AABA

THE ICAEW REPORT INTO ALLEGATIONS OF MONEY LAUNDERING

DATE:

25 February 1994

YOUR REF:

OUR REF:

GJP/MCB/IC GENERAL

To: All members of the
Investigation Committee

Papers for consideration prior to the meeting of the Investigation Committee on Tuesday 1 March 1994 at 2.00 pm in Committee Room 1, Chartered Accountants Hall. Moorgate Place, London.

G J Porter

Committee Secretary

0324 Mr Barry Kingsley Jackson FCA Secretariat
report.

Investigation Committee
1 March 1994

Re:

B K Jackson FCA
Grant Thornton
Coopers & Lybrand

Report to the Investigation Committee

This is the long overdue report to the Committee on AGIP (Africa) Limited.

In January a draft report was sent to the Chairman, Ron White, George Whiteside and Douglas Jupp who had been involved in the Teams. Their comments and questions have been included with reference to the action which might be taken from this point of time.

Body of letter to the team 5 January 1994

I should like nothing better than to close the file on ACIP, not least because I am conscious chat as case officer (not mercifully, my usual current role) I have contributed to delays by putting this matter aside in favour of more pressing and less intractable problems.

The public face of this case, that is the way in which Accountancy Age has criticised the Institute, is that "money laundering" has not been clamped down upon. The Institute's disciplinary procedures do not however lend themselves to this task. There are three versions of the nature of the transactions in which Mr Jackson and his associates were involved:-

(a) AGIP's favoured version of theft, with the proceeds concealed by cut-offs.

(b) Jackson's contention that ACIP were surreptitiously moving funds and avoiding French currency restrictions.

Mrs Bourguiba and Sophie Ben Hassine might have been the beneficiaries under (b) (or (c) I suppose) . The French exchange regulation avoidance has never made any sense to me. How can it be cheaper to send cash to Paris via the Isle of Man than direct from Tunisia?

All in all (c) seems the most likely to be correct. Perhaps Jackson has stuck to (b) because he does not want to be associated with anything overtly disreputable. Where no one can be completely believed, a disciplinary committee cannot come to any firm conclusions.

The position with regard to the legal actions is that AGIP were unsuccessful in July 1993 in registering the High Court judgement in the Isle of Man. Mr Jackson's solicitors (Wedlake Bell) said that they were contesting the registration because the judgement was based on fraud - ie on a false allegation that there had been millions of dollars stolen over a period of years. It seems from the press, however, that the grounds on which the court set the judgement aside were that AGIP had assigned it to Bowaters in March 1992. The latter could register it but appear not to have yet done so.

The following paragraphs, numbered from 1 to 8 are from a team by Messrs B L Worth (then Chairman), C A Barnes and G. L. Whiteside, which was put before the Committee on 5 November 1991. Consideration of the report was deferred to allow the Director, Professional Conduct Department, to review the evidence. This was because he doubted whether a formal
complaint against Mr Jackson could be sustained.

November 1991 Team Report

1 The Court of Appeal in December 1990 found that Barry Kingsley Jackson 'must have assisted in the fraud' which was perpetrated on AGIP (Africa) Limited by one of its employees in Tunisia. This judgement was made on the hearing of an appeal in civil proceedings against Mr Jackson for the recovery of money held by him. Leave to appeal to the House of Lords has been refused.

2. The case attracted considerable media attention particularly in Accountancy Age partly because of certain rather glamorous aspects. The money was transferred out of Tunisia probably without Tunisian Exchange Control permission via companies which Jackson formed and operated in the Isle of Man to jewellery companies operated in Paris by the niece of the ruler of Tunisia. The lawyer involved in running the jewellery companies was assassinated in open court in Paris.

3. It is not suggested that Jackson was involved in the fraud itself which was purportedly effected by altering the names on payment orders. He provided the conduit; he was money laundering.

4 In Court Jackson relied on technical submissions to the effect that if a bank pays away money against unauthorised signatures it pays away its own money. He did not give evidence himself. The judge at first instance and the Court of Appeal rejected the technical defence and condemned him in his silence.

