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Margaret Snowdon OBE, 
Chair of the UK Pensions Scams Industry Group (PISG),
is a campaigner who has worked for many years to prevent pension
scams, protect the interests of those affected by them, and for
positive reform in the industry.

She recently visited Guernsey, where she addressed
Guernsey Association of Pension
Providers (GAPP) to talk about her work and Guernsey’s
involvement with PSIG.

In this blog for WE ARE GUERNSEY, Margaret discusses
the definition of a scam, how to spot the tell-tale signs and how
Guernsey is also playing its part in protecting pension holders
from scammers.

PSIG was set up in 2014 as a voluntary body to combat pension
scams through the publication of good practice in due diligence for
trustees, providers and administrators. Its Pension Scams Industry
Forum (PSIF) was established to share intelligence on scam threats
and trends with industry and regulators. 

It is important to understand the difference between fraud and a
scam. There are several types of fraud, including internal,
service, cyber and identity fraud. But the main difference is that
fraud targets the pension scheme or provider, whereas a scam
targets the individual member via an offer that involves deception,
misrepresentation or omission in order to encourage a transfer from
an authorised pension scheme into one that is unauthorised, or even
a bogus or clone one.  

Figures show that £60bn-worth of transfer values were
requested from Defined Benefit schemes in 2018. We believe as much
as 5% of that value was likely to be scams. Scams affect around
10,000 people a year at an average of £85,000 per victim
– it’s robbing people of their life savings. Fifty
percent of people don’t recognise a scam, so it is vital to

There are some tell-tale signs, or flags, to help potential
victims recognise a scam, which are set out in PSIG’s Code and
which have been carried into recent UK government regulations.
‘Amber flag’ indicators include the fees being high or
unclear in the receiver scheme; the investments being high risk,
unorthodox; incomplete or incorrect responses to member requests
for information; there being overseas investments in the receiving
scheme; and no employment link for the supposed Occupational
Pension Schemes (OPS) or residency link for supposed Qualified
Recognised Overseas Pension Schemes (QROPs). 

In these cases, guidance from MoneyHelper is
required before a statutory transfer can be made. MoneyHelper is a
specific impartial pensions guidance service, offered for free by
the UK Money and Pensions Service.

The more severe warning signs, we refer to as ‘red
flags’. These include advice coming from an unauthorised
independent financial adviser; the person making contact failing or
refusing to provide requested information, pressure being applied
to the member, or the initial contact being unsolicited altogether.
In such cases, there is no statutory right to transfer, so the
request may be refused and reported to the relevant

GAPP has been involved with PISG since its inception and is also
involved with PISF, mainly for its expertise on overseas transfers.
Information sharing is one of the critical ways you can defend
against scams. Guernsey knows how to spot a potential scam and
where trends are going as much as anyone else. To share that
information is invaluable. PISG’s push to change UK transfer
rights and give trustees greater say in stopping scams was
strengthened by Guernsey’s different approach. 

It was suggested during my presentation in Guernsey that we
should explore the idea of a database of trusted schemes – a
universal clean, green list – with a quality mark issued by
the regulator so individual investors can check before becoming
involved. PSIG has already put its mind towards this but it is
actually quite hard to do. It would change and evolve so much, so
keeping on top of it would require quite a huge effort. There is
also a risk that comes with trying to focus on a list of ‘bad
guys’ – you have to be careful because data protection
regulations mean that even scammers can ask what data you hold, so
it needs to be factually accurate to avoid being sued. The industry
does need to get together on this because there will be a

The UK and Guernsey have a number of common areas and ideas to
explore further and I look forward to it. It is very encouraging to
see the interest in Guernsey in protecting pension members from


Left to right: GAPP President Stephen Ainsworth, PSIG Chair
Margaret Snowdon, GAPP Vice President Roger Berry.

For more information about Guernsey’s finance industry
please visit

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.

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