Low instead (see above).

However, in the early exposes about the fraudster’s Cypriot links it was only a copy of the cancelled payment by Donnica Management that was picked up by the international press, including the Financial Times who approached H&P for an
explanation.

The payment from Donnica Management to H&P's Malta bank account explained the cash represented a 13% commission on Jho's €5m property purchase

The payment from Donnica Management to H&P’s Malta bank account
explained the cash represented a 13% commission on Jho’s €5m property purchase

Expressing frustration over reports that had connected H&P to Jho Low H&P had first complained in a statement:

Henley & Partners is aware of numerous misleading articles that have mentioned Henley & Partners in connection to Jho Low, the Malaysian fugitive….. the firm declined to accept Mr. Low as a client. It is therefore false to state that “Henley & Partners helped Jho Low acquire Cypriot citizenship.” [Statement November 2019]

Specifically H&P then told the Financial Times that “the money did not originate from any entity linked to Mr Low or his associates.”

“Henley & Partners told the FT that the payment was a fee from a Cypriot developer under a pre-existing agreement for Henley Estates to provide “marketing support services”, and the money did not originate from any entity linked to Mr Low or his associates.
Juerg Steffen, H&P chief executive, said the payment should nonetheless not have been taken, since his company had previously rejected Mr Low as a client following due diligence checks.
Mr Steffen said the case had helped trigger an overhaul of governance standards in the Henley companies. “Hindsight is a wonderful thing,” he said.
[Financial Times 24th November 2019]

However, as the latest documents that have now come to light reveal, that the payment did not ultimately arrive from the ‘Cypriot developer’ Donnica Management but from the Fides Corp’s client account for Jho Low. This was plainly an entity connected to Jho Low.

Records further show that Donnica Management is itself inextricably and directly tied to H&P. The company was set up 15th May 2015 just one week after Jho Low signed his Client Agreement with H&P and it appears to have existed primarily to facilitate the commission for his €5 million property transaction.

The shell company shares an address and Director (Andreas Trisokkas) with a subsidiary of an established developer on the island, Sky Prime Group, who sold the property to Jho Low according to research by OCCRP. It is the address of their mutual lawyer which houses numerous such Cypriot companies.

The other director of Donnica Management from the date of its incorporation was Ha Thi Hong Gam, a staff member of Henley & Partners based in Vietnam:

Independent developer which signed a pre-existing agreement before H&P took over Henley Estates?

Independent developer signed a pre-existing agreement before H&P took over Henley Estates?

Ha Thi Hong Gam makes clear she was the Vietnamese Director representative of Henley & Partners at that time according on her Linked In site:

The Director of Donnica Management worked for H&P

The Director of Donnica Management worked for H&P

And also according to H&P’s own website at the time which described her as a Director of Business Development:

H&P's own employee was a Director of Donnica Management that they admit processed the property purchase for Jho Low

H&P’s own employee was a Director of Donnica Management that they admit processed the
property purchase for Jho Low

The conclusion must be that far from this being an independent third party transaction H&P was involved in the Jho Low property for citizenship purchase from the start, whilst claiming they rejected him as a client.

Indeed, the same Ha Thi Hong Gam is registered as the Director of a number of other Cyprus companies including Sky Prime Holdings, again in tandem with Andreas Trisokkas.

Sky Prime


Sky Prime

Thus the picture emerges of an interwoven relationship between H&P and the local developers and service providers involved in the property for passport deal arranged for Jho Low – and it would appear for other clients also.

Notably, the local facilitators such as Fides Corp itself only received a fraction of the fees payed by Jho Low – 20% of the €80,000 charged for citizenship work – with the rest going to H&P. This evidence would suggest H&P was the dominant and driving entity behind the  application from start to finish.

Jho Low Wanted His Own Bank – And Multiple Passports

According to our research, the same network of agencies even engaged in the fraudster’s ongoing multiple attempts to buy controlling stakes in private off-shore banks as late as 2016, by which time his infamy was worldwide and the world banking system had closed its doors against him.

Sarawak Report has already reported how in order to facilitate the transfer of his stolen cash piles Jho Low teamed up that year with a Kuwaiti royal sheikh, the son of the then Kuwaiti prime minister Sheikh Sabah Jaber Al-Mubarak Al-Hamad Al-Sabah (Sheikh Sabah), who acted as a front paying bills and making multi-million dollar transfers.

