The Great Ponzi shakedowns: Bart Henderson

Key topics:BHI Trust Ponzi exploited regulatory gaps, leaving billions lost to investors.Michael Haldane controlled BHI Plus and offshore entities, benefiting most.FSCA and NPA investigations were slow, incomplete, and missed key evidence..Sign up for your early morning brew of the BizNews Insider to keep you up to speed with the content that matters. The newsletter will land in your inbox every morning on weekdays. Register here.Support South Africa's bastion of independent journalism, offering balanced insights on investments, business, and the political economy, by joining BizNews Premium. Register here.If you prefer WhatsApp for updates, sign up to the BizNews channel here..By Bart Henderson.What we have here, is, failure to investigateUnder the four pillars of regulatory oversight for financial investments in South Africa, why do so many fraudsters seem to get away with it? Well, that’s easy, because more often than not, nobody is looking for fraud, nobody wants to look, too often everyone is too busy making money from it to want to look. Others get paid to look away.As for the people who’ve pulled off the heists, there’s a type.It is a type. They all think they’re unique, the smartest kid on the block, they all think they’ll get away with it, and they all do, until they don’t.A sociopathy prevails among this type, where insatiable desire for profit eclipses empathy, morality, and social responsibility. One that treats people merely as tools for wealth accumulation, through manipulation, exploitation, and a complete disregard for the well-being of others.In the case of the BHI Trust Ponzi, one person demonstrates this ethos, in spades and it’s not Craig Warriner serving 25 years in prison for the crime.Each Ponzi has its distinct characters sitting behind, or standing in front of them. Each Ponzi has its own distinct vagaries; hence each elicit a varied regulatory oversight response.If we are to learn anything from these fraud schemes, apart from their potential for devastating consequences for victims and for grey-listing, we have to learn from regulatory and oversight gaps and/or failures that permitted them to flourish in the first place.Regulatory Oversight Pillars for Financial Investments in South AfricaThe pillars of regulatory oversight for financial investments (and the broader financial sector) in South Africa are defined under the Twin Peaks framework (Financial Sector Regulation Act, 2017). They apply via the Prudential Authority (PA) (safety/soundness) and Financial Sector Conduct Authority (FSCA) (market conduct/investor protection), covering key laws like FAIS Act, CISCA, and prudential standards for collective investments, advice, and intermediaries.The four pillars of effective regulatory oversight are, licensing (gatekeeping to ensure only fit-and- proper providers operate), issuing regulatory requirements (setting standards/conduct rules (e.g., prudential or market conduct), supervising regulated entities (ongoing monitoring and risk-based oversight), and taking enforcement action (remedial, punitive, or resolution measures for breaches.FICA (Financial Intelligence Centre Act, 2001 – as amended) is separate from the Twin Peaks oversight pillars (PA + FSCA licensing/requirements/supervision/enforcement)..Read more:.BHI Ponzi: Court grants Haldane travel permission, investors outraged.It is a parallel Anti Money Laundering (AML/CTF) regime enforced by the Financial Intelligence Centre (FIC). All financial investment providers (e.g. CIS managers, advisers, brokers) are “accountable institutions”, and must comply.FICA sits alongside Twin Peaks to prevent money laundering/terrorist financing in investments. Non- compliance is a serious offence.Big Four South African Ponzi’s and Regulatory Oversight or Lack Thereof Mirror Trading International (MTI) – Johann Steynberg (2018–2021)South Africa’s largest crypto Ponzi (~R30 billion / $1.7 billion in Bitcoin from 280,000+ victims) — MTI evaded detection for roughly two years primarily because of sophisticated technological deception, regulatory gaps in the emerging crypto sector, MLM recruitment dynamics, and lack of independent verification.The sole “audit” trigger came from broker FXChoice (Belize) in July 2020: after participant complaints, it demanded audited financial statements during a compliance review. MTI/Steynberg refused to provide any, leading