The Cold Truth About The 79th Group, the Police, and Your Money

The 79th Group Loan Notes Recovery

Over the past several months, a growing number of investors have come forward, alarmed and confused by what’s happening with their investments in The 79th Group and its network of companies.

Some have received no returns. Others have received vague updates about an ongoing police investigation. Most are still in the dark — unsure what to do or where to turn. And amidst this uncertainty, one deeply problematic belief continues to spread:

“If the police are involved, I’ll get my money back.”

Unfortunately, this assumption could seriously damage your chances of recovering your investment.

Here’s why.

Many investors are conflating two entirely separate processes — both stemming from the same situation, but operating in very different legal arenas:

1. The City of London Police’s criminal investigation into individuals connected with The 79th Group, and
2. The civil legal process of reclaiming funds from the Loan Note issuing corporate entities involved.

While they may appear related, these processes have distinct objectives, operate under different laws, and follow completely different timelines.

Confusing the two is not just a legal misunderstanding — it’s a strategic mistake that could cause investors to miss the opportunity to take meaningful action.

Criminal vs. Civil: What’s the Difference?

Let’s start with the criminal side.

The City of London Police are currently conducting a criminal investigation into suspected widespread fraud involving individuals associated with The 79th Group. Their job is to determine whether any criminal offences — such as misrepresentation, deceit, or fraudulent trading — have been committed.

If sufficient evidence is found, the police will refer the matter to the Crown Prosecution Service (CPS), who will then decide whether to press charges and pursue criminal prosecutions.

This process — from investigation, to charges, to criminal trial — can take several years to reach any resolution. Even then, the outcome is focused solely on criminal accountability.

That means:

• Gathering evidence for prosecution
• Bringing criminal charges against individuals
• Securing convictions, which may result in prison sentences

But crucially, not compensation.

It’s important to understand:

The City of London Police are not trying to get your money back.
Their focus is on identifying and prosecuting criminal behaviour — not on financial restitution for victims.

Even if one or more individuals are convicted, that outcome does not automatically result in financial recovery for investors.

Civil Recovery: A Different Arena — and a More Effective Route

While the police focus on the criminal conduct of individuals, we at Insolvency & Law are focused on the civil recovery of funds on behalf of investors like you.

Our work involves initiating legal proceedings against the companies themselves, including:

• 79th Commercial Three Ltd
• 79th Luxury Living Five Ltd
• 79th Luxury Living Six Ltd
• 79th Resources Ltd (a Gibraltar-based company previously known as Lusso Tesoro Private Fund Ltd and Castle Ventures 4 Ltd)

These are the entities that issued the loan notes and accepted investor funds — and they are the ones we are holding to account through the civil courts.

The advantage of this route is clear:

• We do not need to prove criminal intent.
• We do not need to wait for a criminal investigation to conclude.
• And we can act now, using well-established powers in civil law to pursue your claim.

Legal Thresholds: Why Civil Is More Actionable Than Criminal

Another key difference lies in the burden of proof.

• In a criminal court, the standard is “beyond reasonable doubt.”
  This is a very high bar — it requires a level of certainty that leaves almost no room for doubt.
• In a civil court, the standard is “on the balance of probabilities.”
  This is a much lower threshold, requiring only that it’s more likely than not that the defendant’s actions caused harm.

This distinction is critical. In a civil case:

We don’t need to prove that fraud occurred beyond doubt — only that the company misled investors in a way that caused financial loss.

This allows us to act faster and with greater flexibility — especially in complex, high-value cases like those involving The 79th Group companies.

The City of London Police Won’t Be Giving You Updates

It’s also important to address a common frustration many investors have raised: the lack of communication from the police.

While many investors are eager for updates, statements, or timelines, the reality is this:

The City of London Police will not be giving you updates as the investigation progresses.

Criminal investigations are highly confidential by nature. They are carried out without public commentary, and for good reason — to avoid compromising the integrity of the case or prejudicing any potential trials.