Fides Corp agreed to manage negotiations on behalf of Sheikh Sabah for the purchase of a stake in the Cyprus Development Bank. It was Jho Low who made the introduction, Jho Low who stated himself to be acting as the Sheikh’s advisor and indeed it was Jho Low’s stolen Malaysian money behind the project.

According to documents obtained by Sarawak Report, on 23rd June 2016 Jho emailed a mandate he had drafted for the Sheikh to sign authorising Fides Corp to negotiate the purchase of up to 100% stake in the bank for €80 million.

The mandate, which the Sheikh duly signed and sent cites Jho Low quite clearly as the Sheikh’s “advisor” in the matter, despite the fact the 1MDB scandal had been raging for over a year. Two others also cited as advisors in the mandate drafted by Low say they were not involved in the attempted deal.

€80 million bid for Cyprus development bank orchestrated by Jho Low with the assistance of H&P's "exclusive local service provider" Fides Corp

€80 million bid for Cyprus development bank orchestrated
by Jho Low with the assistance of H&P’s “exclusive local service provider” Fides Corp

H&P has told Sarawak Report it also knows nothing of those arrangements and according to research by OCCRP the negotiations eventually stalled:

“Even if this individual was a client (which he was not), this sort of subject would not have been part of our discussions, because Henley & Partners is purely focused on professional investment migration advisory services. This is all we do”
[Statement 30th December 2020].

However the company and its network has continued to cross paths with the fugitive billionaire.

H&P was mandated to operate the scheme, but did not bar Jho Low?

H&P was mandated to operate the scheme, but denies it supplied the passport to Jho Low

As late as November 2019, by which time he was the world’s most wanted fraudster, Jho Low was still able to reportedly travel to Abu
Dhabi
on a passport obtained through another citizenship scheme relaunched in 2016 by H&P thanks to a mandate from the island government of Grenada.

No one apparently thought to alert INTERPOL to the existence of that document. H&P denies it was involved in the obtaining of the passport.

The DOJ has also disclosed that Jho Low held a separate passport from the island of St Kitts & Nevis, which is also one of the
string of mainly offshore locations where H&P boasts offices and local agents claiming to be the leading purveyors under cash for passports schemes. However, H&P in a statement has denied it supplied that passport either.

“We cannot comment on whether or not Mr Low acquired citizenship and passports from Grenada and St. Kitts and Nevis because he was not a client of Henley & Partners … We can confirm that never handled any application for this individual in any investment migration program anywhere in the world, nor did we do anything else anywhere for this person, because we rejected this individual as a client following our due diligence process. [H&P statement 30th December 2020]

Read The Full Statement

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Response to Questions OCCRP / Sarawak Report 30 December 2020

Henley & Partners is happy to engage with all legitimate media organisations. We will engage on this matter in two ways

  1. An initial on the record statement that summaries our broad response
  2. More detailed responses to specific questions – where we are able to, given legal constraints

Initial on the record statement

Henley & Partners is the global leader in professional investment migration advisory services. We have invested significant time and capital in creating a corporate and operational structure that has best practice governance at its heart.

Henley & Partners’ operations have brought over US$ 8bn of much needed foreign direct investment (FDI) to many different sovereign states. This FDI has in turn has created very significant sovereign and societal value through economic
diversification, employment creation and infrastructure investment. There has also been considerable collateral positive economic effects in the billions of dollars, besides the FDI generated by our firm. All of this is very important in
particular for smaller, vulnerable, mostly post-colonial economies.

Following a thorough internal audit, we are disappointed to see a respected organisation such as OCCRP attempt to use unnecessarily complex descriptions, and a factually incorrect analysis of investment migration professional practice to
insinuate some sort of nefarious activity.

Both the OCCRP and Sarawak Report are well-respected media with noble intentions and objectives. Many of the investigations that you have carried out and reports that you have published represent important investigative journalistic work.
This is why we have engaged with you in good faith and we would hope that this professional courtesy will be returned. We have answered your specific questions below.

At the same time, we must make clear that anything that is published which is based on real or deliberate misunderstanding of the investment migration industry or the professional work of our firm, or worse factually incorrect assumptions
made through prejudice on behalf of the authors, is likely to be defamatory and for good reason not acceptable.

At Henley & Partners we are proud of our operations and our people. We are particularly proud of the fact that we have helped and are helping many countries that are struggling to attract sufficient investment and create jobs. Many of
these countries are post-colonial economies that have significant difficulties in the face of financial crises, natural disasters, and now this unprecedented global pandemic with catastrophic impact in many economic sectors, and not least in
tourism. We are equally proud of the fact that we help hundreds of families every year to improve

their personal security and mobility, as well as their overall life opportunities, which are randomly assigned by way of where you happen to be born. We will always robustly defend our track record and the positive value we create.

