A forensically verified £97M+ claims pool against Wincham International Limited — 1,564 identified victims across 782 confirmed companies. Thousands of innocent British retired couples, bled dry of their savings by Wincham's mis-sold offshore property scheme. We hold the only comprehensive victim database. Here's how we monetise it.
Wincham International Limited sold an offshore company wrapper scheme to thousands of British retired couples buying property in Spain — marketed as a legitimate tax-saving structure. The advice was negligent, unauthorised, and Brexit made it catastrophically fail. Victims are entitled to recover losses averaging £108,000–£170,000 each. The total claims pool tops £97 million. We hold the map to every single one of them.
Four independently powerful heads of claim attach to every victim in the database. A CMC picking up this brief gets a pre-packaged litigation dossier — common facts, shared defendant, quantified losses per claimant.
Wincham owed a duty of care when advising on tax structuring. They failed to advise on the catastrophic consequences of Brexit on their offshore wrapper scheme. The three-stage Caparo test — duty, breach, foreseeable loss — is satisfied on every client file.
Mark Roach and Wincham International held themselves out as qualified tax and legal advisers. They held no qualifying credentials — making all paid advice potentially unlawful under the Legal Services Act 2007 and the Solicitors Act 1974.
Wincham actively marketed the scheme as a lawful, HMRC-compliant tax-saving structure. This was false. Each victim has a statutory misrepresentation claim giving rise to rescission, damages, or both under the 1967 Act.
The 6-year limitation clock runs from the date of knowledge — not the scheme setup date. For most victims, the crystallising event (HMRC penalties, forced MVL costs) only occurred post-2020. The window is open right now. It won't be indefinitely.
Phase 1 converts the database to immediate cash via a data licence and a marketing services contract. Phase 2 captures the entire commercial upside by running the FCA-authorised CMC ourselves — cutting out the third-party firm entirely.
Approach an established FCA-authorised CMC. Offer them a Data Licence for the victim database and a Marketing Services Agreement to run all victim outreach. Income in weeks, not years. Ellis's UK entity registers as an Appointed Representative of the principal CMC.
Once Phase 1 is generating revenue and credibility, Ellis applies for direct FCA authorisation as a CMC principal firm. The third-party CMC is cut out. The full 35–40% claims management fee flows directly to us.
The Wincham database is built from Companies House public records and AEAT company filings. This is the same data any solicitor or journalist can access. UK GDPR doesn't prohibit using public records commercially — it requires a documented lawful basis. We have three.
The law is on our side. These are standard, established bases — not edge cases.
Connecting victims of a fraudulent scheme to legal redress is a legitimate interest that overrides individual privacy rights. The ICO explicitly accepts this basis for legal claims databases. A Legitimate Interests Assessment (LIA) is documented and retained.
Once a victim signs a CMC retainer agreement, all data processing under that contract has a clear contractual basis. The Data Licence Agreement activates this basis for downstream CMC processing automatically.
UK GDPR Recital 47 and ICO guidance confirm that data already made public — including Companies House director records — attracts reduced compliance obligations. No special categories, no sensitive personal data involved.
Eight sequenced steps that take the Wincham forensic database from research asset to active commercial revenue. Steps 1–4 are achievable within the first three weeks.
| # | Action | Owner | Timeline | Status |
|---|---|---|---|---|
| 1 | Finalise the victim database Complete victim sheets, verify company data, calculate quantum per victim |
Dean | Week 1 | In Progress |
| 2 | Shortlist 3 target CMCs FCA-authorised specialist CMCs — financial claims or professional negligence focus |
Dean / Ellis | Week 1–2 | Pending |
| 3 | Prepare the CMC pitch deck Brief + victim summary + quantum model. Deliver the opportunity — not the raw data. |
Dean | Week 2 | Pending |
| 4 | Incorporate Ellis's UK CMC vehicle Separate Ltd Co. Ellis as director. Company constitution reviewed by solicitor. |
Ellis | Week 2–3 | Pending |
| 5 | Negotiate & execute Data Licence Agreement Non-exclusive, time-limited. IP retained by Dean. Upfront fee + ongoing royalty. |
Dean + solicitor | Week 3–6 | Pending |
| 6 | Execute Marketing Services Agreement Ellis's UK Ltd → CMC principal. Dean's US entity subcontracted. Revenue split formalised. |
Ellis / Dean | Week 3–6 | Pending |
| 7 | Ellis registers as FCA Appointed Representative Of the principal CMC. Standard AR agreement. Ellis holds the SMF role. |
Ellis + compliance | Month 2–3 | Pending |
| 8 | Begin FCA Direct Authorisation application Phase 2 trigger. Full CMC authorisation under FSMA 2000 s.19. Compliance consultant engaged. |
Ellis (lead) | Month 4–6 | Phase 2 |