5 Jackson argued d that there was no fraud, ACIP knew all the time who the money was going to and they got value for it. The implication is that the money was 'sweeteners' for development and drilling contracts in Tunisia and the case bears that interpretation.

6 . However, the Courts both in Tunis and in London found there was fraud. The fraud could not have operated without Jackson's activities and as quoted above the Court has found that Jackson must have assisted. Such actions must bring the Institute into disrepute and the team therefore recommend that a prima facie case of misconduct is made out against him.

7 . There are other members involved in this case. Mr Jackson had a partner, Bowers, but he was not involved in these activities and we find no prima facie case against him. Jackson was invited to become involved in these matters by a non-member manager at Grant Thornton, London office. It seems however that the manager substantially set up the arrangement before he joined Grant Thornton and we believe that it will be difficult to bring a case against the members in-that firm who were responsible for his actions.

8 . In thee course of the proceedings an affidavit was sworn by the auditor of AGIP (Africa) Limited, David Johnson FCA of Coopers & Lybrand, Jersey. It has been suggested chat: his affidavit was incorrect. Our enquiries are continuing and a further report will be made concerning possible charges against Johnson when they are
complete. They do not affect the case against Jackson.

Recommendation: Formal complaint against B K Jackson FCA.

Director's Review (including lists of dramatis personae and companies)

The Director's review, with an annex attached listing the people and companies involved, has previously been circulated. For ease of reference it is attached to this report to serve as a reminder of the facts or an introduction to the case for new members of the Committee (Annex 1),

Related Litigation

The latest position in the litigation is that the High Court in the Isle of Man set aside in July 1993 an application by AGIP to register there the judgement which they had obtained on 19 May 1989 in England and which the Court of Appeal had upheld on 21 December 1990.

The Court ruled that ACIP could not register the judgement because the company had assigned it to Bowrings in March 1992. The latter have not yet, so far as is known, sought to register it.

Whist the civil action was before the Court of Appeal investigation of Jackson's role was suspended. Meanwhile however, the part, if any, played by Grant Thornton was addressed, and by the auditors of AGIP (Africa) Limited who are Coopers & Lybrand (Jersey). Grant Thornton asked to be allowed to await the outcome of Mr Jackson's appeal. Eventually they maintained that he had been introduced to the go-between Monsieur Coulon by their employee Mr Humphrey before he worked for them. They deny any direct involvement on the part of the firm.

There had been, all along, press coverage of the matter in Accountancy Age. The burden of their song was that the Institute ought to concern itself with the parts played by Grant Thornton, whose employee brought B Jackson into the affair, and the auditors of AGIP (Africa) Limited. These are Coopers & Lybrand Deloitte (Channel Islands) who had not been brought into the correspondence except by the Secretariat to advise, very briefly, on the suggestion that AGIP might have wished to transfer money from Tunisia in excess of what might be permitted by the local exchange control legislation. They asked by way of reply, why AGIP would need or wish to do this, since the company did not generate income in Tunisia. Funds were sent to the Tunis branch for the expenses of oil exploration, it seems, not from it.

Press Coverage

The more recent press articles outlined a different scenario altogether from that set out in our earlier summaries. We proceeded on the basis that Mr Zdiri had stolen money from his employers, ACIP (Africa) Limited, by a transparent fraud involving altering the payees on invoices already approved for payment. The resulting money was transferred to a jewellery firm in Paris through companies set up by B K Jackson. The latter was criticised by the judge in an action brought by ACIP to recover the last payment, for turning a blind eye to the nature of the transactions, or at least not making sure there was no illegality involved. Now it was suggested by Mr Stuart Mansell FCA (a freelance journalist writing in Accountancy Age) that ACIP were never defrauded. They were said to have co-operated with the granddaughter of the Bey of Tunis then the wife of the President Bourguiba, to enable her to transfer money to Paris, ie "a plot to circumvent local exchange regulations" (Accountancy Age colour supplement, February 1991 - attached as Annex 2).