Therefore, following a careful review of our responses, please revert to us with any clarifications necessary. We would prefer to go through five iterations and get this right, than have you publish something incorrect due to a lack of
engagement or lack of sufficient understanding. We trust you prefer the same and will make sure you have a complete and honest understanding of all the facts before you write about any of them and ensure that all your sources are correct.

1. On September 23, 2015, a € 650,000 commission on the villa purchased by Low was paid by the Cyprus- registered company Donnica Management Ltd to the Maltese account of Henley Estates Ltd. Henley Estates Ltd was incorporated in Malta in 2013
with the name of Henley Estates Holdings Ltd, and changed its name in 2014. We have evidence showing that Henley Estates Ltd is a company essentially affiliated with Henley & Partners since the date of its incorporation in 2013. In 2014
Henley Estates Ltdwas also a shareholder of Henley & Partners’ Cypriot establishment, E.T.A.G. Consulting Ltd, which was registered in Cyprus under the name of Henley Estates Cyprus Limited in 2013 and changed its name in 2015. We therefore
question why you are reported as having told the Financial Times that you inherited an agreement to receive a payment from Jho Low only as a result of acquiring Henley Estates Ltd some months before?

As explained to the Financial Times, this is a very simple matter of a previous arrangement with a newly acquired company – Henley Estates.

  • The individual in question was never a Henley & Partners client. He was rejected following our due diligence process which applies to everyone interested to become a client of this firm.
  • The referral to an independent third party was made as a matter of policy
  • Henley Estates had previously operated as “Taylored Estates” as an independent real estate advisor. Following a period of engagement, the name “Henley” was used under license – however the two companies operated autonomously, with
    separate management and no shared ownership. This changed following the acquisition. However the Taylored / Henley Estates agreements with 3rd party real estate developers were still in place for some time and not adjusted. This was an
    oversight that emanated from the post acquisition integration process, and would not happen again.
  • Moreover, following a thorough review of our governance, if a client is rejected and referred to another service provider, Henley & Partners will not claim commission on any real estate transaction or other transaction related to any
    rejected client.
  • Again, to be very clear, the individual mentioned was not ever a client of Henley & Partners, but was in fact rejected by Henley & Partners following the due diligence checks we had carried out.
  1. Between June and September 2015 three of Low’s closest associates applied for the Cypriot citizenship. They are: Low Taek Szen, Loo Ai Swan and Tan Kim Loong. In order to meet the program criteria, they purchased three beach-front villas
    located in the same area where Low’s one is. Did Henley & Partners play any role in managing their application for the citizenship and did it receive any commission on the property’s purchases?None of these individuals were Henley &
    Partners clients. We cannot comment on whether they have or have not acquired real estate and/or citizenship because we have no knowledge of these transactions, let alone received any commission should such transactions have taken place as
    you state.
  2. We have established that Donnica Management Ltd is a company affiliated with the Cyprus real estate developer Skyprime Group which is ultimately the company that sold the property to Jho Low. At the time of its establishment Donnica
    shared the same address with E.T.A.G. Consulting Ltd, previously known as Henley & Partners Cyprus Ltd., and FidesCorp Limited. Donnica’s sole shareholder, Leonitus Holding Ltd, was also registered in May 2015 and listed S.P.F. Nominees
    Limited as its sole shareholder. S.P.F. Nominees Limited is a service provider fully owned by FidesCorp Limited. Please provide details. How would you describe the nature of your relationship with FidesCorp Limited and with S.P.F Nominees
    Limited?The operational process of investment migration demands a level of ad hoc co-operation between independent professional advisors. A single application process will often have multiple advisors working on a transaction, as is
    standard in global investments across multiple asset classes. Investment banks / lawyers / accountants from separate, independent firms will often all work on the same private equity deal or other transactions. It is the same with
    investment migration.The best way to describe the relationship with FidesCorp Limited is one of several ad hoc collaborations on shared clients. This is an independent service provider who does for the most part its own accounting,
    corporate service provider, handling their own applications for their own clients, and similar business. We otherwise have nothing to do with FidesCorp Limited, and we do not know and do not have any sort of relationship with SPF Nominees
    Limited.
  3. Skyprime Holdings was incorporated in Cyprus in September 2015. According to Henley & Partners’ website the company is one of Henley’s real estate partners in Cyprus. The company’s beneficial owner is Menphisco Nominees Limited, a
    service provider whose shares are held by the law firm Tsitsios & Associates LLC. In a 2017 statement, Zacharias Zachariou, partner of the law firm, stated that “we have developed a long-standing synergy with Henley & Partners in
    Cyprus by responding positively and conscientiously to their clients’ need for absolute discretion and confidentiality. What we have in common with Henley & Partners is a professional commitment to protect our common clients’ privacy
    and interests”. How would you describe the nature of your relationship with Skyprime Holdings, Menphisco Nominees Limited and Tsitsios & Associates LLC?Again, the operational process of investment migration demands a level of ad hoc
    co-operation between independent professional advisors. A single application process will often have multiple advisors working on a transaction, as is standard in global investments across multiple asset classes. Investment banks / lawyers
    / accountants from separate, independent firms will all work on the same private equity deal or other transactions. It is the same with investment migration.

