Solicitors warned about involvement in SLAPPs

Solicitors have been told to guard against getting involved in litigation aimed at silencing legitimate critics, known as strategic lawsuits against public participation (SLAPPs).

The Solicitors Regulation Authority (SRA) is concerned, alongside increasing public concern, that some solicitors in England and Wales are using SLAPPs on behalf of their clients. These are used to prevent publication on matters of public importance, such as academic research, whistleblowing or campaigning or investigative journalism.

It has published a warning notice that tells law firms not to act for clients in this way and outlines some of the activities that it would view as abusive litigation.

The warning recognises that lawyers can have a legitimate role in encouraging journalists and others to ensure that what is published is legal and accurate, but that proceedings must be pursued properly. Examples of abusive conduct or misuse of the legal system include bringing cases or allegations without merit, making unduly aggressive and intimidating threats, or claiming misleading outcomes such as exaggerated cost consequences or imprisonment in a civil claim.

As well as reiterating the Government’s three-part test for identifying a SLAPP, the notice also touches on other red flags that firms can use to identify them such as a client requesting the firm targets individuals instead of organisations or that they bring it in a jurisdiction unconnected with the parties or events.

The SRA also warns against incorrect or misleading labelling of correspondence, for example as ‘private and confidential’, or ‘without prejudice’. Although there are some instances when such labelling may be appropriate, solicitors need to make sure they have considered the reasons for such labelling and whether further explanation of the label is required. This is particularly important where the recipient may be vulnerable or unrepresented. The SRA says that unless there is a specific legal reason which prevents this, recipients of legal letters should generally be able to disclose that they have received them.

Paul Philip, SRA Chief Executive said: ‘SLAPPs pose a significant threat to the rule of law, free speech and a free press. The public rightly expect that solicitors should act with integrity. They should not be misusing litigation to prevent legitimate scrutiny from journalists, academics and campaigners.

‘This warning notice again makes clear our expectations. The right for clients to bring legitimate claims and for solicitors to act fearlessly in their interest is important. Yet representing your client’s interests does not override public interest obligations, so when solicitors cross the line into SLAPPS, we will take action.’

As well as the warning notice, the SRA has produced information for those who might be the target of SLAPPS, what to look out for and how to report any potential misconduct.

The SRA warned about involvement in SLAPPs in its advice for firms soon after the invasion of Ukraine, and it refreshed its guidance on conduct in litigation in March. It is already investigating 29 cases where firms might be involved in SLAPPs. It has also been in contact with MPs who have raised similar concerns in Parliament for further information.

The SRA has also worked with the Foreign Policy Centre and the Coalition Against SLAPPs in Europe to request details of potential cases, and following discussions with the Department for Business, Energy and Industrial Strategy, it is looking for statutory designation as a “prescribed person” under the Public Interest Disclosure Act to encourage whistleblowers by giving them full protection.

New survey and report show court users calling for 2023 as the year to make freedom of choice a reality

A new survey of court users has found the vast majority are calling for greater freedom of choice over how their judgments are enforced – with 97% supporting the right to use a High Court enforcement route when recovering money owed to them.

The figures – just released by the High Court Enforcement Officers Association (HCEOA) in its 2022 Supporting Court Users – A Right to Freedom of Choice report, highlight that court users have been calling for change from the UK Government for the past seven years.

The new report shows that:

  • 97% of court users would like the freedom to choose between a High Court Enforcement Officer (HCEO) and County Court Bailiff to enforce their unregulated judgments under £600.
  • 93% of court users support a further changeallowing HCEOs to collect debts arising from Consumer Credit Act regulated agreements.
  • 96% of court users are still concerned about County Court delays.
  • just 4% of court users feel the current system meets their needs.

The HCEOA is marking 2023 as “Time for Freedom of Choice” and is calling on Government to take action to allow court users more freedom by making two small changes in regulations to allow court users to choose a HCEO to enforce judgments and recover regulated and unregulated debts under £600.

The changes would not mean an increase in enforcement fees. The HCEOA is proposing that the fees that HCEOs charge for collecting debts under £600 should match the non-High Court fee scale for debts of the same amount – they would be 100% in line with the current system.

The call from court users comes following significant delays in the County Court system. The vast majority – 96% – of court users reported concern over delays when using the County Courts, with many citing they have stopped trying to recover some debts altogether.