FXChoice to mark the pool account as “fraud” and freeze the remaining 1,280 BTC on 7 August 2020. This was the first real detection point.The FSCA started its investigation only in August 2020 (after FXChoice blocked the account), and issued public warnings (18 Aug: “take your money and run”), raiding MTI premises (Oct), and in December 2020 declaring MTI was “conducting an illegal operation, misleading clients and [contravening] several laws.”Barry Tannenbaum Pharma Import Scheme (2005–2009)SA’s second-largest Ponzi-type fraud (~R12.5 billion / ~USD $930m–1.2bn from ~800 mostly high-net- worth victims) involved fake “investments” in pharmaceutical active ingredients (APIs) for ARV drugs, backed by forged purchase orders from Aspen, Adcock Ingram, etc., promising up to 200% annual returns.The scheme operated unlicensed for ~3–4 years (2005–2009) as an unregistered investment vehicle with no Financial Services Provider (FSP) licence under the FAIS Act, and no collective investment scheme authorisation.The FSB (predecessor to FSCA) & FIC, mandated to oversee investment advice, monitor suspicious activity, and protect investors, took no proactive steps. They relied entirely on banks for Suspicious Transaction Reports (STRs).Rand Merchant Bank filed at least one STR in 2007 highlighting transactions that “did not make economic sense,” yet no apparent FIC or FSCA follow-up or intervention occurred. The FSCA later cited the Tannenbaum case as a reason to strengthen the Financial Advisory and Intermediary Services (FAIS) Act to better protect investors from similar "unregulated" schemesLouis Liebenberg Diamond Scheme (Forever Diamonds & Gold / Tariomix, ongoing as of 2026)Regulatory oversight of the Louis Liebenberg / Tariomix (Forever Diamonds & Gold) scheme was almost entirely absent pre-collapse and remained reactive, fragmented, and delayed for years despite early red flags.The operation ran unlicensed from ~2019 until liquidation in 2023 and arrests in 2024, raising an alleged R4–4.5 billion from thousands of investors via social-media MLM pitches promising 100%+ returns on non-existent “diamond parcels.”The scheme ran unlicensed for 4–5+ years as an unregistered investment vehicle:Liebenberg had no FSCA/FSB registration for financial services, collective investment schemes, or high-yield trading, explicitly avoiding oversight by telling investors it was “too new” or “under audit” when licences were requested.With echoes of Banxso, there was no proactive monitoring of social-media MLM-style solicitation.A Hawks / NPA investigation started as early as 2019 (confirmed in court affidavits and media). A Carte Blanche TV exposé (2020) highlighted unpaid returns. The NPA froze ~R100 million assets in 2021 on money-laundering suspicions. Yet no arrests occurred until October 2024 — a multi-year delay that allowed continued fundraising and victim losses to reach R4+ billion.BHI Trust – Craig Warriner (2008–2023/2024)Is a classic Ponzi scheme that raised R2.9 billion from ~800 victims (many retirees and St Stithians old boys’ network), promised steady >10% annual returns via three “strategies” (BHI, BHI Plus, BHI International).Only ~20% (R584 million) was ever legitimately invested through a JSE-authorised brokerage; the remaining 80% sat in a Nedbank money-market account, used to pay earlier investors and fund Warriner’s lifestyle.The scheme ran unregulated for ~15 years due to complete licensing gaps and reactive enforcement:The FSCA only launched an investigation in September 2020 (after possibly an earlier 2013, and subsequent assured 2016/2017 and 2018 separate red flag reports). Allowing Warriner and licensed intermediaries (e.g., Global & Local Asset Management) to continue channelling funds for years.The FSCA found BHI/Warriner contravened FAIS Act s7(1) and s13(1)(a) by acting as an unauthorised Category II discretionary FSPThe FSCA debarred Warriner for 30 years (May 2024) and executives Michael Haldane + Mauro Forlin for 30 years (October 2024) for unsuitable advice (e.g., pensioners with no other income), and withdrew Global & Local’s licence, after not acting for almost a decade.Perhaps it was threats of lawsuits, stemming from the BHI debacle, but the FSCA do seem to be showing some teeth as of late with record fines; Banxso (R2 Billion+) - December 2025, N-e-FG Group (R68 Million total) – 2025, CBI X SA Director (R216 Million) - 2023/24, and Markus Jooste (R475 Million) - March 2024, not that any are inclined to, or can pay. The FSCA: BHI Trust - Dropping the BallWhy did the FSCA in the BHI Trust matter take from 2013, to 17 August 2023 to finally serve Global and Local and Michael Haldane with a Notice of Intended Administrative Action?The case was considered sufficiently egregious for the FSCA to disbar Haldane and Forlin for 30 years. But why weren’t they fined as was the case with, say, Banxso?Paragraph 3.2.3. of the FSCA final report might answer this.