Impact of Prior Executive Knowledge on the Validity of August 2025 Trading Plans

Overview

On 29 August 2025, four senior executives at NatWest Group each entered into irrevocable trading plans concerning their beneficially owned ordinary shares — marking the first time such plans were executed at the company. These individuals were: Paul Thwaite (Group Chief Executive Officer), Katie Murray (Group Chief Financial Officer), Solange Chamberlain (Chief Executive Officer, Retail Banking), and Keiran Foad (Group Chief Risk Officer). (Keiran suddenly left in mid January 2026 the day after our 6 month review of our main corruption case study focusing on Natwest Group with no permanent successor and he was the main person linked and is now in Portugal). Under the terms of these arrangements, each executive was permitted to sell up to 25 % of their vested shares that were free from regulatory retention requirements. The plans were irrevocable, could not be amended once established, and were structured to allow automatic, regular disposals in accordance with pre‑set terms, with the first possible trading date no earlier than 30 days after the announcement.

However, the legal and regulatory protection afforded by these plans depends entirely on the information available to the executives at the moment the plans were created.

Regulatory Framework

Under the UK Market Abuse Regulation (UK MAR), individuals classified as Persons Discharging Managerial Responsibilities (PDMRs) are prohibited from:

trading while in possession of inside information (Natwest had known about our main case study since Jan 2025), and
arranging for trades to occur while in possession of such information.

An irrevocable trading plan is therefore only valid if it is established:

in good faith, and
at a time when the executive is not aware of material, non-public information that could affect the company’s share price.

Scenario: Evidence of Prior Knowledge

If documentary evidence (see our front page article here and its also worth noting that the first court case was on 3rd November 2025) were to show that senior executives were already aware, as of August 2025, of a concealed scandal or material risk that was likely to become public, the legal status of the trading plans would be fundamentally altered.

In such a case, regulators would likely view the act of establishing the plan itself as the moment of trading intent. Because the decision to sell shares was locked in at that point, the plan could be interpreted as a mechanism to enable future disposals while bypassing the normal prohibition on insider trading.

Types of Evidence Considered Material

Regulators would focus on contemporaneous documentation demonstrating executive awareness, including:

internal risk or compliance reports,
audit findings,
whistleblower submissions escalated to senior management,
board or committee minutes, and
email or messaging records discussing the issue.

For the information to qualify as inside information, it must be:

precise in nature,
not publicly available, and
likely to have a significant effect on the company’s share price once disclosed.

Consequences if Knowledge Is Proven

If it is established that executives possessed inside information when they created the August 2025 plans, several consequences could follow:

the plans would lose their safe-harbour protection,
any subsequent share sales executed under the plans could be treated as insider trading,
and enforcement action could be pursued by regulators, including financial penalties, director disqualification, or, in serious cases, criminal proceedings.

Importantly, the existence of an irrevocable plan would not shield the individuals involved; rather, it could be used as evidence that steps were taken to monetise shareholdings before negative information became public.

Historical Context

Notably, the August 2025 trading plans represent the first documented instance that NatWest senior executives entered into irrevocable, pre-committed trading arrangements of this type. While the company’s 2024 remuneration policy had authorised the mechanism in principle, no prior RNS filings or PDMR disclosures indicate that such plans were previously executed by executives. This underscores that the August 2025 event was unusual in the company’s own history, even if similar structures were already common in the broader banking sector.

How Entities Become Part of Potential Insider Trading

In a systemic institutional failure, the actions of any participating entity—regardless of their specific operational role—can become a functional component of a broader market abuse event. When the entities listed in the update below (Brighton Court, High Court, TLT Solicitors, the Government, Oakley Property, Aston Vaughan, AXA, Nationwide etc) utilize “Strategic Silence,” falsify records, or ignore critical correspondence etc, they effectively act as the physical mechanism that prevents price-sensitive information from reaching the public domain. This collective omission creates an artificial environment of stability that allows corporate principals to execute share disposals based on “Inside Information” that remains hidden by the lower-tier entities. Under the doctrine of “Professional Enabling,” even if an entity claims to act for separate administrative reasons, they can be held liable if their conduct serves as the necessary cover for a market distortion or provides the secrecy required for a coordinated insider trading event.

Read the full story below from our front page story and decide for yourself:

When the UK Government orders a Corruption Review – then appears to abandon it

11 March 2026

The Fall of the Magna Carta: Has the Rule of Law Broken Down in the UK?

For American investors and international observers, the United Kingdom has long sold itself as the global gold standard for the rule of law. It is the birthplace of the Magna Carta, a bastion of common law, and the bedrock of international corporate contracts. But peer behind the velvet curtain of the UK’s property and legal sectors today, and a terrifying reality emerges: the system has not just fundamentally broken down—it has been actively weaponized against the public.

This is not a story about a single corrupt court or a rogue bank. This is a documented case study of total, systemic corruption operating in a state-sanctioned “Grey Zone,” where financial institutions, courts, and government ministries use strategic silence to erase accountability linked to allegations including resident attacks and resident tracking.