As has been mentioned above, the press coverage in the case, Accountancy Age that is to say, was directed at a possible link between Grant Thornton and B K Jackson's role in the AGIP matter.

On 5 October 1989 an article headlined "Grant Thornton man linked to AGIP affair,, referred to an employee, Roger Humphrey,_ as the "mystery link-man" and quoted Mr Lickiss as saying "I don't think 'there is any doubt that Humphrey met this man, passed on introductions, did things for him".

The man referred to was Monsieur Coulon. For present purposes it is necessary only to consider what evidence there is to connect him with Grant Thornton as such. Whilst Mr Jackson has given as one reason for his accepting instructions from M Coulon (to set up an Isle of Man company to transfer funds) that he was introduced by a prestigious firm, the latter denies that AGIP or Monsieur Coulon were ever clients.

The general background of the case is set out in the paper prepared by the Director, Professional Conduct Department, for the Committee in December 1991 (Annex 1) . Paragraph 11 deals with the question of who was the client of Mr Jackson and summarises the Grant Thornton view on that point. On 6 January 1992 the same was repeated by the National Managing Partner of Grant Thornton (a copy of whose letter with enclosures is Annex 3).

There has been no further evidence from Mr Jackson who has been asked, through his solicitors on 5 March 1993, whether he might not have presumed a Grant Thornton connection where none existed. Unless this produces grounds for further questions to Grant Thornton, or the team have enquiries of their own arising from the response. no case to answer has in my opinion so far been made out.

The Institute's initial approach to Coopers & Lybrand, Jersey was to enquire whether as auditors of AGIP (Africa) Limited they were able to comment on the alleged thefts by Zdiri over a period of eight years. Their reply was that AGIP were not generating income in Tunisia but spending money on oil exploration. Thus they had no need to transfer sums to Paris (whether avoiding currency restrictions or not) in the way described by Mr Jackson.

In the course of the civil action by ACIP to recover the last transfer, it was suggested on behalf of Mr Jackson that an affidavit b)! D Johnson of Coopers & Lybrand, Jersey, was incorrect. The Accountancy Age colour supplement cover story of February 1991 (Annex 2) deals with the auditors' role as well as giving a broad outline of the story. Mr. Johnson has sought clarification of the allegations against him. His letter of 11 September 1994 (Annex 3) has not been answered directly. The solicitors acting for Mr Jackson say that correspondence ought not to be copied to Coopers & Lybrand, commenting that:-

"It will go to the very heart of this matter if the Institute has a credible response from @fr Johnson of Coopers how it was that the alleged fraud, which AGIP themselves described as 1 gross and obvious' escaped his attention as auditor - if it did - not once, but repeatedly, over many years".

Formulating questions for the auditors to answer presents problems because we cannot just say .bathing was wrong therefore the auditors should have known about it. Mr Jackson clearly maintains that AGIP had organised the transactions surreptitiously. He suspects the auditors know all about it and that no thefts had taken place, but that cannot be proved.

Questions were formulated to the auditors., to which Mr D R Johnson replied. He confirmed that Coopers had not themselves conducted an enquiry when the alleged depredations by Mr Zdiri came to light. The police and AGIP investigated. Coopers later reviewed the internal audit work carried out by AGIP's employees.

Mention was made of a report by R Freeman of Casson Beckman which had been prepared to support the defendants in the action. This was never admitted in evidence. Coopers were standing by with a refutation on behalf of ACIP.

[Mr Johnson has recently retired. He was willing to discuss the case with members of the Committee, provided that one of his former partners could attend any meeting. They are in the Channel Islands, however, and having regard to that and the unlikelihood of serious revelations I would not recommend this course of action].

The following questions were raised by the team members: -

1 . What was done with regard to the seven items for further enquiry listed in the Director's report?

2 . What is the significance of failing to register the judgement?