This means that individuals and businesses are just writing off money they are owed rather than dealing with the current court system. As a result, many businesses are having to increase their prices to absorb these losses, or risk going into debt themselves.

Alan J. Smith, Chair of the HCEOA, said: “For the past year we have been engaging constructively with the Government to ask for a change to the High Court and County Court Jurisdiction Order 1991, which would allow High Court Enforcement Officers (HCEOs) to enforce judgments and recover unregulated debts under £600.

“Government has listened, but we believe 2023 is now the time for action on this issue, and also on regulated debts, as our survey shows court users can’t afford further delays.

“We’ve been listening to concerns raised by court users since 2015 on the lack of choice available to them for recovering the money they are owed and believe High Court Enforcement Officers could help them.

“We are urging the Government to take action now and support the thousands of UK businesses and individuals who would benefit from these changes.”

Changes to the current regulations would alleviate delays to the court system, giving the County Court Bailiffs the time needed to work through the backlog of cases from outstanding judgments, and take on new cases from creditors who do not want to transfer up lower amounts of debt.

You can download the ‘Supporting Court Users – A Right to Freedom of Choice’ report from the HCEOA website here:

Together Financial Services – Q1 2022/23 Results

Together Financial Services Limited (‘Together’ or ‘the Group’), one of the UK’s leading non-bank relationship lenders, is pleased to announce its results for the quarter ended September 30, 2022.

Commenting on today’s results, Gerald Grimes, Group CEO Designate of Together, said: “Together delivered another strong performance in the quarter to 30 September, growing the loan book to £5.7bn while maintaining very low LTVs and arrears. The Group also remained highly profitable and cash generative, with underlying profit before tax of £34.7m and cash receipts of £541.8m.

“We continue to shape our business for the future, with a focus on optimising our distribution strategies, maintaining lending quality and sustainable pricing, and supporting our customers through this challenging economic climate. During the quarter we raised or refinanced over £800m to further strengthen and diversify our funding, leaving us with significant facility headroom to support our growth plans. We also made good progress with our sustainability agenda, achieving silver accreditation from Investors in People 18 months ahead of our plan, maintaining excellent customer reviews and improving our car fleet to 64% electric or hybrid.

“The UK’s economic outlook has become increasingly uncertain with high levels of inflation and rising interest rates causing economists to forecast a prolonged recession. Against this backdrop, many more customers may find themselves underserved by mainstream lenders and look to specialists to help them to solve problems and realise opportunities. With a clear purpose, a multi-cycle track record, our transformation programmes well underway and strong diversified funding base, we believe Together remains well placed to deliver on our strategy, to help increasing numbers of underserved customers realise their ambitions and to play our part in supporting the UK economy.”