Cypriot Citizenship by Investment was often secured through real estate investment. It therefore stands to reason that an advisor such as Henley & Partners would have to work in partnership with a selection of real estate developers so that
we can offer a portfolio of property options to the client.

The best way to describe the relationship with Skyprime Holdings and Tsitsios & Associates LLC is one of ad hoc collaboration with regard to real estate for our clients. These are independent firms and we have otherwise nothing to do with
them. We do not know and do not have any sort of relationship with Menphisco Nominees Limited.

  1. What were the circumstances under which two of your clients, Jho Low and Nobuyoshi Fujisawa, made an attempt to purchase a majority stake in the Cyprus Development Bank? What steps were taken? Were they part of a coordinated series of
    actions? Please provide details.We have no knowledge or understanding of the scenario you have described. As we made clear publicly before, and explained again in detail above, Mr Low was never a client of Henley & Partners. It is
    therefore not factually correct for you to state the above. Even if this individual was a client (which he was not), this sort of subject would not have been part of our discussions, because Henley & Partners is purely focused on
    professional investment migration advisory services. This is all we do. We cannot speculate or answer questions about the circumstances about a situation we know nothing about – or even whether it happened.
  2. Have you any further comment to make as to your role in assisting a known criminal fugitive, which Jho Low clearly was from the moment he was identified by the FBI in mid-2016? Is the contract with Jho Low still in place? Please provide
    details.Again, please take note of the fact that Jho Low was never a client of Henley & Partners. However, it is worth restating the timeline. When he first approached Henley & Partners, he was not a known criminal figure. He was
    nevertheless rejected as a client of our firm
  3. In November last year Henley & Partners issued an official statement that denied Jho Low was a client and claimed the company had turned down his request to become a client, do you wish to qualify that statement?Please see our
    statements above. Jho Low was never a client of Henley & Partners.
  4. Jho Low further obtained passports from Grenada and St Kitts and Nevis. A UK parliamentary committee concluded last year that Henley & Partners had established a relationship with the governments of such countries (where you have
    offices) whereby you act as exclusive providers of such passports. Can you therefore confirm whether or not Jho Low was also your client in obtaining of these two passports?

We cannot comment on whether or not Mr Low acquired citizenship and passports from Grenada and St. Kitts and Nevis because he was not a client of Henley & Partners and we therefore have no knowledge of what he did or did not do and whether
what you state is true or not. We can confirm that never handled any application for this individual in any investment migration program anywhere in the world, nor did we do anything else anywhere for this person, because we rejected this
individual as a client following our due diligence process.

Your question also very unfortunately demonstrates a fundamental misunderstanding of the process of Citizenship by Investment and contains factually inaccurate assertions.

Neither Henley & Partners or any of our peers would have “act(ed) as exclusive providers of such passports”. There is quite simply no such role, and there never has been such a role for any company. Sovereign states that run citizenship by
investment programs based on their laws and regulations issue citizenship following their own processes, and following a qualifying investment to be made by the applicant in the country. These programs are promoted by accredited marketing
agents and applications have often to be handed in by local accredited agents or law firms. Some countries have a few such agents, some have over a hundred such professionals that are accredited to market the programs of these countries. There
is no program we have been involved in either historically or operating today that had or has a private company acting as “exclusive providers of… passports”.

Anyone who states anything to the contrary is at best misinformed and does not understand the situation – which is to some extent understandable as investment migration is a rapidly, globally developing industry. The alternative is that anyone
who states anything to the contrary is knowingly misrepresenting an actually clear situation for their own means.