3. Was B K Jackson asked about his reasons for believing Grant Thornton had previously acted?

4 . Has public or press interest ceased?

The questions put to B K Jackson have been answered by his solicitors, in particular in their letter of 15 October 1992 (Annex 4). The failure of the attempt to register the judgement was because of a technicality. The plaintiffs (AGIP) seem determined to maintain their assertion that the money was actually stolen. The defendant (Jackson) is equally adamant that AGIP were themselves the initiators of the transfers. He seems to have assumed Grant Thornton (Thornton Baker) were previously AGIP's agents because an employee of theirs introduced him to the business.

Public interest as such was never high, and the press have ceased to mention the matter.

23 February 1994
8-3-21 GJP/MCB/I89725 .

INVESTIGATION COMMITTEE
3RD DECEMBER 1991

THE ACTIVITES OF MR. B.K. JACKSON FCA CONCERNING AGIP

A Report by the Report by the Director, Professional Conduct Department

1. I have been asked by the Investigation Committee to review this file following the team's recommendation for disciplinary action to see if evidence would support a reasonable prospect of success before the Disciplinary Committee.

The English Litigation

2 The investigation began as a result of criticisms made by a judge of the Chancery Division concerning the conduct of Mr Jackson. On 19th May 1989 Mr Justice Millett gave judgement in.the Chancery Division in favour of AGIP in its claim against Mr Jackson, his partner Mr Bowers and his employee Mr Griffin for the return of over half a million US dollars representing the last payment in a series of transfers of money from Tunisia to Paris which had been arranged with the assistance of Mr Jackson's Isle of Man firm. The writ did not, as finally drawn, allege conspiracy to defraud against the defendants. The Court of Appeal dismissed Mr Jackson's appeal on 21st December' 1990 and leave to appeal to the House of Lords was subsequently refused.

3 The circumstances in which this money left Tunisia and the nature of Mr Jackson's, participation in the transfer arrangements are hotly disputed. To he ' lp follow the narrative a list of the main characters in this drama is set out in Annex A and the Companies in Annex B.

The Source of the Money: (A) AGIP’s account

4. According to the evidence given on behalf-of AGIP at the trial the COMPanY had been defrauded over a period of years of Us $ 17m by its chief accountant, Mr Zdiri. The history of this last transaction w-as summarised in the Court of Appeal as follows:

On December 18th Mr Del Sorbo of AGIP's Tunis branch, an authorised signatory, signed a payment order of $518,822 for the hire of a vessel. It was then fraudulently and without his knowledge altered by (Mr Zdiri) substituting Baker Oil for the original payee, with the address of the Lloyds High Holborn Branch and the number of Baker Oil's account.

The altered payment order was taken to the Banque du Sud on January 4th 1985. Banque du Sud debited AGIP's account and telexed instructions to Lloyds. It also instructed its correspondent bank in New York with a similar amount.

On January 8th 1985 Lloyds transferred the $518,822 to Bake.. 0'1's account. On January 9th it was transferred from that account to Jackson's client account at the Isle of Man Bank Ltd. On January 15th it was paid out by the Isle of Man Bank in accordance with Jackson's instructions to Kinz Joaillier. Mr. Coulon and to a Mr Chouk ben Abdellaziz who had not been further identified. Baker Oil, Euro-Arabian and Kinz went into liquidation.

Mr Zdiri was subsequently sentenced to imprisonment by a Tunisian court. Seven different companies were used in succession, each holding a US dollar account at the High Holborn branch of Lloyds Bank into which the money was paid. None "of the companies had any assets or carried on any business activity. After two or three payments in each case the account was closed and a new account opened for the successor company, the former company going into liquidation with Mr Jackson or his partner being the liquidator. All payments received were transferred, usually on the same day, to Euro-Arabian.

The Source of Money: (B) Mr. Jackson’s version

5 . Mr Jackson, by contrast, maintains that the payment the subject of litigation narose out of a scheme to circumvent Tunisian exchange control regulations in which (AGIP) were not only aware but also derived benefits. (15.6.89).

