A former British Army rifleman, Daniel Pugh, was prosecuted by the Financial Conduct Authority (FCA) and on 7 August 2025 was found guilty of fraud for setting up a Ponzi scheme that netted over £1 million. He is yet to be sentenced.
The FCA's case
Mr Pugh, a 35-year-old from Devon, set up Imperial Investment Fund (IIF) and between 1 March 2019 and 31 August 2020 targeted 238 investors through Facebook adverts. The adverts promised inconceivably high returns of 1.4% a day, 7% a week, or 350% a year.
Mr Pugh was charged on 18 July 2023 with one count of conspiracy to defraud (despite his alleged co-conspirator remaining out of the jurisdiction). The charge alleged that Mr Pugh had made a number of misrepresentations regarding the interest rates offered, trading activity, and profits from the scheme to those willing to invest in it. Mr Pugh reportedly believed the losses were caused by the FCA's intervention and suggested that any fraud was committed by his alleged co-conspirator.
Mr Pugh had reportedly been warned by an employee of the FCA in January 2020 to cease trading after the regulator had discovered IIF was operating without authorisation. At the start of his trial, Mr Pugh pleaded guilty to carrying out unauthorised regulated activity which breached Sections 19 and 21 of the Financial Services and Markets Act 2000. On 8 August 2025, appearing at Southwark Crown Court, Mr Pugh was found guilty of one count of conspiracy to defraud.
Steve Smart, joint executive director of enforcement and market oversight at the FCA, commented, "Mr Pugh deliberately defrauded unsuspecting investors".
The FCA has confirmed it will commence confiscation proceedings in order to recover the proceeds of crime. It has also attempted to contact investors who suffered losses.
Comment
The FCA's dedication to combating financial crime is clear: “Fighting financial crime is a priority for the FCA, and we are committed to holding fraudsters to account.” It successfully brought criminal proceedings against Mr Pugh and has taken action to support investors who were scammed by the Ponzi scheme. The case also shows that the FCA will not be put off cases whereby only one of the co-conspirators is present.