Open Letter To The Insolvency Service: Response to the Warning and Notice of Disengagement

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If you are new to our work at Lighthouse Global and want to know why the Establishment attacked us, click below to read a statement from our CEO and founder, Paul S. Waugh.

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Attn: Duncan Beach: Chief Executive, the Insolvency Service Board, the Official Receiver, the Deputy Official Receiver, and all relevant decision-makers

Due to the severe effects on the health of Mr Waugh, Mr Nash and Mr Cooper, these matters and all matters moving forward have been taken over by the advocacy group Citizen Intervention Global. It was in fact not Mr Waugh who was involved in the letters that you ashamedly felt so threatened by, but they were produced and sent on his behalf through this advocacy group.

Citizen Intervention Global is an advocacy group and interventionist body. One of the principal purposes of the group’s involvement is to bring reach, structure, public leverage, and wider public-interest scrutiny to these matters, while ensuring that citizens, voters, public officials, oversight bodies, and other affected persons are properly alerted to the situation.

This is a formal and public response to your letters dated 9 January 2026 and 16 April 2026.

We are challenging your purported notice of “disengagement” from Lighthouse and Mr Waugh. You have attempted to place Mr Waugh’s correspondence within your “Unreasonable Individual Behaviour” guidance. You have then foolishly, recklessly, and without proper particularisation, alleged that:  

1. threats had been made; 
2. repeated contact had been made about the same or similar issues; and
3. points allegedly already responded to were being argued again with no new evidence.

Your correspondence is rejected in its entirety!!

The cowardly act of institutional avoidance is rejected on the basis that it does not address and answer the compelling evidence of your corruption, your incompetence, your criminal cover-ups, your provable and evidential lies, and heinous avoidance of the truth and accountability. Your answer to this process of correcting the falsified record and accountability is to disengage. That tells the public everything it needs to know.

If the Insolvency Service, and the individuals responsible for this abomination, were truly on the right side of truth and law, you would not run from scrutiny. You would stand by your convictions, answer the evidence, particularise your allegations, identify your decision-makers, and correct the falsified record. Instead, you hide behind silence, process, and institutional self-protection. That is not the conduct of an institution confident in truth or law. It is the conduct of an institution hiding from both. 

You appear cowardly to believe that silence will make the problem disappear and that Lighthouse will simply go away. That is childish magical thinking. It will not happen. Your silence does not reduce the consequences. It compounds them. Your avoidance does not bury the truth. It strengthens the case against you.

You cannot run from the truth and the consequences of the truth. You cannot falsify the record, weaponise process, damage lives, and then somehow expect disengagement to protect you from accountability as a publicly-funded agency. Until the truth is vindicated and the public record has been corrected across the board, public accountability won’t stop whether you disengage or not!

The longer you refuse to answer, the worse this becomes for the Insolvency Service, because every silence, every omission, every refusal, and every act of institutional avoidance becomes further evidence of the very corruption, incompetence, weaponisation, and criminal cover-ups now being exposed.

The truth will be vindicated!

It’s not a matter of if, but when, and we are working earnestly to ensure that this happens quickly, comprehensively, effectively and publicly. The public will be educated on the character, conduct, tactics, failures, and institutional abuses of the Insolvency Service and the individuals involved in this diabolical situation. This includes, but is not limited to, Michael Bint, Joseph Sullivan, Gary Seymour, Edna Okhiria, Gareth Allen, Dean Beale, Victoria Prime, Daniel Curthoys, Karen Baldock, and Alec Pybus will be held personally accountable, and there will be no hiding behind the institution and seeking immunity. 

We will expose your criminal cover-ups, corruption, false and pseudo investigations, provably false allegations, institutional incompetence, procedural abuse, and deliberate avoidance of facts, truth and accountability. We will expose how the Insolvency Service has abused process to achieve heinous results, protect reputations, avoid correction of the falsified record, and shield those responsible from the consequences of their conduct. Those days are behind you.

This is now a matter of public record, public scrutiny, and public accountability. The Insolvency Service does not control the truth. It does not control the public record. It does not control the evidence and facts. And it will not control the consequences of what is now being exposed.

1. Disengagement Does Not Close This Matter

Disengagement does not solve the problems that need to be addressed urgently. Correction needs to be made promptly, reforms need to happen, and the appropriate compensation needs to be paid for the damage the Insolvency Service and individuals like Michael Bint and Gary Seymour have caused.   