The UK Parliamentary Committee referenced was the Culture, Media and Sport (DCMS) select committee looking at fake news and misinformation. It was not looking at investment migration, did not take evidence on the topic and does not claim to
have expertise on the subject as – for example – the Foreign Affairs select committee might.

The referenced comments made by that committee in its report were in fact outside its terms of reference. This perhaps puts in context why the statements we have described above are so inaccurate. Indeed, had the report not been subject to
parliamentary privilege we would have successfully challenged it as it contains a large number of factually incorrect statements, such as the example you stated with regard to Grenada and St Kitts and Nevis. This is very simply not true, and
verifiable by research of publicly available sources such as the relevant laws and regulations, for example. Any article that suggested the wording adopted by the DCMS committee on this point (or indeed many others where we have demonstrated
their findings were factually wrong) is correct, or that implied it had investigated the matter, would be inaccurate and most likely defamatory.

Conclusion:

We appreciate from following your reporting in the past that you have faced challenges to publish allegations that transpire to be true. However, for the reasons we have set out in this document, that is not the case here. It would be
disingenuous for you to cast aspersions that simply do not exist.

The public interest, which we know drives your work and is laudable, does not exist in casting false aspersions, particularly where we have directly contradicted those allegations by way of this response.

This is particularly so were you to suggest that previous statements issued by us were untrue. To carry such false allegations would risk causing serious harm to our business. We trust that, however much you believe investment migration as such
may be not desirable (and we very much think it fundamentally is, but currently lacks sufficient understanding to appreciate the significant economic and societal value it creates), you will appreciate that it would not be correct to paint a
picture that simply does not reflect the reality.

If for any reason the explanation for why these claims are demonstrably wrong is not clear to you, please let us know right away and we will be pleased to discuss and explain further. We are always at your disposal for any additional
information or clarification you may need.

Where Jho Low's known citizenship activity intersects with H&P's network of agencies

Where Jho Low’s known citizenship activity intersects with H&P’s network of agencies

Read The Full Updated Statement 13th January

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OCCRP / Sarawak Report 13 January 2020

Introductory Statement

Henley & Partners is committed to positive, objective and transparent engagement with all stakeholders, including the global media. We believe it is through this interaction that we will help better educate all audiences as to the
undoubted sovereign and societal value created by investment migration, as well as how it has developed into an international professional advisory services business that for its client base is just as standard as wealth management or legal
advisory services.

We believe that the most effective way to answer your questions is to provide a detailed narrative, thereby taking you through the historical progression.

Investment migration is a niche and complex business. It is therefore entirely understandable that those from outside the industry can make honest mistakes in their analysis of how transactions are managed, who is advising and who is
compensated and by whom etc.

Should you have any additional questions, we will be more than happy to engage.

Taylored Way / Henley Estates / Henley & Partners

Taylored Way Inc was registered as a limited liability company in 2010 by Andrew Taylor, a British- Canadian marketing expert. Prior to that, it was Taylored Way Marketing, a sole proprietorship registered in Canada by Mr Taylor. He traded
under both Taylored Way Marketing and Taylored Way Estates.

Taylored Way had staff in Canada, the UK, and South Africa. It marketed and sold properties primarily located in Thailand and Saint Kitts & Nevis to international investors. It acted, for example, for multiple real-estate developers that
owned projects approved for the citizenship program in Saint Kitts and Nevis. Arrangements with developers in other countries, such as Antigua, Portugal or Cyprus, were added later.

Taylored Way was effectively a sales and marketing consultancy or broker for real estate developers – the vast majority of income derived from their commission agreements with developers on whose behalf they would market and sell property as
an investment to international clients.

This is how Henley & Partners and Taylored Way first interacted – as entirely separate businesses operating in adjacent but largely non-competitive and potentially complementary markets. In 2010, Henley & Partners agreed to refer
clients that were interested in acquiring citizenship and/or residence through a program that involved real estate investment, to Taylored Way who had the necessary experience both in managing the needs of international clients and had a
strong understanding of the St. Kitts & Nevis real estate market. Taylored Way would provide an overview of the various real estate projects on the island and assist with a purchase that would satisfy the needed condition for citizenship.
Taylored Way in turn, referred their clients interested in Saint Kitts citizenship to Henley & Partners, whose expertise and focus was the advisory and processing of legal applications for residence and citizenship.