But for investors, this means:

• No regular updates
• No transparency on progress
• No indication of how long the process will take
• And most importantly — no pathway to financial recovery

You could be waiting months or years just to find out whether charges will be filed — all while your window for civil action may be quietly closing in the background.

Warrants Signal Seriousness – But Not a Solution

When the City of London Police execute warrants and forcibly enter properties, it sends a very clear message:

Their investigation into suspected widespread fraud involving The 79th Group is serious, active, and supported by substantial concerns.

But as impactful as these actions may appear, they do not represent a path to recovering your investment.

Police raids, search warrants, and arrests serve the criminal process, not the financial interests of investors. These steps are about securing evidence to prosecute wrongdoing — not returning money to those who have suffered losses.

And yet, many investors remain in a holding pattern, waiting to “see how that plays out.”

This passive strategy is dangerous.
If you wait too long, you may lose your chance to take meaningful legal action — action that could actually result in your money being returned.

Here’s the truth:

While the police pursue their investigation under criminal law, you still have the power — right now — to pursue civil enforcement under civil law. These two legal routes can operate in parallel. One does not need to wait for the other.

Unless a criminal restraint order has been issued to freeze specific assets, the civil courts remain fully empowered to act.

This means that you — and other loan note holders — are not legally blocked from initiating recovery proceedings. You still have a window of opportunity.

But that window is closing.

Don’t Wait – Legal Time Limits and Insolvency Risks Could Close the Door for Good

One of the most important — and least understood — legal risks facing investors right now is the risk of becoming time-barred from taking civil action.

Under the Limitation Act 1980, most civil claims — including those involving:

• Misrepresentation
• Breach of contract
• Negligence

must be brought within six years from the date the wrongdoing occurred — or, in some cases, from when the investor ought reasonably to have discovered that wrongdoing.

If you miss that legal deadline, your claim may be permanently barred, even if you have a strong case and even if the police later secure criminal convictions.

In other words:

Time is not on your side.

And the situation with The 79th Companies only makes matters more urgent.

The Reality of Insolvency: Assets vs. Obligations

Let’s be blunt: The 79th Companies are hopelessly insolvent.

We say that they have issued loan notes worth multiple times more than the total value of their reported assets. Their own balance sheets — limited and unaudited as they are — paint a dire financial picture.

This is not a company experiencing temporary cash flow issues. This is a group of companies that:

• Cannot meet their debt obligations
• Are unlikely to ever repay most loan note holders
• Have more liabilities than they do assets to cover them

In fact, the reality is even more stark:

The vast majority of investors will not recover their money unless they act quickly — and on a first-come, first-served basis.

The assets available for recovery are limited. And in insolvency, funds are distributed according to legal order and timing — not sentiment or fairness.

Investors who act now, through a civil process, may still recover part or all of their investments. Those who wait, hoping the police investigation will lead to a resolution, risk being left behind — and at the back of the queue.

A winding up petition has already been filed against 79th Luxury Living Five Ltd. This is not a hypothetical threat. The formal insolvency process is already in motion.

The clock has started ticking.

In Summary: Time Is Your Enemy — Not the Police

The police investigation is serious and necessary. But it is not your solution.

You cannot rely on criminal justice outcomes to secure your financial recovery. They are slow, uncertain, and focused on punishment — not restitution.

Civil recovery is your only viable route to get your money back.

• Civil recovery and criminal investigations can run side by side, with different goals and different legal powers.
• Police are focused on criminal prosecution; civil action is focused on financial recovery.
• Unless assets are frozen under a criminal restraint order, civil recovery can proceed unimpeded.
• Funds recovered via civil action do not get recalled as “evidence” once legally distributed to investors.
• Insolvency practitioners and the civil courts have strong powers to trace, secure, and distribute funds — regardless of the status of a criminal investigation.
• Waiting for the police investigation to conclude may leave you legally time-barred from taking civil action.

Still Holding Out Hope?