“any loss or damage suffered by any person as a result of the conduct”; (is taken into account in determination) – “There have been no losses suffered by clients thus far”.The BHI Trust Ponzi collapsed barely a month later with losses exceeding an estimated R1.9 billion.It seems the fickle hand of fate stepped in, and Michael Haldane and Mauro Forlin of Global and Local, the now infamous financial advisors who referred hundreds of investors to the illicit scheme dodged the bullet of a hefty FSCA fine by approximately six weeks. Quite remarkable and fortuitous timing for them, considering the entire FSCA investigation into the scam dragged on for 7 years.That’s 100 times better luck than odds at a casino.If paragraph 3.2.3 had any credibility or merit in relation to why Haldane and Forlin weren’t fined, then it must be borne in mind that Michael Haldane was only debarred by the FSCA effective from 20 September 2024, by which time the damage wrought by his conduct was blatant for the world to see. The FSCA had 11 months knowing that investors lost in the billionsNow maybe the FSCA can come up with some rationalisation for their 7-year investigation, despite three separate tip-offs by highly credible sources providing a roadmap to the fraud, and why they imposed no fines between the report and final debarment in the end, but from the evidence point of view, in this matter, justice was not served.The FSCA failed to exercise their mandate, egregiously in my view, and as a consequence, failed the investors in the BHI Trust Ponzi and wider South African public.The devil is always in the detail and in regards to the entire record accumulated so far in the two years that have passed and subsequent investigations that followed, there is one paragraph in one document among thousands of pages of record that stands out, as that one stand out, devilish detail, that throws the entire case and the handling of it wide open.The Devil in the BHI Trust DetailIn this case its paragraph 3.7 of the FSCA Investigation Report: BHI Trust, Global & Local Investment Advisors (Pty) Ltd, Rubicon Administration Services (Pty) Ltd and Mr Craig Roy Warriner, dated 17 April 2023.Quote: “On 6 February 2013, the relationship between Axiam and BHI Trust was terminated. After this termination, Warriner remained a representative of Axiam and managed another client’s portfolio known as “Amalgum”, which was not a subject of this investigation.” (Exhibit FSCA)The detail is the exclusion of “Amalgum”, from the FSCA investigation into the Ponzi, it is, the, proverbial baby being thrown out with the bathwater.So grave was this misstep, of such magnitude, it makes a mockery of not only the FSCA investigation, but also that of the SAPS and NPA, their entire BHI investigation approach and process, for reasons that will soon become blatantly obvious and readily apparent.The BHI Trust Ponzi funds extraction LynchpinAmalgum 108 was a lynchpin, among others, but in this case the one that facilitated and perpetuated the systematic plunder of investor funds leading to the entire scheme ultimate collapse as I have stated before.This exclusion of Amalgum, from the FSCA investigation into the Ponzi has consequences.Such significant oversight influences the terms of reference for subsequent parallel investigations and role of the SAPS and the NPA, in investigating and pursuing the case, which from all appearances does seem to be non-existent, with both the SAPS and NPA seeming to demonstrate a distinct lack of appetite to pursue it, and this simply cannot go unchallenged.There are over 800 victims, not the 220 referred to by the FSCA, and between R2bn – R3bn in reasons why.Amalgum 108, was the key to the BHI fraud, racketeering and money laundering Valhalla. Amalgum is the BHI Plus Strategy referred to in the FSCA investigation record.Craig Warriner, the supposed mastermind of the BHI Ponzi, handed himself