6 According to Mr Griffin (3.10.89), Mr Humphrey, told the firm in 1983 that this was part of a long established scheme to transfer money out of Tunisia as protection against the potential chaos likely on the death of President Bourguiba, seemingly for the benefit of Sophie Ben Hassine. Miss Hassine ' who was 'said to be a granddaughter of the last Bey of Tunis, was in some form of partnership with Madame Bourguiba and was the mistress of the managing director of AGIP. Assurances of the legality of the arrangements had been given to Mr Jackson by Monsieur Coulon, a French lawyer and adviser to Euro-Arabian, and by the Tunisian Interior Minister, Mr Driss Guiga. The money was being transferred out of Tunisia for a variety of purposes, but mainly for investment in Miss Hassine's jewellery shops in Paris. Mr Griffin used his contacts in Coopers' Jersey office to obtain informal confirmation of the arrangements. For his part, Mr Jackson “did not involve myself blindly (but) made good and sufficient enquiry. I questioned the original misleading story told me by Humphrey. I visited France and inspected the business”.

7 There is an apparent inconsistency in Mr Jackson's account in that. in one letter (15.6.89) he told us that -I was never a director or shareholder of the French company", while in two others (9.10.89 and 27.11.89) he stated that he was a director of Euro-Arabian. This latter version is borne out by Mr Griffin (3.10.89).

8 . Mr Griffin's account goes on to relate that in 1984, following unrest in Tunis, an order was given to discontinue the money operation, but it was ignored within AGIP which 'pushed the transfers to the limit with the intention of a final huge transfer towards the end of 1984-. (G 3.10.89). Monsieur Coulon (who had originally assured Mr Jackson of the legality of the arrangements - J 15.6.89) still claimed that the payments were legal, but Griffin found difficulty in resolving the different accounts he gave (G'3.10.89).

9. According to Mr Griffin (3.10.89).

Once Euro-Arabian had been established I could not understand what purpose the “shelf companies., served. The suggestion that they were being used to launder" the money is charmingly naive. One would hardly use the bank, the same branch and the same named official for a succession of companies and then transfer all the money to the account of another company within the same branch if one was seriously attempting to conceal anything. Further, to transfer the money to a trading company in France where it was under constant review by the exchan'o control authorities and could only be repaid back along the route by which it had come must be a fairly novel way of doing things. Besides, apart from the small economy of Tunisia, it does not have traditional trading links with the United Kingdom and these payments would have stood out even within Lloyds International let alone the Banque du Sud.

10. Mr Jackson claims (27.11.89) that the arrangements he made were “to avoid the ownership of the money being drawn into the French exchange control net". Shortly after, he describes it as a "scheme to circumvent Tunisian exchange control, (of course, it may have been both). Mr Jackson is however adamant that he had no reason to believe that the arrangement was illegal or constituted evasion (9.10.89). "The use of a company outside a jurisdiction to hold monies or other assets as a protection against exchange control, capital taxes or death duties in another is quite common (J 4.1.90).

Who was the Client?

11. Mr Jackson claims (4. 1. 90) that he acted throughout on the instructions Mr Humphrey, an employee of Grant Thornton who first approached the firm in April 1983. The National Managing Partner of Grant Thornton's version is entirely different:

After Roger Humphrey joined my Firm (November 1982) he informed Monsieur Coulon that my Firm did not do the sort of work previously carried out by Minets/Tyndalls (because we did not have the facility to administer companies off shore). However, Barry Jackson did and Roger Humphrey therefore introduced Coulon to Barry Jackson. Thereafter, although Roger Humphrey did some minor work and rendered fee notes to the company(s) concerned in respect of it, he was always working on the basis that Monsieur Coulon was Barry Jackson's client and he was acting only as liaison between them – as required by Monsieur Coulon to the knowledge of Barry JacksQn.(GT 13.5.91 - not for release).

12. Mr Jackson states (27.11.89) that he had no engagement letter because
of the view he took that ' as a director and liquidator of companies,
such a letter was not appropriate.