Disengagement and avoidance do not correct the falsified record and the consequences of that perversion. It does not address the corrupt and pseudo investigation launched against Lighthouse International Group. It does not explain the reliance on provably false accusations by fake whistleblowers and the failure of due diligence on behalf of the Insolvency Service. It does not address and resolve the criminal institutional cover-ups and the weaponisation of state power.  It does not remedy and heal the severe consequences caused to real people, families, livelihoods, reputations, and health.

2. False Allegations Hidden Behind Vague Language

Alongside your avoidance, which you have chosen to label as “disengagement”, and alongside the letters addressed to Mr Waugh, you have failed to particularise the allegations relied upon in this communication. That failure is not accidental. It is the tactic of an institution making allegations it cannot prove and justify.

You accuse, but you do not particularise. You assert, but you do not provide evidence. You label, but you do not substantiate. You criminally and corruptly smear, but you do not prove.

That is precisely what happens when allegations are false, unsubstantiated, abusive, defamatory, libellous, and incapable of surviving scrutiny. If the allegations were genuine, you would identify the exact words relied upon. If the evidence existed, you would disclose it. If the conduct was truly threatening, unreasonable, or abusive, you would quote the passages, identify the dates, name the recipients, explain the context, and state the legal or policy basis for your conclusion.

You have not done so. This omission is fatal!!

The Insolvency Service has attempted to create an institutional finding by assertion alone. That is not evidence. That is not due process. That is not accountability. It is bureaucratic cowardice. It is procedural corruption. It is the familiar conduct of a public body seeking to protect itself from exposure by making broad, defamatory and damaging allegations while refusing to put those allegations to the test.

The position is simple: particularise the allegations or withdraw them publicly. Identify the evidence or admit there is none. Quote the words or stop making the accusation. Prove the allegation or correct the falsified record.

Your disengagement letters do not close this matter. They expose it further.

3. From Disengagement to Re-engagement

You appear to believe that by issuing a bureaucratic warning, followed by a formal disengagement notice, the Insolvency Service can file away the evidence, avoid the pertinent questions and scrutiny, protect senior leadership, and declare this matter exhausted. That is not going to happen as long as we draw breath! This is not a closed matter. It is an open public-interest accountability process.

The Insolvency Service does not get to declare this matter closed while the consequences of its own conduct remain active, damaging, unanswered, unresolved, and criminally covered up. 

Your April 2026 letter claims that the Insolvency Service is “stopping” contact about this matter. That is your choice. Citizen Intervention Global are content to disengage from the level at which engagement from the Insolvency Service in relation to the Lighthouse case was clearly failing. But that does not mean the matter ends. It means Lighthouse is now re-engaging at a higher level, with more evidence, more affected people, more cases, wider public documentation, and a broader exposure of wrongdoing, corruption, cover-ups, lies, weaponisation, institutional abuse, and incompetence. Your disengagement is not the end of accountability. It is now part of the evidence.

Every assertion, omission, contradiction, refusal, delay, and procedural manoeuvre by the Insolvency Service will be analysed and placed on public record. The public has a right to see what has been raised, what has been ignored, what has supposedly been answered, what remains unanswered, and what the Insolvency Service refuses to confront.

4. 114 Critical Questions. Not One Sufficient Answer.

We have published online for the public record, every question asked by Lighthouse and directed to the Insolvency Service. This will include the questions, the dates raised, the recipients, the subject matter, whether any response was provided, and whether that response was sufficient, evasive, incomplete, or entirely absent.

👉 Questions The Insolvency Service Refuses To Answer

By way of overview, and to demonstrate the scale of the Insolvency Service’s non-cooperation, non-compliance, avoidance of scrutiny, and refusal to engage with evidence, Lighthouse has so far identified 114 crucial and critical questions directed to the Insolvency Service in relation to the Lighthouse case.

The position is stark:

questions answered sufficiently  –  0  (0%)

questions answered insufficiently  – 39  (34%)

questions not answered  –  75  (66%)

Answered insufficiently: these are questions where some response, procedural answer, court position, generic policy answer, denial, or partial explanation exists, but it does not directly resolve the substance of the question.