in, signed a confession, signed a plea deal and was convicted, sentenced to 25 years, end of, is how the story goes and the current status.Well, Warriner did not act alone. That is painfully obvious, from Warriner’s own account, and even if he only left breadcrumbs to follow, they were more than sufficient to pursue, unless it was somehow felt, by the authorities, that the “alleged mastermind”, had no credibility or anything meaningful to add.If it is, that is where I would beg to differ. It also begs the question as to why the criminal charges against Michael Haldane and Sona Pillay, who should both be in jail already, were “provisionally withdrawn” by the NPA.It is the “provisional withdrawal” of the charges, and seeming 2-year lack of interest on the part of NPA and SAPS, which I feel compels laying out some cold hard questions, facts, and the receipts, for the new NPA boss, the FSCA, and Acting DPCI bosses, as I lay out a premise, that Amalgum was the fountainhead of investors’ funds extracted by Michael Haldane in particular from the BHI scheme, bearing in mind the following:According to the FSCA Press Release 3 October 2024Global and Local, Haldane and Forlin contravened provisions of the Financial Advisory and Intermediaries Services Act, 37 of 2002; General Code of Conduct for Authorised Financial Services Providers and Representatives, 2003; Determination of Fit and Proper Requirements for Financial Services Providers, 2017; and Financial Sector Regulation Act, 9 of 2017. Haldane and his former associate, Mauro Forlin, former director of Global & Local Asset Management, have each been slapped with a 30-year debarment.Nothing in this finding points to Haldane’s active participation in the Ponzi itself, when in fact he was deeply involved in its structure, in its control, and in his beneficiation from that involvement, and participation and control of that structure, alongside Warinner. In fact, it appears Haldane, was the primary beneficiary of funds derived from the proceeds what was the BHI crime.FSCA REGULATORY ACTIONS REPORT 1 APRIL 2023 - 31 MARCH 2024: CASE STUDY BHI TRUST AND CRAIG ROY WARRINER:“The FSCA’s investigation showed that Mr. Warriner, through the BHI trust, offered three fictitious “investment strategies” to his clients, namely; the BHI Strategy, BHI Plus and the BHI International Strategy. (page 13)While these strategies purported to invest clients’ funds in various financial products and assets, the financial analysis conducted by the FSCA for the period September 2020 to November 2023, revealed a different reality.Of the approximately R2.9 billion received from clients, only about 20% (approximately R584 million) was invested in a legitimate investment vehicle through a securities trading account held at a brokerage of a JSE authorised user. The remaining 80% of the funds were held in a money market account, used to pay returns to other investors in a ponzi scheme fashion, and to fund Mr. Warriner’s lifestyle.” (Exhibit FSCA 1)There is no FSCA investigation record or finding related to the BHI Plus or the BHI International Strategy?If they did not investigate these entities, had they done so, they would have opened up the means for the SAPS to follow not only a substantial portion of the money stolen from BHI investors, but by who exactly, where it went, and ultimately ended up.The Hard Facts and Open Letter to: Unathi Kamlana (FSCA); Advocate (Andy) Mothibi (NPA); and Lieutenant General Siphesihle (ST) Nkosi (DPCI)Michael Haldane and his cohort, through his company Global and Local, steered by far the majority of the victims of the BHI scam to Warriner. There were most certainly not 220 victims as identified in the FSCA Report. There were hundreds more as I’ve discovered and stated.What does the following record tell you?The BHI Strategy Who Owns Whom RecordGlobal and Local majority shareholder (74%) at the time of its collapse, was a Trovara International HK Limited according to Global and Local Shareholder Structure dated 14 April 2023 signed by Mauro Forlin (Managing Director), Dave Haldane (Consulting Accountant and brother of Michael Haldane) and others. (Exhibit 1)Has anyone asked who this “Trovara” might be? Whether it surfaces anywhere else?Well, it does. It is a 50% shareholder in the company called Amalgum 108, which of course is BHI Plus Strategy, according to the share certificate, along with another company called