Digital illustration of a puppet in a business suit signing documents at a desk surrounded by stacks of banknotes: A Muppet-style puppet with dark hair and wide eyes sits at an office desk wearing a navy pinstripe suit and tie, holding a pen over signed paperwork. The desk is covered with bundles and stacks of US dollar bills, and three silhouetted figures in suits stand in a dimly lit office with closed window blinds in the background.

How criminals use “muppets” to commit corporate fraud – and how to stop them

13 February 2025

8 Comments

Many fraudulent companies at Companies House are run by entirely fake directors – non-existent people with fabricated identities. But many others are fronted by “muppet” directors: real individuals, often recruited through Facebook, who lend their names to companies they don’t actually control. The true masterminds behind the fraud remain in the shadows.

From next month, we’re likely to see a surge in muppet directors. Companies House is introducing ID verification rules, making it much harder for fraudsters to register fake identities. The fraudsters’ likely response? Recruit more muppets.

Companies House needs to act to end muppet directors – and we have a simple proposal.

Donna

Meet Donna:

Donna's facebook profile

Donna seems a nice person, but has a tendency to promote “get rich quick” internet promotions to her friends:

facebook promotions for "win £100 credit" and "money gator"

Those posts didn’t get much attention, and nobody commented.

This one is different:

the free £1,600 is back - £450 each you do it a max of 4 times. Then dozens of comments from interested people.

Dozens of people responded – not surprisingly, given the offer of £1,800 of free money.

But what is this thing that you can do up to four times, but not if you’re Scottish, and if you’ve done one then you can’t do another?

Donna’s companies

Here’s what happened to one of Donna’s companies:

Companies House filing history page for a company with redacted name: [redacted] LTD
Company number [redacted]
Follow this company

Overview | Filing history | People | More

Filter by category
[ ] Show filing type
[ ] Accounts
[ ] Capital
[ ] Charges
[ ] Confirmation statements / Annual returns
[ ] Incorporation
[ ] Officers

Date | Description | View / Download
26 Mar 2019 | Final Gazette dissolved via voluntary strike-off | View PDF (1 page)
08 Jan 2019 | First Gazette notice for voluntary strike-off | View PDF (1 page)
27 Dec 2018 | Application to strike the company off the register | View PDF (1 page)
23 Nov 2018 | Micro company accounts made up to 5 April 2018 | View PDF (6 pages) / Download iXBRL
17 Apr 2018 | Micro company accounts made up to 5 April 2017 | View PDF (6 pages) / Download iXBRL
12 Feb 2018 | Registered office address changed from Victory House 400 Pavilion Drive Northampton Business Park Northampton Northamptonshire NN4 7PA to Unit 4 Conbar House Mead Lane Hertford Hertfordshire SG13 7AP on 12 February 2018 | View PDF (1 page)
01 Feb 2018 | Notification of Josefina [redacted] as a person with significant control on 24 March 2017 | View PDF (2 pages)
31 Jan 2018 | Confirmation statement made on 22 January 2018 with updates | View PDF (4 pages)
09 Jan 2018 | Previous accounting period shortened from 31 January 2018 to 5 April 2017 | View PDF (1 page)
08 Dec 2017 | Director's details changed for Mrs Josefina [redacted] on 24 March 2017 | View PDF (2 pages)
04 Aug 2017 | Appointment of Mrs Josefina [redacted] as a director on 24 March 2017 | View PDF (2 pages)
18 May 2017 | Registered office address changed from [redacted] United Kingdom to Victory House 400 Pavilion Drive Northampton Business Park Northampton Northamptonshire NN4 7PA on 18 May 2017 | View PDF (1 page)
25 Apr 2017 | Termination of appointment of Donna [redacted] as a director on 25 April 2017 | View PDF (1 page)
23 Jan 2017 | Incorporation
Statement of capital on 2017-01-23
GBP 1
• Model articles adopted | View PDF (10 pages)

Four months after becoming a director, Donna resigned, and was replaced by Josefina – a resident of the Philippines:

Extract of a Companies House director appointment document dated 24 March 2017: New Appointment Details

Date of Appointment: 24/03/2017

Name: MRS JOSEFINA [redacted]

The company confirms that the person named has consented to act as a director.