Financial highlights: quarter ended September 30, 2022

  • Strong loan book growth at conservative LTVs with low arrears
    • Average monthly loan originations of £289.7m, up 61.9% on Q1‘22 (£179.0m) down 1.4% on Q4‘22 (£293.8m)
      • Conservative weighted average origination LTVs of 62.0% (Q1‘22: 60.1%; Q4‘22: 61.8%)
    • Group net loan book increased to £5.7bn, up 34.5% on Q1‘22 (£4.2bn) and up 8.3% on Q4‘22 (£5.2bn)
      • Weighted average indexed LTV remains very low at 51.9% (Q1‘22: 52.5%; Q4‘22: 51.5%)
      • Arrears profile remains benign, reflecting robust loan book quality
      • Impairment coverage increased slightly from previous quarter at 1.63% (Q1‘22: 2.15%; Q4‘22: 1.61%) due to increased impairment provisioning resulting from future macroeconomic uncertainty in forward-looking IFRS 9 modelling
  • Robust and sustainable financial performance
    • Interest receivable and similar income of £119.0m, up 27.5% on Q1‘22 (£93.3m) and up 11.9% on Q4’22 (£106.3m)
    • Underlying net interest margin of 4.9% (Q1‘22: 6.1%; Q4‘22: 5.3%), with compression during the period reflecting the impact of the extent and timing of rising interest rates
    • Annualised cost of risk of 0.9% (Q1‘22: 0.1%; Q4‘22: 0.2%), with change due to an increased impairment charge as a result of increased IFRS 9 provisioning
    • Group remains highly profitable and cash generative
      • Underlying profit before tax of £34.7m, down 10.6% on Q1‘22 (£38.8m) and down 12.4% on Q4‘22 (£39.6m) primarily due to higher impairment charges
      • Cash receipts of £541.8m (Q1‘22: £419.4m; Q4‘22: £522.2m) as redemptions remained strong
Q1 Q1 Q4
Key metrics     2023   2022 2022
Interest receivable and similar income (£m) 119.0   93.3 106.3
Underlying interest cover ratio[1] 1.7:1   2.3:1 2.0:1
Interest cover ratio 1.8:1   2.3:1 1.9:1
Underlying net interest margin [2] (%) 4.9   6.1 5.3
Net interest margin (%) 4.9   6.1 5.3
Underlying cost-to-income ratio1 (%) 32.3   36.9 37.8
Cost-to-income ratio (%) 28.0   37.1 44.4
Underlying cost-to-asset ratio1(%)     1.6   2.1 1.9
Cost-to-asset ratio (%)     1.3   2.1 2.2
Cost of risk (%) 0.9   0.1 0.18
Underlying profit before taxation1 (£m) 34.7   38.8            39.6
Profit before taxation (£m) 37.7   38.7            35.2
Underlying EBITDA   88.3   70.9 77.8
Loans and advances to customers4 (£m) 5,684.9   4,227.8         5,247.9
Net debt gearing (%) 81.2   76.2 79.7
Shareholder funds [3] (£m)         1,093.6   942.8            1,030.0
Underlying return on equity1 (%) 11.1   13.6 12.0
Return on equity (%) 12.0   13.5 14.7

Operational highlights

  • Further strengthened and diversified funding to support growth plans
    • Over £800m raised or refinanced across three transactions
    • £1.4bn facility headroom and £389.9m immediately available liquidity at 30 September
    • In October, credit rating agency S&P upgraded Together to ‘BB’ (previously ‘BB-’) citing our resilient earnings, capital buffers and asset quality. S&P also upgraded Together’s Senior Secured Notes to ‘BB’ (previously ‘BB-’) and Bracken Midco1 PLC’s PIK Toggle Note to ‘BB-’ (previously ‘B+’)
  • Continued progress against Sustainability targets
    • Achieved 75% 5 star customer reviews during quarter5
    • Awarded silver accreditation from Investors in People, 18 months ahead of plan
    • Funded a further 56 social housing properties securing homes for 187 tenants
    • 64% of car fleet now electric or hybrid

[1] September 30, 2022 excluded a £3.0m release of costs accrued in a prior period relating to the group’s strategic options review (Q1‘22: £0.1m customer redress provision charge, whilst Q4‘22 excluded a £0.2m share based payment charge and £4.2m costs associated with a strategic review of the business.
[2] There are no exceptional items impacting upon net interest income recorded in the current or comparable prior periods.
[3] Includes subordinated shareholder loans of £32.0m (Q1‘22: £29.8m, Q4‘22: £31.4m)
4 Net loan book is the net of gross loans and advances to customers and impairment allowances
5 Based on 220 reviews collated by Feefo, Trustpilot and Google Reviews during Q1‘23

Surging costs causing UK consumers to cut back on sustainable choices

Intrum’s annual European Consumer Payment Report (ECPR), which surveys 24,000 European consumers on payment behaviour and the economic outlook, shows that record increases in the cost of living have set off a wave of bill-anxiety, forcing consumers to make difficult spending choices.

Two thirds of UK consumers (65 per cent) say they would like to buy more sustainable goods and services, but the rising cost of living makes it challenging for them to do so. Seven in 10 are changing how they spend money and 66 per cent say that, because of inflation and increasing costs, they now can’t pay a premium for sustainable products. Of those changing their spending behaviour, half say they plan to shop more in discount stores in the next year.

Other sectors likely to be affected by changing consumer spending patterns are not-for-profits and charities, with one in five of those changing their spending behaviour saying they will give less to charity in the next year.

“The cost-of-living crunch has understandably made struggling consumers look for discounts, leaving less scope to pay a premium for sustainable products. This can create additional challenges for governments, businesses and other organisations striving to keep sustainable consumption and the green transition at the top of the agenda,” says Vanessa Söderberg, Intrum’s Global Sustainability Director.