Examples include questions where Michael Bint or the Insolvency Service gave a general or procedural response, such as saying the investigation was conducted according to standard procedures, refusing to take requested actions, saying there was no mechanism for state support, or saying the agency does not hold case-specific court records. In other words, the Insolvency Service may have said something in response, but it did not answer the question asked.

In other words, not one (0%) of the 114 critical questions has been answered sufficiently. This is not cooperation. This is not transparency. This is not accountability. This is not public service. It is institutional avoidance on an industrial scale.

The Insolvency Service cannot credibly accuse Lighthouse of repetition when the reason pertinent questions have had to be repeated is because the Insolvency Service has failed to answer them. Repetition caused by institutional avoidance is not unreasonable conduct by Lighthouse. It is evidence of the Insolvency Service’s refusal to confront the falsified record.

These questions will now be placed before the public so that citizens can see for themselves what was asked, what was ignored, what was evaded, what was answered inadequately, and what the Insolvency Service has chosen not to confront.

You cannot bury this matter through silence and avoidance. 

You cannot filibuster accountability through time, process, exhaustion, and disengagement. You cannot control the falsified public record by controlling your inbox. Your decision to disengage is therefore profoundly damning. It does not close this matter. It further exposes the corrupt and pseudo character of an institution failing against its own Charter, its public duties, and the basic principles of truth, accountability, fairness, and public service.

A public body confident in its position would answer questions and welcome the evidence. It would particularise the allegations. It would correct the falsified record. It would explain its decisions. It would stand openly behind the lawfulness and integrity of its conduct. 

Most of all, an honest public body would be humbled by the reality that it exists to serve the public. Therefore it stands to be corrected by more conscientious and diligent members of the public who care more about truth and service than its own staff.

You have done the complete opposite to what an honest, transparent and responsible public body would do.

You have chosen silence over evidence, avoidance over accountability, disengagement over correction, and institutional self-protection over truth. That is not strength. It is exposure. It is the conduct of an institution that knows the falsified record cannot safely withstand scrutiny.

5. Your April Letter Is Institutional Evasion Dressed Up as Procedure

The April 2026 letter is not an answer. You say matters have already been addressed. Prove it! 

We have evidence proving the complete opposite: that the central questions remain unanswered, the falsified record remains uncorrected, the corrupt and pseudo investigation remains unexamined, and the serious evidence placed before you has been avoided rather than answered.

Identify each point you claim has already been addressed. State when it was addressed. State who addressed it. Provide the document, paragraph, date, recipient, and reasoning relied upon. Identify the evidence considered. Identify the conclusion reached. Identify the person responsible for that conclusion.

If you cannot do that, then your claim that matters have “already been addressed” is not a fact. It is a superficial soundbite parading as institutional self-protection. It is procedural deception. It is an abuse of public office, public trust, and public resources.

Citizens have a right to know when a public institution is failing its Charter, failing in its duties, failing the public interest, and using bureaucratic language to conceal avoidance, incompetence, corruption, and the refusal to correct a falsified record.

The Insolvency Service does not get to mark its own homework, declare itself satisfied, and then file away the evidence without answering it. That is not accountability. That is not public service. That is institutional evasion.

6. You Have Confused Accountability With Unreasonable Behaviour

You say the correspondence repeated the same or similar issues. Prove it. Identify what was repeated, what was new, what was materially new, what was substantially new, and why the later evidence was not relevant. You have not done so. You say threats were made. Prove it.

Identify the exact words, passages, documents, dates, recipients, and context relied upon. A serious allegation cannot be made by vague institutional labelling. It must be particularised.

Robust public-interest criticism of alleged corruption, weaponisation, cover-ups, incompetence, and institutional misconduct is not a threat. Public scrutiny is not threatening conduct. Demanding answers is not abusive. Exposing evidence is not misconduct.

The only “threat” created by this correspondence is the lawful reputational consequence of truth being placed on public record for the world to see..

The Insolvency Service appears to be attempting to reframe public-interest accountability as “unreasonable behaviour”. That is rejected entirely.

Sending evidence-based material to staff, leadership, stakeholders, or public-interest audiences is not inherently threatening, abusive, or unreasonable. If you say otherwise, you must prove it by evidence, not discomfort, embarrassment, or institutional preference.

You rely on an “individual behaviour” policy, yet impose an organisation-wide, Board-level, staff-wide, and third-party restriction. This contradiction matters significantly. 