Service Address recorded as Company's registered office

Country/State Usually Resident: PHILIPPINES

Date of Birth: **/03/1966
Nationality: FILIPINO
Occupation: BUSINESSWOMAN

Not long after, the company was struck off.

And this happened 23 times. Usually Donna is a director for a few months, then replaced by a Philippine resident individual, and then the company is dissolved:

Table of previous company appointments and directorships from a corporate database: Current appointments | Previous appointments

Previous appointments: 9 | Previous possible appointments: 14
Directorships: 9 | Possible Directorships: 9
Company secretaryships: 0 | Possible Company secretaryships: 3
LLP memberships: 0 | Possible LLP memberships: 2
Show per page: 50

Confidence | Date appoint. | Resig. date | Position | Co. Name | Reg. Number | Account date | Consolid. | Sales | Assets | Status
100% | 23 Jan 2017 | 20 Feb 2017 | Director | | | N/A | N/A | N/A | N/A | Dissolved
100% | 23 Jan 2017 | 12 Apr 2017 | Director | | | N/A | N/A | N/A | N/A | Dissolved
100% | 06 Jan 2017 | 20 Feb 2017 | Director | | | 05 Apr 2022 | No | GBP 0.00 | GBP 0.00 |
100% | 23 Jan 2017 | 25 Apr 2017 | Director | | | N/A | N/A | N/A | N/A | Dissolved
100% | 23 Jan 2017 | 25 Apr 2017 | Director | | | N/A | N/A | N/A | N/A | Dissolved
100% | 03 Mar 2017 | 25 Apr 2017 | Director | | | N/A | N/A | N/A | N/A | Dissolved
100% | 03 Mar 2017 | 25 Apr 2017 | Director | | | N/A | N/A | N/A | N/A | Dissolved
100% | 03 Mar 2017 | 25 Apr 2017 | Director | | | N/A | N/A | N/A | N/A | Dissolved
100% | 03 Mar 2017 | 25 Apr 2017 | Director | | | N/A | N/A | N/A | N/A | Dissolved
93% | 15 Nov 2018 | 20 Dec 2018 | Director | | | N/A | N/A | N/A | N/A | Dissolved
93% | 24 Feb 2018 | N/A | Director | | | N/A | N/A | N/A | N/A | Dissolved
93% | 23 Oct 2018 | 01 Aug 2019 | Director | | | 31 Oct 2021 | No | GBP 0.00 | GBP 1.00 | Dormant
93% | 12 Mar 2019 | 14 Mar 2019 | LLP Designated Member | | | N/A | N/A | N/A | N/A | Dissolved
93% | 13 Mar 2019 | 28 Apr 2021 | Director | | | 31 Mar 2021 | No | GBP 5.68k | GBP 350.00 | Dissolved
93% | 15 Mar 2019 | N/A | Director | | | N/A | N/A | N/A | N/A | Dissolved
91% | 10 Jun 2022 | 26 Oct 2022 | Director | | | 31 Dec 2022 | No | GBP 0.00 | GBP 243.00 |
91% | 10 Jun 2022 | 26 Oct 2022 | Director | | | 30 Nov 2022 | No | GBP 0.00 | GBP 117.00 |
91% | 23 Jul 2019 | 03 Oct 2019 | LLP Designated Member | | | N/A | N/A | N/A | N/A | Dissolved
91% | 24 Jan 2020 | 31 Mar 2023 | Director | | | 30 Jun 2020 | No | GBP 0.00 | GBP 51.73k |
91% | 07 Mar 2022 | 13 Jun 2022 | Director | | | N/A | N/A | N/A | N/A |
76% | 20 May 2020 | 30 Sep 2021 | Company Secretary | | | N/A | N/A | N/A | N/A | Dissolved
74% | 13 Mar 2019 | 28 Apr 2021 | Company Secretary | | | 31 Mar 2021 | No | GBP 5.68k | GBP 350.00 | Dissolved
67% | 15 Nov 2018 | 20 Dec 2018 | Company Secretary | | | N/A | N/A | N/A | N/A | Dissolved

23 Results
« ‹ 1 › »

Kelly

Kelly responded to that Facebook comment thread on 15 March:

Facebook comment from Kelly asking for information: Kelly [redacted]
Info please
Like 12 w

And, a few weeks later, she became the director of a series of companies, later resigning and being replaced by a Filipino individual:

Four side-by-side Companies House officer register pages for four different companies: [Panel 1]
[redacted]XY LTD
Company number [redacted]
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Overview Filing history People More
Officers Persons with significant control

Filter officers
Current officers

2 officers / 1 resignation

[redacted] Jarian
Correspondence address
Unit 3, 22 Westgate, Grantham, United Kingdom, NG31 6LU
Role ACTIVE Director
Date of birth July 1993
Appointed on 14 September 2023
Nationality Filipino
Country of residence Philippines
Occupation Director

[redacted], Kelly
Correspondence address
[redacted] United Kingdom, [redacted]
Role RESIGNED Director
Date of birth November 1980
Appointed on 28 April 2023
Resigned on 14 September 2023
Nationality British
Country of residence United Kingdom
Occupation Consultant

[Panel 2]
[redacted]YMZIE LTD
Company number [redacted]
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Overview Filing history People More
Officers Persons with significant control

Filter officers
Current officers

2 officers / 1 resignation

[redacted], Richard
Correspondence address
Office 4, Keystone House, 247a, Jockey Road, Sutton Coldfield, United Kingdom, B73 5XE
Role ACTIVE Director
Date of birth September 1985
Appointed on 15 September 2023
Nationality Filipino
Country of residence Philippines
Occupation Director

[redacted] Kelly
Correspondence address
Office 4, Keystone House, 247a, Jockey Road, Sutton Coldfield, United Kingdom, B73 5XE
Role RESIGNED Director
Date of birth November 1980
Appointed on 1 May 2023
Resigned on 15 September 2023
Nationality British
Country of residence United Kingdom
Occupation Consultant

[Panel 3]
[redacted]VIORE LTD
Company number [redacted]
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Overview Filing history People More
Officers Persons with significant control

Filter officers
Current officers

2 officers / 1 resignation

[redacted] Jennifer
Correspondence address
Office 4, Keystone House, 247a, Jockey Road, Sutton Coldfield, United Kingdom, B73 5XE
Role ACTIVE Director
Date of birth November 1992
Appointed on 18 October 2023
Nationality Filipino
Country of residence Philippines
Occupation Director

[redacted], Kelly
Correspondence address
Office 4, Keystone House, 247a, Jockey Road, Sutton Coldfield, United Kingdom, B73 5XE
Role RESIGNED Director
Date of birth November 1980
Appointed on 2 May 2023
Resigned on 18 October 2023
Nationality British
Country of residence United Kingdom
Occupation Consultant

[Panel 4]
[redacted]RYST LTD
Company number [redacted]
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Overview Filing history People More
Officers Persons with significant control

Filter officers
Current officers

2 officers / 1 resignation

[redacted] Jennifer
Correspondence address
Office 4, Keystone House, 247a, Jockey Road, Sutton Coldfield, United Kingdom, B73 5XE
Role ACTIVE Director
Date of birth December 1976
Appointed on 18 October 2023
Nationality Filipino
Country of residence Philippines
Occupation Director

[redacted], Kelly
Correspondence address
Office 4, Keystone House, 247a, Jockey Road, Sutton Coldfield, United Kingdom, B73 5XE
Role RESIGNED Director
Date of birth November 1980
Appointed on 3 May 2023
Resigned on 18 October 2023
Nationality British
Country of residence United Kingdom
Occupation Consultant

These companies are still active.

What’s going on?

Donna and Kelly’s companies were used as part of what’s called “mini umbrella company” fraud – thousands of small companies created to claim tax incentives they’re not entitled to. We published a four part report into these frauds in 2023. HMRC’s view of these frauds is set out here.

HMRC initial response to the frauds was to ensure the tax incentives could only be claimed by companies with UK directors. That’s why Donna and Kelly were hired. But once the fraud has started, they’re not needed – better to use directors who can be paid less, and are much harder for HMRC to track down. The Philippines is an ideal location.

Is it a crime?

