FCA Secures Conviction Over £1.3 Million Imperial Investment Fund Ponzi-Style Scheme

August 13, 2025

FCA Conviction Over £1.3m Imperial Investment Fund Ponzi Scheme

The Imperial Investment Fund was a £1.3 million Ponzi-style scam that lured almost 240 people with promises of up to 350% returns.

Run by Daniel Pugh between 2019 and 2020, it collapsed leaving investors out of pocket and facing little chance of direct repayment.

In 2025, following an investigation by the Financial Conduct Authority (FCA), Pugh was found guilty of one count of conspiracy to defraud. The case serves as a clear reminder of the warning signs investors should watch for and the recovery routes that may be available when a scam like this is uncovered.

What Happened?

Between March 2019 and August 2020, the FCA said that Daniel Pugh operated the Imperial Investment Fund, which he promoted heavily on Facebook as an “investment club”.

Investors were promised ‘impossibly high’ returns of 1.4% per day or 350% a year.

Instead of generating genuine profits, Pugh used money from new investors to pay earlier ones – a classic Ponzi scheme structure.
By the time the scheme collapsed, 238 investors had lost a total of around £1.3 million.

In August 2025, following an FCA investigation, Pugh was found guilty of one count of conspiracy to defraud and pleaded guilty to carrying out unauthorised regulated activity. Sentencing is expected later this year.

How Ponzi Schemes Work

Ponzi schemes are designed to look like legitimate investments. In reality, they rely entirely on a constant flow of new money.
Once fewer people join, the scheme quickly unravels.

In this case:

  • Early participants were paid “returns” from money invested by later victims.
  • The use of Facebook advertising made the scheme highly visible to ordinary investors.
  • No regulated investment activity took place, and there was no legitimate underlying business.

The Warning Signs Investors May Have Missed

This scheme displayed several classic red flags:

  • Unrealistic returns – hundreds of percent in a year is almost always a scam.
  • No FCA authorisation – Pugh was not authorised to offer regulated investment products.
  • Pressure to act fast – urgency can push people into decisions without checking the facts.
  • Vague or complex explanations – the method for generating returns was never clearly explained.

Why This Matters for UK Investors

The FCA continues to warn about scams using online ads and social media.
Fraudsters know how to make offers sound credible and often target people feeling financial pressure, especially in a cost-of-living crisis.

Even savvy investors can be caught out. The best defence is independent verification before you invest.
That means checking the FCA register, looking for warnings, and questioning any offer that seems “too good to be true”.

What To Do If You’ve Been Caught in a Similar Scam

If you suspect you’ve invested in a fraudulent scheme:

  • Report it to Action Fraud and the FCA immediately.
  • Contact your bank immediately to freeze or recall payments if possible.
  • Keep all correspondence, adverts, and payment records.
  • You may have recovery options through:
    • Bank chargeback or Authorised Push Payment (APP) fraud reimbursement schemes.
    • The Financial Ombudsman Service.
    • The Financial Services Compensation Scheme (FSCS) if a UK-regulated firm that has failed is involved, and your claim meets FSCS eligibility criteria.

Can You Claim Through Your Bank?

In some cases, victims of investment scams may be able to recover losses through their bank or card provider.
This could apply if:

  • You made payments directly from your UK bank account (potential APP fraud claim).
  • You paid by debit or credit card (chargeback or Section 75 protections may apply).

Can I Claim Through My Bank For Imperial Investment Fund?

For victims of the Imperial Investment Fund you may be able to claim through your bank if:

  • You sent money to Imperial Investment Fund via UK bank transfer
  • Your payment was sent to another UK bank account.
  • The payment was made after 28 May 2019, and your bank was signed up to the voluntary Contingent Reimbursement Model Code (CRM Code), which provided protections until it was replaced by mandatory APP Fraud reimbursement rules in October 2024.

Outcomes vary case by case, and claims can be escalated to the Financial Ombudsman Service if your bank refuses to refund you. A case review with a specialist can help you assess whether pursuing this route is worthwhile.

How We Can Help

Our team has supported victims of similar high‑profile investment scams in understanding their rights under UK banking rules.

If you’ve lost money in the Imperial Investment Fund or another high-return investment scheme, we can give you a free, no-obligation review to see what recovery options might be available.

  • FCA-regulated claims management company (FRN 829766)
  • Specialists in scam and fraud-related claims
  • Clear, upfront pricing if you decide to go ahead

Important: You don’t have to use us to make a claim. You can go directly to your bank, the Financial Ombudsman Service, or the Financial Services Compensation Scheme yourself for free, if a UK-regulated firm that has failed is involved and your claim meets FSCS eligibility criteria.

If you’d like us to handle it for you after the review, we’ll explain our fees in full before you make any decision. Our standard success fee is 15% + VAT of the gross compensation offered to you, capped at £7,500 + VAT. We’ll also send you our Client Agreement, which sets out exactly how our charges work, including any cancellation costs if you choose to stop your claim before completion.

We can’t guarantee a successful outcome, but we’ll work hard to make the process as straightforward and stress-free as possible.

FAQs

Q: What is the Imperial Investment Fund?
A Ponzi-style investment scheme run by Daniel Pugh between 2019 and 2020, promising investors unrealistic daily and annual returns before collapsing and leaving investors £1.3 million out of pocket.

Q: What is a Ponzi scheme?
A fraudulent investment structure where returns are paid from new investors’ money, not genuine profits.

Q: Can you recover money from a Ponzi scheme?
It depends on the circumstances. If a UK-regulated firm that has failed is involved and your claim meets FSCS eligibility criteria, or if payment routes, such as your UK bank, offer protection, there may be avenues for recovery.

Q: How can I check if an investment is genuine?
Search the FCA register, review the FCA warning list, and be wary of any scheme offering unusually high returns.

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