If this is about individual conduct, particularise the individual conduct.

If this is really about public-interest campaigning, public exposure, institutional embarrassment, or scrutiny of the corrupt and pseudo-investigation, then identify the lawful basis on which a public authority seeks to restrict, ignore, or suppress that scrutiny.

You cannot hide criminality, corruption, cover-ups, lies, weaponisation, incompetence, and institutional misconduct behind an “unreasonable behaviour” policy.

7. The Corrupt & Pseudo Investigation Remains Unresolved

The central issue remains the corrupt and pseudo-investigation launched and pursued against Lighthouse. The Insolvency Service should have conducted proper due diligence on its sources from the outset. It should have tested whether the accusations were legitimate before relying on them, escalating them, weaponising them, and allowing them to cause catastrophic reputational and personal harm.

Instead, serious questions remain unanswered about false whistleblowing, deliberate lies, source reliability, evidence avoidance, procedural manipulation, public-interest abuse, and the use of state power against Lighthouse. The Insolvency Service appears to have reversed victim and offender.

You exercised state power. You relied on provably false accusations. You ignored warnings that these accusations were provably false. You caused severe harm and damage. You allowed the consequences to escalate. Then, when challenged with evidence and direct questions, you labelled the challenge as unreasonable. That is not accountability. That is institutional self-defence and reputation preservation based on avoidance! 

Lighthouse did not initiate this process. Lighthouse is responding to the incompetent and corrupt conduct of the Insolvency Service, the consequences of the corrupt and pseudo investigation, the reliance on provably false accusations, and the damage caused by institutional misconduct, perjury in court by a public official, incompetence, weaponisation, and criminal cover-ups.

8. The Warrant of Arrest & Enforcement Consequences Remain Live

Your disengagement letters do not erase the continuing consequences of the Insolvency Service’s conduct. They do not resolve the unlawful warrant of arrest of Mr Cooper. They do not resolve the procedural unfairness and violation of human rights. They do not resolve the unanswered evidential issues. They do not resolve safeguarding concerns. They do not resolve the severe harm caused to those affected by the corrupt and pseudo-investigation accompanied by criminal cover-ups. 

You cannot maintain the consequences of enforcement while refusing to engage with the evidence that challenges the legitimacy, fairness, proportionality, and factual foundation of that enforcement.

The Insolvency Service created an impossible trap: you punish people for alleged non-cooperation. You then punish them for complying in a way you do not like. You then try to punish them again for over-compliance by labelling evidence-based challenge as “unreasonable”.

That reveals the real issue. This was never merely about cooperation from Lighthouse. It was about totalitarian control, preserving institutional reputation, and avoiding exposure of wrongdoing and criminality.

Every refusal, omission, contradiction, and procedural assertion is now part of the evidential record. You may file correspondence without response, but you cannot prevent that correspondence from being published, analysed, evidenced, and placed before the public.

The Insolvency Service’s real concern appears not to be correspondence itself. Its concern is public exposure.

9. Your Allegation of “Threats” Must Be Particularised

The Insolvency Service has made a serious allegation that threats were made against the Insolvency Service, staff, or third parties acting on its behalf. That allegation is categorically rejected unless and until it is properly particularised.

You must identify:

1. the exact words alleged to be threatening;
2. the document or communication in which those words appeared;
3. the date of the communication;
4. the recipient or recipients;
5. the legal or policy basis on which those words are said to amount to a threat;
6. whether you allege unlawful harm was threatened;
7. whether the alleged threat was referred to police or any safeguarding authority;
8. who made the assessment;
9. who approved the allegation being made;
10. why robust public-interest criticism was treated as threatening.

Public interest questioning and constructive criticism are not a threat. Calling for investigation, accountability, correction, reform, and lawful redress is not a threat. Exposing alleged corruption, institutional wrongdoing, weaponisation, cover-ups, and incompetence is not a threat. 

Surely an organisation that claims to exist for the purpose of maintaining economic confidence should be wholeheartedly committed to those virtues: truth, transparency, accountability, correction, fairness, and public trust. Your conduct evidently shows the opposite. The Insolvency Service cannot claim to maintain economic confidence while behaving in a way that destroys confidence in its own honesty, competence, fairness, and accountability.