Donna and Kelly surely know nothing about the tax fraud that is these companies’ ultimate goal. But they both incorporated a company and clicked a box that says they control it – that they’re the “person with significant control”:

Screenshots of Companies House persons with significant control registers for two companies: [Left panel]

FIXY LTD
Company number
[Follow this company] [File for this company]

Overview | Filing history | People | More
Officers | Persons with significant control

1 active person with significant control / 0 active statements

Ms Jarian [cut off] ACTIVE
Correspondence address
Unit 3, 22 Westgate, Grantham, United Kingdom, NG31 6LU
Notified on: 14 September 2023
Date of birth: July 1993
Nationality: Filipino
Country of residence: Philippines
Nature of control
Ownership of shares – 75% or more

Miss Kelly [cut off] CEASED
Correspondence address
Unit 4, Mill Park, Martindale Industrial Estate, Cannock, United Kingdom, WS11 7XT
Notified on: 28 April 2023
Ceased on: 14 September 2023
Date of birth: November 1980
Nationality: British
Country of residence: United Kingdom
Nature of control
Ownership of shares – 75% or more
Ownership of voting rights - 75% or more
Right to appoint or remove directors

[Right panel]

AL LTD
Company number
[Follow this company]

Overview | Filing history | People | More
Officers | Persons with significant control

1 person with significant control / 0 statements

Correspondence address
Office 8, Mills Hill Works, Corbrook Road, Chadderton, Oldham, England, OL9 9SD
Notified on: 16 February 2017
Date of birth: September 1980
Nationality: Filipino
Country of residence: Philippines
Nature of control
Ownership of shares – 75% or more

Donna [cut off] CEASED
Correspondence address
Notified on: 6 January 2017
Ceased on: 22 May 2023
Date of birth: December 1984
Nationality: British
Country of residence: United Kingdom
Nature of control
Ownership of shares – 75% or more

This isn’t true. Donna and Kelly aren’t in control of these companies – they’re doing what someone tells them. They provided false information to Companies House, and if they did so recklessly or intentionally then that’s a criminal offence.

The muppet explosion

As of today, muppets are a minority of the fraudulent companies at Companies House. Fraudsters are more likely to use completely non-existent people as directors – it’s easier and cheaper. The people hiring muppets probably did so because they wanted the veneer of legality.

But muppets are about to become much more common.

Companies House will have new identification procedures starting in March 2025 – this will make it much harder for criminals to establish companies using fake names. The obvious response from fraudsters? Hire more muppets. The muppets are real people – so would have no problem providing genuine identification documents.

We can therefore expect a large increase in muppet directors.

The Low Incomes Tax Reform Group issued a press release in 2023 warning people not to get involved in these “director” schemes. This was the right thing to do, but we fear it will not reach many of the people drawn to the schemes.

We have two suggestions:

  • Companies House’s incorporation website should add prominent warnings of penalties and criminal liability for people acting as “nominee” directors – i.e. agreeing to be a director on paper and follow someone else’s instructions. With the warning not merely a tick-box, but requiring new directors to type that they understand the warning.
  • Harsh as it may sound, we need widely publicised prosecutions of people like Donna. People will only stop being muppets if they know they face serious consequences.

An obvious response from the fraudsters would be to exclusively hire muppet directors from outside the UK, who are less likely to understand any warnings, and much less likely to have seen any prosecutions of previous muppets. That will, however, be less attractive to the fraudsters – if a company is trying to present itself as a real UK company (either to HMRC or other potential fraud victims) then foreign directors are a red flag. But if we’re wrong about this, and Companies House sees an explosion in foreign muppets, then we may need a radical solution, like requiring all foreign directors of UK companies to appoint a UK agent covered by money laundering rules.

We hope Companies House are ready to act.


Thanks to Simon Goodley at the Guardian for his original reporting on the MUC tax fraud, and Richard Smith and Gillian Schonrock for their amazing investigative work tracking down the scheme companies. If you haven’t read our original report, and how a tax KC blessed the fraudulent scheme, it’s available here.

Thanks to CompanyWatch for giving Tax Policy Associates access to their excellent software for free (there was no quid pro quo; they didn’t even ask to be credited).