Shangren, also Hong Kong, with the remaining 50% shareholding in Amalgum 108, also according to a share certificate. (Exhibits 2 & 3)According to CIPC records, Warriner was the Director of Amalgum 108, in 2023. However, Michael Haldane founded the company with Warriner on the same day on 05 September 2007. Haldane resigned as a director in 2010.In 2013, Amalgum 108 issued a Dividend Certificate for R800 000.00 in favour of a Rubicon Global Limited (Coastal Building, 2nd Floor, Wickhams Cay II, PO Box 2221, Tortola, Road Town, British Virgin Islands) (Exhibit 4)Whoever had ownership in Amalgum 108 (BHI+) it seems also owned 74% of Global and Local.If Global and Local were sending investors to BHI, they were double dipping as both Financial Advisor, and Fund.Problematic to say the least. This would be a conflict of interest. Illegal, no. But it does require far stricter oversight.So, who owned Rubicon Global Limited? Not a creative name when you consider the companies surrounding the BHI Trust Ponzi were Global and Local, Rubicon Administration, and Rubicon Trust.According to a Global and Local Share Certificate, dated 26 February 2010, Rubicon Global Owned 100% shares of Global and Local. Consequently, it seems at best, whoever owned Global and Local were, in fact, double dipping fees and commissions well before the scheme collapse. (Exhibit 5)By 2023 the situation had changed. A Shangren and Trovara owned 100% of Amalgum 108 (BHI Plus Strategy), while Trovara owned 74% of Global and Local.On Monday, November 13, 2023, a Lindi van den Berg of Global Capital solutions wrote an email to a Shanne Faber of Global and Local.“Hi Shanne Can you please assist with providing me with a breakdown of all dividends that have been paid offshore from: Global & Local, Rubicon Admin Services, Amalgum? Please provide the date of the payment, ZAR and foreign currency amount? Thank you for your help!” (Exhibit 6)This email was followed up with an email with two attachments. The one attachment, is an xlsx file.The xlsx file reveals “dividends” paid in the hundreds of millions by Warriner to, at first Rubicon Global Limited up to and including 2018, and from then on, to Trovara and Shangren, Amalgum 108 (BHI Plus Strategy), Rubicon Administration, and Global and Local. (Exhibit 7)The insidiousness of these quite apparent less than arm’s length relationships, is that Rubicon Administration, the “Fund Administrator” was a second central component to the BHI Trust heist.And let me be clear, some might call it a Ponzi, but I call it a planned, executed, calculated heist.Rubicon Administration had the distinct responsibility of sending out fake statements to investors with fake returns. These illegal fake statements with their fake returns saw Global and Local, Rubicon Administration, Amalgum 108 (BHI Plus Strategy) and BHI Trust all extracting fees and/or commissions and/or both.From these records then not only was there double dipping, but someone was “triple dipping”, benefitting from payments made by Warriner, for income from the Amalgum “Fund” (BHI Plus Strategy), The BHI Trust “Fund”, and income from the Amalgum (BHI Plus Strategy) fund Administrator, Rubicon Administration, with Global and Local Investment Advisors acting as financial advisors, sending hundreds of investors, to both BHI Trust and Amalgum (BHI Plus Strategy), like lambs to the slaughter, while also charging investors fees for that pleasure.Was this triple dipping strictly illegal? It also seems the answer is no according to my research. But again, it requires an even stricter, and far higher degree of oversight. Maybe the FSCA can answer if this triple dipping by Haldane was legal, even if it presents a profound conflict of interest?To me this structure was the perfect recipe for a disaster. The question is, was this conflict disclosed, and if it wasn’t that would qualify as a deliberate misrepresentation by way of a material omission.Going OffshoreIn any event, this triple dipping “someone”, appears to be whoever is behind, and ultimate beneficial owner (UBO), of the two Hong Kong based entities Shangren and Trovara (HK).And that appears to be two Trusts, namely an Emieri Trust and an AMEE Trust according to a 2023 xlsx spreadsheet attached to an email exchange titled, “MH Revised structure” prepared by an “Emily”, dated 27 September 2023, between Lindi van den Berg of Global Capital Solutions and a company called