Ask yourself this, in the name of public interest, who has cost the British taxpayer more – The Insolvency Service or Lighthouse? The Insolvency Service is so ashamed of that question that it can’t even declare how much it has already spent on pursuing, damaging, and attempting to destroy the lives and livelihoods of the people at Lighthouse. Worse still, this has been done on the back of tabloid hearsay allegations, , from sources whose credibility, motives, context, and alleged evidence the Insolvency Service refuses to properly investigate. 

That refusal is revealing.

This is because you know an honest and transparent investigation of your sources, their motives and their ‘evidence’ with full (not partial) context will irreparably discredit and decimate your reputation and standing expose the foundations of the corrupt and pseudo investigation. It would show the public that the Insolvency Service relied on claims it did not properly test, escalated allegations it did not properly verify, and weaponised state power on a defective evidential foundation.

That is why you avoid the question. That is why you refuse transparency. That is why you hide behind process. Because full disclosure would not protect the Insolvency Service. It would discredit it.

The truth may feel threatening to those who are averse to accountability. That does not make the correspondence unlawful. It makes the institution’s relationship with truth and accountability the real issue.

10. You Must Define “This Matter”

Your April letter says that future communications about “this matter” will not be answered. That phrase is deliberately vague, procedurally abusive, and designed to give the Insolvency Service a blank cheque to ignore anything it finds inconvenient. The Insolvency Service cannot use the phrase “this matter” as a bureaucratic dumping ground for every issue it wants to bury.

Complaint handling, evidence submission, safeguarding concerns, SAR and FOI matters, misconduct allegations, public interest disclosures, court-related issues, whistleblowing concerns, and requests for correction of the falsified record are not all the same thing.

Each requires a proper procedural route. Each requires lawful handling and an appropriate response. 

The Insolvency Service cannot use a vague phrase to avoid everything inconvenient and “threatening” because it exposes its criminality, corruption, misconduct, perjury, weaponisation and false investigations.

Pending review, you must confirm the proper route for submitting evidence relating to:

• alleged criminality;
• alleged corruption;
• alleged cover-ups;
• alleged weaponisation of state power;
• safeguarding concerns;
• SAR and FOI matters;
• misconduct complaints;
• public-interest disclosures;
• court-related material;
• correction of the public and institutional record.

11. The Decision Maker Must Be Identified

Your April 2026 letter is signed anonymously by “Customer Complaints”. That is unacceptable! You have made serious allegations and imposed a serious restriction. A public authority should not hide behind an anonymous departmental sign-off when making accusations of threats, unreasonable conduct, repeated correspondence, and lack of new evidence.

The following must be identified:

1. the person who made the disengagement decision;
2. the person who approved it;
3. the person who assessed the alleged threats;
4. the person who assessed whether the evidence was new;
5. the person who decided matters had already been addressed;
6. the person who considered the correspondence addressed to Duncan Beach;
7. whether Duncan Beach personally read, considered, delegated, or ignored the correspondence sent to him.

If the Insolvency Service stands by these allegations, the responsible individuals must attach their names, roles, evidence, and reasoning to them. Until the responsible individuals are named, the evidence is disclosed, the allegations are particularised, and the reasoning is properly set out, your disengagement letters are null and void in substance. They are not accountability. They are not due process. They are institutional evasion dressed up as procedure.

12. The January Warning & April Escalation Are Procedurally Defective

Your April 2026 letter relies on the January warning. If the January warning was not properly served through the formal correspondence route provided by Lighthouse, then the escalation from warning to disengagement is compromised.

The Insolvency Service’s own correspondence management has been inconsistent and procedurally careless, while wrongly criticising Mr Waugh for his communication conduct.

You cannot impose restrictions while failing to use the workable and monitored correspondence route provided to you on numerous occasions. You cannot rely on your own procedural failures as the basis for escalation.

13. The Review Must Be Genuinely Independent

Your April letter says that the disengagement decision can be challenged by requesting a review by an independent senior manager. We are absolutely challenging this decision and categorically reject it. We demand that this review must be conducted independently.

It cannot be handled by anyone connected to the Lighthouse matter. It cannot be handled by the Official Receiver, Deputy Official Receiver, complaints team, or any person previously involved in the handling, escalation, defence, or consequences of the corrupt and pseudo investigation.

