MR MOHAMMAD NADIM ALAM

Disqualified from

2021-11-17

Date of birth on record

November 1968

“Between 11 August 2014 and 29 December 2014, Mr Mohammed Nadim Alam (“Mr Alam”) allowed Smarttrades (Wales) Limited (“STW”) to participate in transactions which were connected with the fraudulent evasion of VAT, such connections being something which Mr Alam should have known about. HMRC denied zero-rating of STW’s supplies in the VAT periods ending 30 November 2014 and 28 February 2015, and raised assessments of VAT totalling £1,397,774. ANNEX Mr Alam was aware of, or ought to have been aware of, VAT fraud in the trade sector in which STW was engaged by 24 July 2014 at the latest, because: • On 19 June 2013, HMRC visited STW and issued a copy of VAT Notice 726 and its leaflet “How to Spot Missing Trader Fraud”; • On 01 July 2013, HMRC issued a letter to STW warning of the risk in using Alternative Banking Platforms, describing MTIC VAT fraud, the need to conduct “know your customer checks” and informing of Notice 726. • On 18 July 2014, you were present during a visit conducted by HMRC where STW’s wholesale trading in mobile phones was discussed. • On 24 July 2014, HMRC issued a letter to STW warning of the risks associated with MTIC VAT Fraud and the need to conduct “know your customer checks” and informing of Notice 726. The trading in which STW was involved had features which should have put, Mr Alam on enquiry about the legitimacy thereof, because: • STW embarked on trading in mobile phones, which was different to its normal trade in clothing, and in doing so was able to generate a very high turnover, with STW conducting sales of mobile phones of at least 9.4 million Euros in the period between 24 July 2014 and 29 December 2014. • STW conducted a number of transactions on a back to back basis, that is, the mobile phones purchased were all sold on in the same quantity without STW being left holding any stock and the transactions being conducted within a short period of time. • The mobile phones were delivered to a freight forwarder in Poland rather than to STW’s customer based in the Czech Republic. • STW utilised a Latvian bank for its mobile telephone transactions; Despite being aware of STW conducting wholesale trading in mobile telephones and having knowledge of VAT fraud in that trade sector and STW engaging in transactions bearing the features of such fraud, Mr Alam failed to take every step that could be reasonably undertaken to prevent STW’s participation in VAT fraud, because: • Mr Alam allowed, STW’s trading in mobile phones to be conducted by a third party who HMRC established to have been a director of a Company that had previously been involved in MTIC VAT fraud. • Mr Alam relied on the same third party to undertake due diligence checks on STW’s behalf. • There is no evidence of any due diligence checks being undertaken, or any formal written contracts being entered into, with regards to the trading partners involved in STW’s mobile phone transactions. • HMRC’s letters to STW dated 01 July 2013 and 24 July 2014 advised STW to verify the VAT status of its customers and suppliers in respect of each transaction with HMRC’s Wigan Office. STW did not carry out any such verifications. • STW conducted the sale of mobile phones totalling at least 9.4 million euros to a customer, which HMRC found to have been established on 21 January 2014 and whose business activity was described as “real estate activities”. STW’s mobile phone transactions conducted in its 11/2014 and 02/2015 VAT periods were connected with the fraudulent evasion of VAT, with HMRC able to trace STW’s transaction chains through its customer (based in Czech Republic) to defaulting missing traders (based in Poland).”