If you’re one of the investors who still believes The 79th Companies might recover and resume payments — we understand. It’s difficult to accept that what was once presented as a safe, fixed-income investment has unravelled into silence, unpaid interest, and investigations.

But let’s be clear:

The facts don’t support the hope that The 79th Group will come good.

We urge you to look closely at the financial and structural realities behind these companies. Let’s revisit some of the key facts we’ve previously published — and why relying on The 79th Group to fix this situation is not a recovery strategy.

The 79th Group Companies: A Pattern of Financial Instability

A deeper investigation into the structure and filings of the 79th Companies reveals a troubling trend. While accounts may have been filed on time, the figures tell a story of systemic instability:

• The majority of trading companies under the 79th umbrella are balance-sheet insolvent — in some cases by millions of pounds.
• According to Section 123(2) of the Insolvency Act 1986, a company with liabilities exceeding its assets is legally deemed insolvent. This applies to The 79th Companies.
• Just six companies report any positive balances — and even those amounts are negligible (£1, £2, £90, £100).
• None of the companies have submitted a profit and loss statement.
• None of the companies have submitted independently audited accounts — raising serious concerns about transparency.

Worse still, the companies claim that they have paused interest and redemption payments due to the ongoing police investigation into suspected fraud. But this explanation doesn’t align with insolvency law.

Failing to meet debt obligations when they fall due is a clear indicator of cash-flow insolvency, as also defined by Section 123(1)(e) of the Insolvency Act 1986.

Put simply, these companies are now trading while insolvent — both on paper and in practice.

Are the Police Being Used as a Shield?

We believe that the directors of The 79th Companies are using the City of London Police investigation as a convenient excuse to justify their suspension of payments.

But this is not about waiting for legal clarity — it’s about a group of companies that are unable to meet their liabilities, with insufficient assets to cover obligations, and no realistic prospect of paying out to all loan note holders.

The Scale of the Loan Note Exposure

Let’s examine the numbers. The total value of loan notes issued by The 79th Companies is staggering:

• 79th Commercial Three Ltd – up to £25 million
• 79th Luxury Living Five Ltd – up to £37 million
• 79th Luxury Living Six Ltd – up to £500 million
• 79th Resources Ltd – up to €192 million

These figures represent the maximum potential exposure to investors. They are backed, allegedly, by assets — but so far, there is no credible indication that such assets of matching value exist.

Spotlight on 79th Resources Ltd

A special note must be made about 79th Resources Ltd. This is a Gibraltar-registered entity, previously known as:

• Lusso Tesoro Private Fund Ltd
• Castle Ventures 4 Ltd (name changed on 22 March 2021)

The Castle Ventures brand is historically associated with Steven Knight, indicating that this entity may have played a much deeper role than simply providing trustee services.

It’s worth noting that Castle Trust and Management Services Ltd (CTMS), also linked to the same
brand and which stood as the previous Trustees for various 79 th Loan Notes, is now in liquidation,
having provided Trustee services to High Street Grp Ltd Loan Notes. Losses for Loan Note Holders in
this company run in excess of £126 million with no action taken by CTMS in their capacity as Security
Trustee..

The presence of these offshore, rebranded, and liquidated entities further undermines confidence in the structure and integrity of The 79th Companies.

Loan Notes “At Large” vs. Asset Coverage

Our current estimate of loan notes “at large” issued across these entities is:

• Up to £562 million
• And up to €192 million

While these loan notes have been formally charged at Companies House by the appointed trustees, there is no corresponding evidence that assets of sufficient or significant value exist to support them.

In our professional opinion, The 79th Companies have sold several times more in loan notes than they have in actual assets.

Weaknesses in the T&T Debenture Deed

To better understand the level of protection offered to investors, Insolvency & Law conducted a detailed review of a Debenture Deed lodged by T&T Trustees for 79th Luxury Living Six Ltd.

The findings were — frankly — alarming.