The reviewing officer must be named and the review must identify:

1. the evidence considered;
2. the decision-maker;
3. the criteria applied;
4. the reasoning for each conclusion;
5. the specific passages alleged to be threatening;
6. the basis for saying matters were already answered;
7. the basis for saying there was no new evidence;
8. the lawful basis for extending restrictions to third parties;
9. the safeguarding impact of disengagement;
10. the route by which new evidence, public-interest disclosures, misconduct concerns, SAR/FOI matters, and court-related material can still be submitted.

The Insolvency Service cannot be the sole judge of whether evidence against itself is relevant, new, sufficient, or worthy of response. That is precisely why independent review and public scrutiny are necessary.

14. Public Interest Publication Will Continue

This correspondence is not merely about obtaining a reply from the Insolvency Service. It is about placing evidence, unanswered questions, institutional conduct, provable corruption, criminal cover-ups, weaponisation, procedural evasion, and public-interest concerns on record.

The public has a right to see what has happened. The public has a right to know whether the Insolvency Service answers evidence or avoids it. The public has a right to know whether serious questions about the corrupt and pseudo investigation are investigated or buried. The public has a right to know whether the Insolvency Service acts in the public interest or merely protects itself.

You cannot stop evidence being placed before the public by characterising communication as unreasonable. This is a long-term accountability project. It will not end because the Insolvency Service issues a disengagement letter.

If the Insolvency Service doubles down, scrutiny will increase. If it refuses to answer, the refusals will be documented. If it hides behind process, the process itself will be scrutinised. If it attempts to silence public-interest accountability, that attempt will be placed on public record.

15. Required Action

The Insolvency Service is now required to do the following:

1. Withdraw or suspend the disengagement decision pending independent review;
2. Identify the named decision-maker and approving officer;
3. Particularise the allegation of threats with exact words, dates, documents, recipients, and context;
4. Identify every point said to have been “already addressed”;
5. Identify where those answers can be found;
6. Explain why later evidence was not treated as new, substantially new, or materially relevant;
7. Define precisely what is meant by “this matter”;
8. Confirm the route for new evidence, complaints, SAR/FOI matters, safeguarding concerns, public-interest disclosures, and court-related material;
9. Confirm whether Duncan Beach personally considered the correspondence addressed to him;

10. Appoint a genuinely independent named senior manager to review the disengagement decision;
11. Preserve all records relating to the corrupt and pseudo investigation, disengagement decision, complaint handling, internal discussions, referrals, staff communications, and correspondence management.

In the near future, you will receive a detailed breakdown of the lawful and public steps we are taking, and intend to take, to hold the Insolvency Service and specific individuals accountable.

This includes, but is not limited to, Michael Bint, Gareth Allen, Dean Beale, Gary Seymour, Joseph Sullivan, Victoria Prime, Daniel Curthoys, Karen Baldock, Edna Okhiria, Alec Pybus, and Duncan Beach.

We will exhaust every lawful, evidential, procedural, regulatory, political, and public-interest avenue available to hold the institution and these individuals personally accountable for their wrongdoing, corruption, criminal cover-ups, incompetence, abuse of process, failure of public duty, and the severe damage caused to real people, families, livelihoods, reputations, businesses, and health.

These individuals were entrusted with public responsibilities. They were entrusted with public power and resources. They were entrusted with duties owed to citizens, businesses, the courts, and the public interest.

They have gravely failed those duties and they will now be held accountable, personally and institutionally, through every lawful route available.

16. Final Position

The Insolvency Service may choose disengagement. Lighthouse chooses evidence, public record, scrutiny, correction, reform, accountability, and lawful redress.

The Insolvency Service does not get to declare the matter closed while the harm continues, while the warrant consequences remain unresolved, while the evidence remains unanswered, while the corrupt and pseudo investigation remains unexamined, and while serious allegations are made without proper particularisation.

Your letters do not end this matter. They deepen it!

They show an institution attempting to control correspondence and the falsified record rather than confront evidence, facts, and the truth. They show a public authority relying on ‘tricknicalities’ and abusing the process rather than truth. They show the Insolvency Service attempting to protect itself from the consequences of its own corrupt, criminal, and incompetent conduct.

That will not succeed, and this response is placed on public record.

Citizen Intervention Global, on behalf of Lighthouse Global 

www.citizenintervention.org