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Advice to Michael Child

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Enquiry

From
Michael Child
Date advice given
28 June 2018
Enquiry type
Email

Near the beginning of the pre application stage I asked pins about the position regarding money paid to pins by RiverOak RSP in terms of how pins would ensure that the money, from what is basically a foreign company that in it's various forms has operated out of at least two locations considered as tax havens.

Back when I asked RiverOak appeared to be located in Connecticut but registered as a Delaware LLC (perhaps for tax avoidance purposes) but my understanding is that this would have made pretty much impossible to ensure that funds from them were legitimately sourced and compliant with UK money laundering legislation.

At that time pins made me assurances that compliance was deemed to start at the point where RiverOak paid the acceptance fee to pins, which you say they now have.

My understanding is that RiverOak is still funded partly or wholly from outside the UK.

Can you please provide me with details of how pins ensured the payment was legitimately sourced?

Advice given

Relevant legislation does not place a requirement on the Planning Inspectorate to investigate or test the source of Acceptance fees.