This key legal document, which should provide security to loan note holders, is riddled with weaknesses:

• Lack of Specificity in the charge details
• Weak Protective Covenants, providing minimal safeguards
• Limited Oversight or Accountability from the trustee
• Ambiguous Legal Language that creates uncertainty about enforceability
• Certification that offers no real protection in practice

We examined this in full in a previous blog, but in summary:

The deed is structurally flawed and provides little to no practical protection for investors.

What Needs to Happen Now

In the interest of transparency and fairness to investors, The 79th Companies must immediately:

1. Publish a full schedule of loan notes in circulation
2. Disclose a corresponding asset schedule
3. Clearly identify which assets are fixed, and which are secured to the loan notes

Until this happens, confidence cannot be restored — and inaction only increases the risk of further losses.

Who Are Insolvency & Law?

We are debt recovery specialists with 17 years’ experience, as verified by Companies House. Our team focuses exclusively on helping individuals and groups recover lost money, investments, and assets from insolvent, collapsed, or mismanaged entities.

Some of our most notable results include:

• A £6.5 million settlement against auditors of an insolvent insurance company
• A £24 million group settlement following the collapse of a bond-selling insurance business
• £7.5 million recovered for 148 investors after a property group failure, linked to a third-party claim of £13 million against three law firms
• 100% recovery of a £1 million claim for a group of 12 investors via an appointed insolvency practitioner
• An ongoing group action for DeTrafford apartment purchasers, due to settle this year
• Further third-party actions in progress and due to commence in the coming months

What Is Insolvency & Law Doing Now?

We are leading the civil recovery effort on behalf of loan note holders affected by The 79th Companies.

While the City of London Police pursue criminal accountability, Insolvency & Law is taking direct legal action to pursue financial recovery — and fast.

We have already issued a Pre-Warning Letter Before Action via The 79th Group legal representatives, JMW Solicitors LLP. This is the first formal step in pursuing recovery through the civil courts.

What Does the Recovery Process Involve?

Our legal strategy is multi-pronged, including:

• Analysing loan note agreements for breaches or misrepresentation
• Filing civil claims for mis-selling, breach of contract, and deceit
• Recovering available assets through court action or liquidation
• Exploring negotiated settlements where viable

What Civil Enforcement Options Are Available?

Where appropriate, we will pursue powerful legal mechanisms such as:

• Appointing an insolvency practitioner (administrator or liquidator)
• Bringing Third-Party Actions against regulated firms that enabled investor losses
• Filing misfeasance claims against company directors
• Tracing and recovering assets through civil enforcement
• Challenging suspicious transactions under:\n – Section 238: Transactions at undervalue\n – Section 239: Preferences

Our approach is proactive, structured, and laser-focused on one thing:

Financial recovery for investors.

We are not waiting for criminal prosecutions to conclude. We’re acting now, using the full scope of civil law.

Final Warning: Don’t Wait for the Police — They Can’t Return Your Money

There is a persistent — and harmful — misconception among investors in The 79th Group and Companies:

“The police are investigating, so I’ll get my money back.”

That is not how it works.

The City of London Police are pursuing a criminal case. That case may — or may not — result in charges. If it does, it may take years to resolve. And even then, you won’t be compensated through it.

Your best — and only real — chance to recover funds is through civil action.

And that is exactly what Insolvency & Law is facilitating right now on behalf of investors.

But time is critical. If you delay, you could miss the legal deadline to bring your own claim. And if that happens, your right to recover anything at all could be lost forever.

We understand this is overwhelming. But waiting is not a strategy — it’s a risk.

Act now — before it’s too late.

What You Can Do Now

If you are a loan note holder affected by The 79th Companies’ suspension of payments:

You must act quickly.
Delays will further reduce your ability to recover funds or protect your legal rights.

If The 79th Group or Any Company Owes You Money…

Whether it’s The 79th Group or any company refusing to repay a legitimate debt, you don’t have to navigate this alone.

Our team can help you assess your position and take swift action to secure what you’re owed.

Reach out to us at: [email protected]