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As the international investment migration market developed, with new programs being launched by sovereign states that recognised the sovereign and societal value drivers of investment migration, real estate became a common qualifying option
for citizenship and / or residence programs in various countries. It therefore became more and more necessary for an investment migration advisor to have some sort of in house real estate advisory offering to clients. Henley & Partners,
as a pure play investment migration advisory firm, had neither the experience or appetite to engage in the management or operation of a real estate company, or provide credible advice on real estate investments. It was therefore necessary to
source and develop a more structured formalised global agreement with an external organisation.

Due to the positive client feedback and experience with Taylored Way, Henley & Partners agreed to support the expansion and operation of their real estate business to primarily support in the countries offering a residence or citizenship
program under the licensed name Henley Estates. As a result, Taylored Way changed its name to Henley Estates, and Andrew Taylor (the managing director) led the expansion from 2013 onwards.

Taylored Way became Henley Estates, however remained autonomously owned and managed by Andrew Taylor and his team until the end of 2014/early 2015. By 2015 Henley Estates had been acquired and integrated under the Henley & Partners
Holding corporate structure, and at that time became a Henley & Partners group company. As a result, Andrew Taylor in return became a shareholder of Henley & Partners, and joined the executive committee with responsibility for real
estate. An integration process started whereby Henley Estates adopted all Henley & Partners policies and procedures, and several people and offices from Henley Estates were integrated into or became part of Henley & Partners.

Yiannos Trisokkas and the Cyprus operations of what is now Henley & Partners were originally part of the Henley Estates organisation. They were, therefore, affected by the acquisition and post- transaction transition and integration.
Originally, Henley & Partners had no presence in Cyprus.

It should also be understood that the Henley & Partners Cyprus team had numerous real estate developers and agents as their clients. Taylored Estates and then subsequently Henley Estates was always compensated through their contracts with
multiple real estate developers and agents. Their role had always been that of a real estate broker, not contracted with or compensated by private clients, but servicing and being paid by real estate developers and/or agents.

Henley & Partners post-acquisition structure and relationship with external parties are entirely standard in both the investment migration advisory industry, as well as within many financial services organisations, and it is standard
practice in the real-estate development and brokerage field worldwide.

The transaction in question

Henley & Partners rejected Mr Jho Low as a client in 2015. This was due to the contents of an external due diligence report that made it clear that he was a second-generation PEP, having been very close to the Malaysia government of the
day, which was correctly assessed as too high risk. He therefore did not pass our onboarding procedures.

This was enough, under Henley & Partners’ governance standards, to make a decision not to onboard Jho Low as an investment migration advisory client, not to act on his behalf to support any investment migration application. However, the
nature of the decision meant that we did not make a judgement as to whether he would or would not be successful in a Cypriot Citizenship by Investment application. In such circumstances, we offer to refer the individual to independent
providers, which in this case was done by our local offices on the understanding that Henley & Partners cannot act for them.

To be very clear, Jho Low was never a client of Henley & Partners. Henley & Partners was not mandated by Jho Low.

We can however understand a level of confusion from outside observers as to the nature of the relationship. It can be explained as follows:

  1. Jho Low was rejected by Henley & Partners as an investment migration advisory client
  2. Jho Low was referred without prejudice to an external and independent consultant
  3. Jho Low (it should be assumed) was advised by the independent consultant as regards Cyprus Citizenship by Investment Application.
  4. Henley Estates Limited (Malta) remained responsible for all real estate related contracts in Cyprus. The team of Henley & Partners Cyprus continued to act as a broker for multiple real estate developers – not to advise private
    clients but to support real estate developers or cooperative agents.
  5. Any engagement between Jho Low and H&P staff, if any, was as a result of Henley’s long- standing position as an agent of multiple real estate developers. To be clear, the team of Henley & Partners Cyprus were acting on behalf of
    real estate development clients in the same way as Taylored Way/Henley Estates acted in the past. At no point did any person or entity within the H&P Group structure, including Henley Estates, ever contract or receive income directly
    from Jho Low. They contracted and received income from long standing corporate real estate partners.
  6. Any income derived from this process was always paid to Henley Estates solely from the real estate developer or agents due to the long-standing Taylored Way / Henley Estates style of contract that Henley & Partners took over,
    whereby, as a result, Henley & Partners Cyprus acted as a broker on behalf of real estate developers. There is absolutely no way Henley & Partners nor Henley Estates could have received any payment from Jho Low.

Henley & Partners today: constant development and commitment to governance

Henley and Partners in 2021 is not the Henley of Partners of 2010, or of 2015-17. There has been a series of significant changes both in terms of senior management and in terms of structure and processes.