Osiris, calling on Osiris to revise their fee structure to assist Michael Haldane in restructuring his entire investment portfolio. (Exhibit 8)This would be 4 October 2023, one week before Christian Ashcroft, Warriner’s co BHI Trustee reported the scheme to the police.Timing is everything, and in this case this restructuring of Haldane’s offshore assets took place within a month, perhaps through somewhat of a tip off, in the form of a letter dated 17 August 2023, sent to Global and Local attorneys by the FSCA under an ominous heading: NOTICE OF INTENDED ADMINISTRATIVE ACTION AGAINST GLOBAL AND LOCAL INVESTMENT ADVISORS (PTY) LTD, in whichthe reasons for the administrative action were set out.It was the Authority’s view that during the period January 2013 to April 2018, Global & Local Investment conducted financial services with BHI Trust by furnishing advice to its clients. BHI Trust was not issued with a licence to render financial services..Listed under cryptic initials “MH Entities” in the email exchange dated 27 September 2023, between Lindi van den Berg of Global Capital Solutions and the company called Osiris with the attached 2023 xlsx spreadsheet, are Emieri Trust, Emieri Investments, Shangren and Trovara.In the email thread, an exchange makes reference Osiris request for permission from Lindi van den Berg of Global Capital Solutions, to settle the invoices for an AMEE Trust. (Exhibit 9)According to a letter signed, but undated, by Michael Haldane and Warriner created on 17 January 2018 and saved on 18 January 2018 they state; “As settlors and ultimate beneficial owners (“UBOs”) of the Daimoku Trust (DT) and the Sansho Trust (ST), we understand that the Trusts have signed undated transfer forms for the equal transfer of the shares of the company with Bianchi, which are yet to be executed. (Exhibit 10)The trustees of the Daimoku Trust, according to another letter signed by Michael Haldane, on 17 November 2014, and addressed to a “Geneva Management Group BVI”, addresses this Geneva Management Group as Trustees of the Daimoku Trust setting out his (Haldane’s), wishes and preferences regarding this trust. (Exhibits 11; 12 & 13)In the 2023 xlsx spreadsheet attached to the email exchange titled, “MH Revised structure” prepared by an “Emily”, dated 27 September 2023 is a graphic demonstrating the proposed offshore structure for the Emieri and AMEE Trusts.In this graphic, Emieri Trust (BVI), is to become Emieri Investments, a Global Business Company (GBC) registered in Mauritius.AMEE Trust (BVI) is to remain in the British Virgin Islands with its related assets being Shangren (HK) and Trovara (HK) as among its assets. (Exhibit Offshore) What the Documentary Evidence Tells MeFSCA REGULATORY ACTIONS REPORT 1 APRIL 2023 - 31 MARCH 2024: CASE STUDY BHI TRUST AND CRAIG ROY WARRINER:“The FSCA’s investigation showed that Mr. Warriner, through the BHI trust, offered three fictitious “investment strategies” to his clients, namely; the BHI Strategy, BHI Plus and the BHI International Strategy. (page 13)While these strategies purported to invest clients’ funds in various financial products and assets, the financial analysis conducted by the FSCA for the period September 2020 to November 2023, revealed a different reality.Of the approximately R2.9 billion received from clients, only about 20% (approximately R584 million) was invested in a legitimate investment vehicle through a securities trading account held at a brokerage of a JSE authorised user. The remaining 80% of the funds were held in a money market account, used to pay returns to other investors in a ponzi scheme fashion, and to fund Mr. Warriner’s lifestyle.”There is absolutely no evidence of an investigation record or finding related to the BHI Plus or the BHI International Strategy by the FSCA, much less the NPA or the SAPS?Initially it would seem, the whole shebang outside of the actual BHI Trust “fund”, was owned by a Rubicon Global Limited, up to and including 18 January 2018, and this structure piggy backed on Warriner’s BHI Trust, dwarfing anything Warriner himself benefitted from financially, by some stretch.In essence then from the record, Michael Haldane appears through these opaque structures to have had a controlling interest in, and beneficial ownership of, 90% of the issued share capital of Global and Local Investment Advisors, 100% of the issued share capital of Rubicon Administration, and 100% of the