Discussion

13. With certain minor exceptions mentioned above Mr Jackson has told a consistent story throughout: he had been instructed to set up a complicated arrangement to transfer money from Tunisia to Paris, avoiding, but not evading, exchange control. He checked the story he had been told and received assurances from a French lawyer as to its legality. As to whether Mr Humphrey or Monsieur Coulon was the principal we have no means of determining but Mr Jackson's version is at least corroborated by Mr Griffin.

14. In my view the findings of the judge in the Chancery Division are of no use to the Investigation Committee because they were arrived at without hearing evidence from Mr Jackson or his co-defendant. Nor can the Investigation Committee rely on the presumption that, by failing to give evidence, Mr Jackson acknowledged the weakness of his case.

15. No guidance was available at the material time to members of this Institute against the dangers of money laundering. Indeed, the only guidance I can trace. was issued to banks and building societies in December 1990.

16 . It has been put to me by the Secretary of the Investigation Committee that, given the tortuous nature of the arrangements Mr Jackson was involved in making, any honest accountant must have realised that they were at least improper and probably illegal. This was certainly the judge's view, albeit without hearing Mr Jackson's version of
events. I am far from satisfied that such a submission would be accepted by the Disciplinary Committee. To establish liability on this basis the Investigation Committee would have to prove two things.

17. First, they would have to prove that an Isle of Man chartered accountant faced with instructions such as Mr Jackson received in 1983 ought to have realised that the arrangements were in pursuit of an end which he could not ethically support. I am far from convinced of the implications of Mr Justice Millett's comments concerning secrecy or of the weight which Fox ' L J placed on the word 'circumvention". Many chartered accountants' clients wish to undertake secret financial arrangements for a variety of reasons which need not necessarily be dishonest. Mr Jackson claims and we cannot disprove that he made enquiries and received assurances. To secure a finding of guilt the Investigation ' Committee would have to show that those enquiries and assurances were" either inadequate or did not take place.

18. Secondly, it would be incumbent upon the Investigation Committee to show, not only that Mr Jackson failed to make adequate enquiry, but that the arrangements which he made were in pursuit of an unlawful or at least. improper end.

19. Whatever we may speculate, there are only two possible scenarios to explain the reason for the transfer of these monies; either they were a form of money laundering to dispose of stolen property or they were an exchange control fiddle. The arguments put forward by Messrs Jackson and Griffin against this being a money laundering exercise look convincing and the only evidence of theft available to the Investigation Committee is the conviction of Mr Zdiri by a Tunisian court, a fact which could easily be explained as part of the AGIP conspiracy. Mr Jackson's own account is that this was an exchange control fiddle, but a lawful and not an unlawful one. To prove otherwise the Investigation Committee would have to obtain the exchange control regulations of the country in. question and show exactly how they had been infringed. It may be that members of the Committee have sufficient expertise to be able to judge whether the arrangements in question were such as would be likely to be adopted by someone engaged in evading exchange control, but to someone unfamiliar with these activities the case is not convincing.

20. Finally, it should be borne in mind that,. whatever the Investigation Committee Is case might be, it would have to prove it, not on the ordinary balance of probabilities test, but to the same high standard as rests on the prosecutor in a criminal case.

21. I realise that it may be tempting for the Committee to take the view that, Mr Jackson having allowed himself to be involved in some very dubious arrangements, he ought to be sent to the Disciplinary Committee to explain himself. This is a particularly beguiling approach given the public criticism to which the Institute has been and continues to be exposed for its apparent inaction. However, the Bye-laws do not work that way. If Mr. Jackson has to explain himself it is to the Investigation Committee, not the Disciplinary Committee. At the Disciplinary Committee Mr Jackson should be entitled to say to the panel: "It is not for me to prove my innocence, but for the Investigation Commit-lee to establish my guilt beyond reasonable doubt”. If, as he would assert, the evidence did not establish a case to answer no responsible lawyer acting on behalf of Mr Jackson would allow him to give evidence or c411 witnesses and possibly convict himself out of his own mouth The inevitable consequence is that the complaints would have to be dismissed.