In the course of these changes, today neither Andrew Taylor, nor Jennifer Lai or Yiannos Trisokkas are employees of Henley & Partners. Andrew Taylor remains a non-executive director of two of the group companies (Malta and South Africa)
but it is planned that he will resign also from these remaining positions at some point as he is no longer active since several years. Also the CEO during the period under question is no longer with the firm and there is new leadership in
place since that time (in fact since 1 January 2017 onwards).

We understand that as one of the leading firms in the field, we have to and want to be seen to be entirely committed to the highest of standards. This is why we have invested significant time and capital in creating a corporate structure that
has governance and due diligence at its heart. This is also why, for many years, we have worked hard to develop relevant partnerships with NGOs in the forced migration arena and have been responsible for fund raising of millions of dollars
through our partnerships with UNHCR, UNICEF, Andan Foundation and many others. Therefore, we have not only helped hundreds of people with their personal security and mobility who could afford our services, but also thousands of families who
could not and were forced to flee their homes.

A period of rapid growth an expansion (2010-2017) was followed by a period of consolidation, learning and restructuring (2017-2019). Multiple acquisitions and new operations had to be properly integrated into the global structure – including
and in particular Henley Estates. As part of this process, the transaction above was seen as an example from which Henley & Partners should and did learn. Following a significant management restructuring between 2017 and 2019 and
subsequent strategic audit processes, this transaction was identified as a one off that should not be repeated and is contrary to our adjusted corporate governance post integration of Henley Estates. To be very clear: such a transaction with
real estate partners, as we have discussed in the above narrative would not be possible today, and has been the case for a number of yeras.

Henley & Partners has both enhanced its governance standards and altered its contracts with external parties to ensure that if it rejects an individual for any reason, it can no longer benefit even indirectly from that individual’s
possible subsequent transactions in any way.

We remain entirely certain that this firm did nothing wrong. It may be that some individual staff members involved at that time did not act as one team or failed to adhere to the new procedures, or did not exercise a sufficient level of
judgment as to their interaction with real estate partners. All possibly involved and responsible persons are no longer with the firm today. Finally, it is very clear that Jho Low was never a client of any Henley & Partners company and
that Henley & Partners was only compensated corporate partners following long-standing contracts that were inherited from the takeover of Henley Estates.

It is due to our commitment to governance and best practice that we have chosen to engage on this subject to this level of transparency and detail, which we trust you will appreciate.

If anything is unclear, we are happy to clarify further and help you reach an accurate and factually correct conclusion.

Treasure Island Escape Routes For Global Fugitives?

Henley & Partners, fronted by Swiss lawyer Christian Kalin as Group Chairman, markets its ‘citizenship through investment’ schemes as a route to ‘Global Citizenship’ for so-called ‘High Net Worth Individuals’ using a network of mainly off-shore commonwealth domains boasting visa free travel arrangements to the world’s top destinations such as Europe, the UK and America.

However, there are concerns that in the same way the off-shore finance sector enables individuals to hide cash and assets, the off-shore citizenship business enables them to travel unfettered on multiple passports. Jho Low has exemplified the use to wealthy crooks and fugitives on the run.

H&P retains a pre-eminent role in the management of Grenada's passport scheme according to the official site. However global enforcement agencies appear not to have been notified of the existence of Jho Low's Grenada passport.

H&P retains a pre-eminent role in the management of Grenada’s passport scheme according to the official site. However global enforcement agencies appear not to have been notified of the existence of Jho Low’s Grenada
passport.

Over the past two decades the trade has exploded into a multi-billion dollar business for which H&P, as the market leader, makes no apologies:

“We are particularly proud of the fact that we have helped and are helping many countries that are struggling to attract sufficient investment and create jobs. Many of these countries are post-colonial economies that have significant
difficulties in the face of financial crises, natural disasters, and now this unprecedented global pandemic with catastrophic impact in many economic sectors, and not least in tourism. We are equally proud of the fact that we help hundreds of
families every year to improve their personal security and mobility, as well as their overall life opportunities, which are randomly assigned by way of where you happen to be born. We will always robustly defend our track record and the positive
value we create.”
[H&P Statement 30th December]

On the other hand, the potential for abuse is plain to see. In a recent TV expose a separate passport selling outfit in Cyprus assured one Al Jazeera reporter posing as a wanted criminal from China that the document could easily be issued, even with a bogus name and identity if required.