issued share capital of Amalgum Investments 108 (BHI Plus Strategy) since at least 2018.With the only dilution of shares being in Global and Local Investment Advisors as at 04 April 2023, to 74% (through Trovara), down from 90% in 2018.This serves to definitively demonstrate, Craig Warriner was merely a signatory to effecting transactions and funds transfers, on behalf of Michael Haldane, who it now appears, was the greater beneficiary, and mastermind behind the entire BHI Trust heist in the latter part of its lifespan, up to and including the time of the schemes collapse.It was his Rubicon Administration, and his alone, that generated the fictitious paperwork, that he used to draw in unsuspecting investors, that gave the BHI Ponzi its longevity, while he drew fees and commissions, based on fictitious fund positive performance.For this alone Michael Haldane should already be in jail serving a prison sentence, his assets seized.Michael Haldane has emerged through these documents, as the central architect and beneficiary of the “BHI Strategy” scheme, far beyond his role as a client advisor or referrer.While Craig Warriner served as the visible director and operator—handling day-to-day payments, including offshore transfers to Haldane—the structure points to Haldane's ownership and control of Amalgum 108 (BHI Plus), Rubicon Administration and Global and Local, as principal enabler of the fraud, its scale, concealment, and wholesale plunder.It is difficult to express what’s just been described, from my point of view, beginning with the reasons behind the FSCA disregard of Amalgum 108.This inexplicable failure of the FSCA to investigate a critical element of the BHI Strategy investigation, Amalgum/BHI Plus Strategy, appears to be a grossly negligent act and omission, by a function meant to ensure fiduciary duty and oversight, investor, and shareholder protection.To take 10 years since the first report was made to the FSCA by Mr Derek Course, a former employee, and 7 years from the time the scheme was interrogated and reported by Global and Local’s own Compliance Officer, speaks to a level of prevarication and gross negligence almost impossible to comprehend.It can only be concluded, that the FSCA, its critical failure to investigate Amalgum, its failure to fine Haldane, and the hitherto SAPS and NPA’s attitude towards the matter, their failure to even entertain any evidence oral or otherwise, from Warriner, from victims of the scheme or their attorneys, private citizens such as Sonja Oelofse and others, their treatment of any efforts to advance the investigation, or accept any outside assistance, demands very deep scrutiny and its own investigation, lest the public form their own already deeply jaded opinions, and draw their own conclusions.Especially once you realise, if you follow Amalgum/BHI Plus Strategy, you actually end up following the trail of money stolen by Haldane and by Warriner, a money trail they were at pains to try to conceal.Or at least R450 million+/- of the money known of, as reflected in the referenced emails and their attached spreadsheets.And we haven’t touched the millions looted through the other criminal enterprise Rubicon Trust, a company quite distinct from the company Rubicon AdministrationWith Rubicon Trust is where millions were stolen by Sona Pillay, from deceased estates and Road Accident Funds beneficiaries.So, I ask Unathi Kamlana (FSCA); Advocate (Andy) Mothibi (NPA); and Lieutenant General Siphesihle (ST) Nkosi (DPCI), what do these records tell you at face value, simply on a balance of probability?.Read more:.BHI Ponzi: Just 1% of R1.64bn recovered, even darker side to Haldane’s evil exposed.Victims of these crimes deserve justice, and restitution, and the low hanging fruit of Craig Roy Warriner walking himself into prison delivers neither, while the authorities allow the principal architects of the scheme, Warriner’s co-conspirators, to walk away scot free with their victim’s stolen money.What I see is a failure of the Twin Peaks framework, the four pillars of effective regulatory oversight, and FICA sitting alongside the Twin Peaks, to prevent money laundering/terrorist financing, involving BHI victims’ investments, and also a gross violation of the civil rights of the victims of this crime, to a proper and thorough investigation.

The Great Ponzi shakedowns: Bart Henderson

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