The ECPR findings show, however, that most UK consumers will still ‘punish’ companies that they believe to be prejudiced. Sixty per cent said they would stop spending money with a company if they believed it discriminated against consumers by racial or socioeconomic profiling.

Other key findings in European Consumer Payment Report 2022 include:

Consumer confidence is lower now than in the darkest days of lockdown

  • More than half worry they won’t be able to retire comfortably (57%) and that they aren’t saving enough for the future (60%). This is up from 54% and 54% last year.
  • Unlike in recent years, older consumers are more likely to be affected (for example, 83% of Gen X say they are worse off than they were last year, compared with the UK average of 63%).

Inflation and lack of confidence is impacting consumer spending patterns

  • Seven in 10 UK consumers say they have become increasingly aware of unnecessary costs.
  • Consumers changing their behaviour are cutting back on meals out to compensate for rising prices, which is bad news for the hospitality sector and others that were starting to regain their footing after the impact of Covid.
  • Four in 10 are struggling to make ends meet and expect to default on a utility bill in the next 12 months. Three in 10 have already missed a payment in the past year.
  • Consumers who expect to miss bill payments in the next 12 months say they are most likely to default on e-commerce and online store bills.

CIVEA calls for Enforcement Conduct Board to uphold standards and support vulnerable people

After two years of detailed work, the Civil Enforcement Association (CIVEA) has welcomed the launch of a ground-breaking oversight body for the civil enforcement industry.

CIVEA is the principal trade association that represents the civil enforcement industry in England and Wales and was instrumental in designing the blueprint for the independent Enforcement Conduct Board (ECB).

A unique partnership between the debt advice sector and the enforcement industry, with support from the Centre for Social Justice (CSJ), has led to the establishment of the ECB to bring independent, objective, and effective supervision against a backdrop of increasing household debt and unpaid government revenues.

This comes as the next step in reforms led by CIVEA members to help professionalise the enforcement industry, which has involved the raising of standards, supporting vulnerable people and establishing an independent complaints procedure to empower individuals.

Russell Hamblin-Boone, CIVEA Chief Executive commenting on the launch said: “The enforcement sector has endured intense scrutiny in recent years, but the ECB can lift the bonnet on our industry. It is in a unique position to investigate the evidence and provide an education on the enforcement process, which will help to build a stronger reputation.

“CIVEA members are committed to work with the ECB to drive up standards and protect those struggling with problem debt. The task now is for the ECB to get up to speed on modern enforcement practices and to set in train its supervisory model.”

Intrum UK agrees deal to acquire Capquest and Mars UK platforms from Arrow Global

Credit management services company Intrum has agreed a £36.5m deal to buy the Capquest and Mars UK servicing platforms from European fund manager Arrow Global, along with a £121.25m investment for 50% of Arrow’s UK back book consumer portfolios.

The purchase includes outsourcing contracts with major financial institutions as well as the continued servicing of the Arrow UK consumer back book portfolios. It marks a significant stage in Intrum’s UK growth plans, following the company’s expansion in third party servicing over the recent years.

Intrum’s acquisition of Capquest and Mars UK will include approximately 800 roles, as well as two Glasgow servicing centres and premises in Manchester. The deal is subject to approval by the Financial Conduct Authority and is expected to take six months to complete.

“The agreement we have reached with Arrow Global further cements our commitment to third party servicing in the UK and underlines our growth ambitions in this market,” said Intrum Managing Director for the UK and Ireland Eddie Nott. “We believe the combined group presents a stronger proposition to prospective clients and our existing partners.”

Nott added that the cultures of the two businesses are highly compatible and the combined team will grow the business together. “We help our clients prosper by caring for their customers. This customer-centric approach, combined with Intrum’s scale, track record and sector expertise, means we are ideally placed to acquire the Capquest and Mars UK platforms.”

The acquisition accelerates Intrum’s long-standing UK growth plans. “The purchase aligns with our investment approach and is formed of key asset classes for Intrum UK, including several significant long-term contracts. This will lead to exciting opportunities for our existing and new teams and we look forward to welcoming those joining us,” said Nott.

The acquisition is expected to complete in the second quarter of 2023, subject to regulatory approvals.

Healthcare struggling with overdues

Accounts departments in the healthcare sector are spending twice as much time as their counterparts in the service sector chasing debts – proof that the fight for cash in some of the most hard-pressed sectors of society is now fully underway.

