Two brothers convicted over Collateral P2P platform that misused the FCA Register
Collateral (UK) Ltd · Peer-to-peer lending
The case in brief
Visible before detection
Checks that could have surfaced it, on hindsight
Document authenticity / direct pull
Would have pulled the FCA Register entry directly and seen the firm name and permissions did not match.
Can mislead when: The company can refuse consent, and a refusal is itself a flag. Some banks and co-op banks are not on AA yet.
Regulatory & litigation records
Would have shown the regulatory position and any FCA warnings.
Can mislead when: Court records lag and name spellings vary. A clean record can mean the problem has not reached court yet.
Bank credits vs books
Would have compared client money bank movements with the loan book.
Can mislead when: AA only sees the accounts the company links, so an undisclosed account stays invisible. Cash-heavy businesses and timing differences create false flags.
End-use tracing of funds
Would have traced withdrawals from client accounts.
Can mislead when: Kubr sees only the company's own accounts. Once money reaches a third party's bank, Kubr can flag the payee but cannot see the next hop without that party's consent.
Where Kubr services would have helped
Borrower monitor
Offered in India- C1 Would have compared client money bank movements with the loan book.
- C6 Would have traced withdrawals from client accounts.
- C8 Would have shown the regulatory position and any FCA warnings.
Financial diligence
Offered in India- C1 Would have compared client money bank movements with the loan book.
- C5 Would have pulled the FCA Register entry directly and seen the firm name and permissions did not match.
IC note
Offered in India- C5 Would have pulled the FCA Register entry directly and seen the firm name and permissions did not match.
- C8 Would have shown the regulatory position and any FCA warnings.
Portfolio monitor
Offered in India- C1 Would have compared client money bank movements with the loan book.
- C8 Would have shown the regulatory position and any FCA warnings.
Mapped from the checks each service runs. A hindsight reading of public records, not a promise that the failure would have been found.
Same pattern
A summary of public documents. It reports what the sources say. It is not Kubr's finding and not a statement of guilt.