Advice

22. A formal complaint should be preferred only if it can be proved that
(a) the arrangements Mr Jackson was involved in must have been illegal on any reasonable interpretation of the evidence available; and (b) he knew or ought to have realised this fact, either when he first became involved in these arrangements or at any stage subsequently while he still pursued them.

23. I do not believe that the Committee can yet be confident of proving either of these and I recommend that further enquiries be made under Bye-law 80(a), either in writing or by oral examination of the members concerned. In particular the Committee should attempt to discover or obtain:

(a) more information as to the principal/client relationship between Mr Jackson and Mr Humphrey and how Mr Jackson was remunerated, including copy :Invoices :Eor his services;

(b) the letter of 14th August 1984 from Mr Smyth of Knapp Fishers referred to by Millet i indicating that Mr Jackson was concerned at the Possibility that AGIP might obtain disclosure of Lloyds Bank's records, discover what had happened to the money and try to recover it;

(c) the minutes of the first meeting of the directors of KEELWARD Ltd on 22nd March 1984 suggesting that Mr Jackson thought that their clients were engaged in evading Tunisian exchange control (per Millet J);

(d) the reasons for the inconsistencies in Mr Jackson's accounts (para 7 above);

(e) whether there is any corroboration of the assurances Mr Jackson claim to have received as to the legality of the arrangements;

(f) whether Mr Jackson was aware of Mr Griffin's doubts of 1984 (para 8 above); and

(g) why Mr Jackson participated in what he claims to have regarded as purposeless exercise of setting up and liquidating seven shelf companies.

B T Harris
Director
(18.11.91)

ANNEX A

Edward BOWERS FCA Mr Jackson's partner. and defendant to the
AGIP suit.

John BOTTING Barrister and former principal Inspector of
Taxes (J 4.1.90). A director of Tyndall bank (J 15.6.89).

Yves COULON A French lawyer assassinated 1991.

Richard FREEMAN An expert witness for Jackson & Co criticised by Millett J.
,(Sometimes described as
Jonathon Freedman)

Ian D GRIFFIN A non-member employee of Jackson & Go and codefendant to the AGIP suit.

Sophie Ben HASSINE Claims to be the grand-daughter of the Bey of
Tunis.

Roger HUMPHREY Former Minet employee. Went to Tyndall taking work with him, thence to Thornton Baker. (Now Grant Thornton).

David R JOHNSON Coopers' Jersey partner and engagement partner for the audit of AGIP.
1
Philip MONJACK Of Leonard Curtis was liquidator of 8 of the
companies (AA 11.5. 89).

Frederick NEWTON Former partner of Jackson & Co.
WEDLAKE BELL Solicitors to the defendants at the trial.

ZDIRI Chief accountant of AGIP subsequently imprisoned by a Tunis court for fraud on his employer.

BTH/SL
14.11.91

ANNEX B

THE COMPANIES INVOLVED,

AGIP (Africa) Ltd The Jersey registered subsidiary of the Italian State Oil Company. AGIP was audited by Coopers & Lybrand, Channel Islands. As to its report for the year ending 31.12.84 see Wedlake Bell 27.2.91 and Herbert Smith29.4. 91.

Baker Oil Services Ltd The "shelf,' company through which the last
payment of US $ 500,000 was paid in 1985.

Banque du Sud A Tunis bank at which AGIP held a US dollar account and from which payments were made overseas.

Euro-Arabian
Jewellery SARL This was a company registered-in England which subsequently became Kinz Joaillier (i 27.11.89).

Kinz Joailler SARL A French company through which most of the payments were channelled. Said by the judge to be a wholly owned subsidiary of Euro-Arabian.

Sogine SA Sophie Ben Hassine's French company.

Windlist Ltd The first of the "shelf,' companies concerning which Mr Jackson first met Mr Humphrey.