Image by DALL-E 3: “a photorealistic image of a muppet committing fraud”

Footnotes

  1. We are masking the name and identifying details of the individuals caught up in this scheme because it would be unfair for them to attract random abuse on social media. We expect researchers will be able to identify them without too much difficulty (and we’re happy to assist any researchers/government agencies who need more information). ↩︎

  2. The software that extracts this data from Companies House is CompanyWatch – it’s much more sophisticated than the Companies House website, which often shows one person (even with a unique name) as multiple people, making it hard to see all the companies they’re involved with. CompanyWatch has kindly given us a free licence to use their software free. ↩︎

  3. Another solution would be for Facebook to use its immense resources and knowhow to block people from promoting “get rich quick” scams. There is, however, little sign of this. ↩︎

  4. For example typing something like: “I understand that if I act as a director on behalf of someone else without registering them as a PSC then I could be liable for large financial penalties and even imprisonment”. ↩︎

8 responses to “How criminals use “muppets” to commit corporate fraud – and how to stop them”

  1. E Rosa avatar

    Hello. I am actually quite concerned about this in relation to someone I know. They have a learning disability and I believe are being exploited in this way. I feel that simplystating “we need widely publicised prosecutions of people like Donna” isn’t helpful – some of these people actually need safeguarding against this, and we all need educating around how to help someone extract themselves once they are in this horrible situation.

  2. Pikolo avatar

    So… why does being Scottish prevent people from being a muppet director?

  3. Sally Burdis avatar

    I might add, as a result of something I saw happening in front of my eyes on FB I did a lot of investigation into similar posts, in this case mostly ticket scams, a common trick is to get fake or hacked profiles of people who appear to be keen to get involved and give positive feedback, this encourages others. It may be that the real people, were hacked accounts and all their date stolen and used – this can happen just from a ‘like’ to a post from a scammer that looks to be genuine. My conclusion is as many as 30% of FB profiles could be fake or hacked accounts, using stolen data and photos. Anyone can create up multiple profiles fairly easily. Scammers and others use this to their advantage to repeat ‘offend’ and find more ‘muppets’. Reporting to FB rarely has any effect.

  4. Sally Burdis avatar

    Why isn’t Meta taking responsibility? These ‘invites’ are all over FB profiles including fake profiles for Rishi Sunak, King Charles III, Paul Hollywood – hundreds of fake FB profiles in the names of celebrities, politicians, members of the Royal family exist and they are used to steal data and entice innocent people into such things, as well as selling fake tickets etc. etc. I find it increasingly worrying the lack of accountability that FB takes.

  5. Do He avatar

    When I first became a Director (c.2010) I was given a letter by Companies House that made clear I could basically end up in jail for any wrongdoings by the company even if I didn’t do anything wrong personally. My company – the parent – indemnified me – but the letter itself was a wake up call and if CH have stopped sending these then I would find that a backwards step. Sure, they can be improved but they must still exist.

  6. Caroline avatar

    Some of those muppets may be baby solicitors. This happened to me many decades ago.

    The senior partner asked me to sign something so I did. I was busy. I trusted him absolutely. He didn’t have time to explain but I had the impression it was about employers’ NI contributions. When I heard later from Companies House, I think that the annual return was late, and eventually realised what I had done, I was horrified and explained. Then I was horrified to realise I’d probably spoken out of turn about the senior partner. Nothing came if any of it as far as I know.

    And as I now find to my surprise that he is still alive and even has his own name on some companies, I’ll leave it there.

  7. Tom McCallum avatar

    Dan, what if the “mother country” could flip the script and, instead of telling Cayman what do to, in fact asked Cayman for their advice on how to handle this?

    Cayman is VERY strict on KYC on these and other matters. No “muppet” directors there.

    They have well established systems (including an online portal for reporting and for uploading relevant ID and other information) for Cayman companies.

    I would LOVE to introduce you to the people in Cayman, perhaps starting with Dax Basdeo, Chief Officer of the Ministry of Financial Services, or Cindy Scotland, CEO of CIMA (Cayman Islands Monetary Authority).

    I think interviewing them would help highlight to people in the UK how big the gaps are at Companies House here.

    1. Paul Hale avatar

      I mentioned that to Dan a while ago. I got the impression he didn’t believe me!

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