In a survey conducted by Debt Register, a new digital payment platform, 80% of firms surveyed in the healthcare sector, from drugs companies to care providers, were devoting 51% or more time on the phone or emailing to get money that was rightfully theirs to collect.

The most ‘efficient’ appear to be those in the Services sector (accountants, consultancies etc) where 43% spent less than 50% of their time on overdues, and of those, almost a quarter (23%) spent anything between 0 – 25% chasing the cash.

Perhaps not surprisingly, businesses in the energy sector also appear less troubled; 60% spent less than 50% of their time on overdues. When all businesses were taken into account, almost a third (32%) spend up to three-quarters (between 51% – 75%) of their time chasing late payments and almost a quarter (24%) spent even more (76%+).

But while the figures show the extent of UK business’ cashflow concerns, some commentators are worried that chasing the cash is taking accounts teams and business owners away from other tasks that are vital to business growth.

Gary Brown, Founder of Debt Register, says that businesses should be following up on invoices before they are due, and not when they are already late: “There are several tools out there that can deal quickly with overdues and free the credit manager to steer their companies towards businesses that they should be trading with, and away from those who present a greater risk,” he says.

Philip King, former interim Small Business Commissioner and Industry Champion, agrees: “Of course businesses need to keep the cash flowing, but if we are to grow our way out of recession they need also to be focused on the next sales opportunity, and not bogged down on tasks that can be easily automated.”

The survey was undertaken in the context of new technologies and platforms now being available that can automate the overdue payment process, dramatically improving cashflow without tying up a team’s time or having to resort to expensive (and often unproductive) legal action.

Digital payments: Sella launches trial of the biometric credit card in Italy

Authorize payment transactions by simply placing your finger on your credit card, securely and quickly. Sella is launching a trial of a biometric recognition credit card that, thanks to a small chip sensor, allows people to make payments by using their fingerprint.

The rollout of the new card, providing biometric verification for both direct and contactless payments, is led by Sella Personal Credit, the company of the Sella group specializing in credit to families, through a pilot project involving a selected target of customers in Italy.

Each customer receives a kit containing a particular device (“sleeve”), allowing for the enrollment of their fingerprint on the card in complete autonomy in a few simple steps, without having to go to the bank branch. Once acquired the fingerprint, the card is ready for use and requires no batteries: the biometric chip is powered directly by the POS in case of contact payments and through a magnetic field for contactless transactions. It will be sufficient to place your finger on the biometric chip on the front of the card to have a payment securely authorized.

The new F. CODE biometric card issued by Sella Personal Credit on the Visa scheme is developed in partnership with IDEMIA, a world leader in Identity Technologies with a multi-year know-how of design and implementation in the payment card sector and a proven track record in similar pilot projects worldwide.

The biometric cards can be used worldwide and are recognizable by any EMV-certified POS and ATM terminal.

“This new card enables a recognition mode that daily, is already in use by many people on their smartphones. At the same time, it highlights the Group’s constant focus on offering increasingly cutting-edge solutions to meet renewed personal needs”, says Giorgio Orioli, CEO and General Manager of Sella Personal Credit. “The collaboration with IDEMIA and Visa confirms this vision, aiming to enrich our customers’ payment experience while ensuring simplicity and security.”

“At IDEMIA, we are convinced that digital and innovation in payment will change how people shop and pay by bringing more convenience and security to the payment experience. Alongside our long-standing knowledge and expertise in Biometrics for decades, we are thrilled to participate in the deployment of the first biometric card in Italy issued on the VISA Scheme and look forward to shaping the future of payments with our partner Sella” says Aaron Davis, SVP – Financial Institutions, Europe at IDEMIA.

Lowell Third Quarter Results 2022

Lowell, a European leader in credit management services, today announces its results for the 3 months ended 30 September 2022.

Commenting on today’s announcement Colin Storrar, Group Chief Executive Officer, said: “These results demonstrate the continued underlying delivery of our business. The Group is performing in line with our June reforecast and the DACH region continues to show pleasing progress in its recovery following the Cyber incident in Q1.

“The deconsolidation of the publicly rated ABS facility is a key milestone, providing a repeatable funding source which will allow the Group to recycle capital and crystalise returns earlier in the investment cycle.

“Our run rate on purchases has peaked following a strong LTM period, and we expect purchases to be more closely aligned to our Replacement Rate as we move through into 2023.”