Chairman Christian Kalin and ex-Malta PM

Chairman Christian Kalin and ex-Malta PM Joseph Muscat

Cyprus has now suspended its citizenship scheme and launched a major official investigation into the scandal, including links between the industry and members of the government
connected to the scheme.

The Director of Fides Corp is himself the son-in-law of the now resigned Speaker of the Parliament, Demetris Syllouris, also caught on record by Al Jazeera claiming he could fix the passport they required.

H&P has also been accused of close ties with the now fallen Maltese Prime Minister Joseph Muscat, who had been challenged by journalist Daphne Caruana Galizia for granting the company an exclusive concession for another passports for sale scheme providing entry into the EU. Henley was reportedly threatening legal action against Caruana Galizia before the journalist was murdered by a car bomb.

Malta’s scheme has also now been suspended and is under investigation by the EU.

‘Faustian Pact’ To Elect ‘Conducive’ Governments?

Further criticism of the company’s alleged manipulative ties to off-shore political bosses was published in the February 2019 report of the UK Parliament’s Culture, Media & Sport Committee enquiry into the scandal hit political consultancy Cambridge Analytica/SCL.

The committee referred to a “Faustian Pact” between the two companies whereby H&P steered donations from wealthy passport buyers to ruling political parties to help keep the governments issuing passports through the company in power, including paying SCL to run their election campaigns.

Our Interim Report described the relationship between SCL Elections’ campaigning work and Christian Kalin, Chairman of Henley & Partners:
We were told that, behind much of SCL Elections’ campaigning work was the hidden hand of Christian Kalin, Chairman of Henley & Partners, who arranged for investors to supply the funding to pay for campaigns, and then organised SCL to write
their manifesto and oversee the whole campaign process. In exchange, Alexander Nix told us, Henley & Partners would gain exclusive passport rights for that country, under a citizenship-by-investment (CBI) programme. Alexander Nix and
Christian Kalin have been described as having a ‘Faustian pact’. With the exclusive passport rights came a government that would be conducive to Mr. Kalin and his clients. [UK Parliamentary Report into Disinformation and Fake News]

One example highlighted in news reports involved an election in St Kitts & Nevis. According to the Guardian newspaper H&P Chairman Christian Kalin first denied supporting elections, then acknowledged he made some ‘introductions':

“Kälin denies it. “This is rubbish. This whole notion that we raised or organised the financing is misguided,” he said.
Kälin insisted there was no coordinated effort by him, or Henley, to raise money for SCL. But he admitted many of his wealthy clients could have donated to the campaign.
He recalled meetings where he introduced people to Douglas and SCL, which, he said, he saw as part of his mandate as the then honorary consul for St Kitts in Switzerland.
“At that time I had direct interaction with clients. They trusted me. The prime minister trusted me. So I introduced many people to the prime minister. For sure many of them would have gone on to make a donation.”
Some of those donations, he says, would have been paid directly to SCL, but not all donors were Henley clients.” [Guardian 16th Oct 2018
‘The passport king who markets citizenship for cash’]

However, H&P has dismissed the comments by the UK Parliamentary Committee as being under-informed and based on inaccurate claims:

“The referenced comments made by that committee in its report were in fact outside its terms of reference. This perhaps puts in context why the statements we have described above are so inaccurate. Indeed, had the report not been subject to
parliamentary privilege we would have successfully challenged it as it contains a large number of factually incorrect statements.” [H&P statement 30th January].

What the global community can no longer ignore after examples like Jho Low is that off-shore financial secrecy combined with multi-billion dollar off-shore citizenship programmes have become the key instrument for global criminals to evade justice,
hide illicit funds and avoid paying taxes.

Recent estimates calculate trillions of dollars are lost to world governments owing to this
corruption – and the 1MDB scandal has helped place it in the spotlight. Following Brexit, the EU last week voted to add the Channel Islands and British Virgin Islands to its off-shore blacklist with other major players like the Cayman Islands likely to face similar scrutiny.

The new United States President Joe Biden has also pledged to tighten crackdowns on kleptocracy and off-shore money laundering under which the FBI assisted in the pursuit of Jho Low:

““I will lead efforts internationally to bring transparency to the global financial system, go after illicit tax havens, seize stolen assets, and make it more difficult for leaders who steal from their people to hide behind anonymous front companies,” [Foreign Affairs March 2020]

Indeed, as governments begin to chase the stolen money, off-shore operators like Henley & Partners may find their business model becomes more challenging and that the next probes will be from regulators rather than journalists.

To read the full OCCRP investigation click here.

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