Key Highlights

  • Completion of the Hoist UK acquisition
  • Deconsolidation of the publicly rated ABS following the sale of 51% of the Junior Notes
  • LTM Cash EBITDA increasing to £583m (£504m)
  • +530bps LTM Margin accretion to 61% (56%)
  • £178m LTM free cash generated
  • £577m of LTM Portfolio Acquisitions (£320m)
  • Strong liquidity at the end of the quarter of £543m

(Note: comparable numbers for LTM Q3-21 in brackets)

Key Financial Highlights

As at 30 September 2022 LTM Q3-22 LTM Q3-21 Change
Cash Income £954m £904m +6%
Cash EBITDA £583m £504m +16%
Cash EBITDA Margin 61% 56% +530bps
Portfolio Acquisitions £577m £320m +80%


The business has deployed a significant amount of capital across the last twelve months on unique and attractive opportunities which will support its long-term growth ambitions. The completion of the Hoist UK acquisition in Q4 further supplements this and the Group expects purchases to be more closely aligned to its Replacement Rate through 2023. These acquisitions, and ongoing collection initiatives, will be key drivers in ongoing growth and de-leveraging.

Group Financial Performance

Solid Performance Despite Wider Economic Environment

Cash EBTIDA growth of £79m YoY following acceleration of collections associated with the publicly rated ABS structure.

Underlying performance is broadly flat, with the Group benefiting from strong LTM margin performance despite known headwinds of DACH Cyber incident and UK collection softness. Margin progression reflects increased collection activity in the UK and some early signs of inflationary pressure on the cost base.

DACH recovery remains pleasing with September in-month backbook performance above 100%, strong levels of capital deployment in the region and the on-boarding of new servicing mandates in the quarter.

The Group continues to generate significant free cashflow after Replacement Rate, providing sustainable self-funding for growth and benefits from a strong liquidity position of £543m at Q3.

Leverage sits within the guided range of 4.0x – 3.5x at 3.7x, despite a continuing ~0.2x impact from the collection deferral in the DACH region. The Group expects to continue to operate comfortably within its leverage guidance.

UK Collections Performing in line with June Reforecast

The UK region continues to benefit from a significant proportion of payments from long term sustainable plans with its consumers.  These payment plans continue to be resilient, however there is some marginal softness visible in the value from settlement payments.

Despite this, UK collections have performed in line with the June reforecast which accounted for the expected rephasing of collections and default rates have remained low at ~5%.

Completion of Hoist UK Acquisition and Funding Model Further Strengthened

The acquisition of Hoist UK completed in October 2022 following FCA approval. The deal will be part financed through the new £170m ABS facility as previously announced.

Lowell completed the sale of 51% of Junior Notes held in the publicly rated ABS structure for £10m in August, which has resulted in deconsolidation of the associated assets and liabilities from the Lowell balance sheet.

This process allows the Group to recycle capital from the back book of assets earlier in the investment period and clearly demonstrates Lowell’s ability in rehabilitating consumer accounts from non-paying in to reperforming cashflows.

Lowell continues to hold a minority stake in Junior Notes (49%) and will service the assets.

Bahamian FTX Liquidators Cite ‘Serious Fraud and Mismanagement’ in Court Filings – Comments from cryptocurrency fraud expert

“News that FTX’s liquidators have pointed to signs of serious fraud at the exchange is a major and potentially concerning development in the FTX saga. If it emerges that FTX defrauded customers on a major scale, or that there were internal failings which failed to prevent external fraud, this will no doubt have drastic regulatory consequences for the entire cryptocurrency industry.

“The digital assets and decentralised finance industry is already facing calls for regulation from governments and from non-governmental organisations such as the IMF and UN. Should it transpire that FTX committed or failed to prevent fraud, the scope and extent of those failings is likely to take some time to emerge, including the number of potential victims, but it is likely to increase the support for new regulatory regimes to be imposed.

“Cryptocurrency is an asset class that has been heavily affected by investment frauds and Ponzi schemes in recent years, however these allegations against FTX are of particular relevance given that the exchange was the third largest in the world at its peak. A clearer picture will no doubt emerge, however the liquidators’ findings pose a serious cause for concern for investors, regulators and the wider cryptocurrency market.”

Nicola McKinney, Partner at Quillon Law