We’d love to known Paul S. Atkins (see below) Chairman of the U.S. Securities and Exchange Commission updated rating of the risk of Natwest Group.

Our 2 year primary case study at PropertyCorruption.com maps out a staggering network of complicity that infects every tier of the British establishment. By tracking the precise metadata, structural anomalies, and administrative loopholes these institutions use to hide their liabilities, the sheer scale of the crisis becomes undeniable. When you look at the evidence, the question isn’t whether the UK system is failing; it’s whether a functioning legal system still exists in Britain at all and according to our readers submissions – this case isn’t unique – its typical.

See our latest case study update below and read more about our global mission here.

In complex legal and property management landscapes, accountability often disappears into what can be described as a “grey zone”. This article explores the tactics used by various entities to blur responsibility, utilize regulatory gaps, and maintain strategic silence to shield themselves from legal risk.

Tactics of Evasion

A primary strategy identified in our main case study involves pushing contentious issues into ambiguous territory. By exploiting administrative gaps, these organizations effectively neutralize complaints and shield themselves from the consequences of resident attacks or mismanagement.

Key methods include:

Sudden Personnel Shifts: Moving key figures or debt responsibilities immediately following critical updates.
Bureaucratic Loops: Redirecting inquiries between management agents and directors to ensure no party ever provides a concrete answer.
Strategic Silence: Simply refusing to acknowledge emails or formal questions regarding insurance, service charges, or legal hearings.

Entity Accountability Tracker

The following table illustrates specific instances of these “Grey Zone” tactics observed:

Entity	Action / Tactic Observed
Natwest Group	Following a 6-month update in Jan 2026, the day after the sudden departure of Chief Risk Officer Keiran Foad and a move to Sean Pilcher and more here.
Nationwide	Moved debt from Moorgroup to Zinc Group the day after the Jan 2026 update distribution. Full story here about potential criminal offences.
TLT (who represent Natwest Group)	Maintained silence following the Feb 18 report regarding “Part One” issues. Part Two will contain questions about their hidden contact with Court.
Police	Refuse to specify which crime reports they are referring to in their replies.
Fire Service	See update here
RTM Directors (Sam Arshi, Gerry Bloom, Chris Bradley, Lucy Clow, Andrew Pavli)	They request all contact goes to Oakley Property first, Oakley Property ignores the contact, directors then say that the annual survey says that Oakley responds to most emails. A loop of non accountability that AXA is insuring.
Oakley Property / Moreland Estate	Failure to escalate service charges for 16 months (issued stage one in Jun 2025,stage one in Dec 2025 and faked service charge documents), Moreland claimed service charge management in Feb 2026 but sent statements excluding service charges, then Oakley/Moreland ignored subsequent emails. Key staff involved disappear.
Brighton Court	Refusal to open emails related to a “mystery hearing” on Feb 10, 2026, or answer questions regarding it. Already 60 page N244 on court conduct.
Court Hub	Refuses to maintain email chains or respond to direct questions. They narrowed the remit of questions to a PCOL issue to neutralize the inquiry.
High Court	Stops opening emails after court reported to Police.
AXA	Ignores all inquiries regarding the renewal of building or directors’ insurance and any potential risk.
Veriforce CHAS & Everest Miles Contractors (still being recommended by Brighton College, Harringtons, Macconvilles Ltd, Burgess Hill Girls School, Architekton Architects, and En Architects – further analysis here)	Refusal to provide insurance details. Everest Miles won’t open emails about resident tracking and attacks by their contractors.
Apax	Ignores all emails and potential conflict of interest
Estate Agents	Ignore due diligence.
Ernst and Young	Ignores risk
Virgin Money	After ignoring the emails we sent about the broader situation, they now push towards moving debt to another company – will they also send the context or just sent basic details like their parent company Nationwide?Emails here. 19/3/2026 – They have stopped opening emails and have started calling 6 times a day.

Conclusion

The use of silence and administrative redirection serves as a powerful tool for avoiding transparency. When entities refuse to keep consistent records or “narrow the remit” of a conflict, they successfully move the issue out of the actionable light and back into the grey. This is why the Propertycorruption.com Government Reviews are essential, this case study isn’t a one off – based our reader submissions – it’s the standard approach. See below.

UK Government Reviews

First read about Propertycorruption.com mission and our initiatives here.

The proposed reviews focus on four core entities involved in our primary case study: NatWest Group, Nationwide, TLT Solicitors, and AXA.

This program is part of Propertycorruption.com and our Integrated Governments Initiative (IGI), which will operate a planned three-year cross-border regulatory audit (UK Pilot, Germany, and Switzerland).

Review Structure & Ministerial Oversight

1. The Lead Procurement Integrity Review

Status: ACTIVE
The Cabinet Office has formally responded to concerns regarding the Crown Commercial Service (CCS) legal frameworks and the conduct of supplier TLT Solicitors.
Read details here.

2. The Judicial Process Integrity Review (Pending)

Minister Responsible: The Rt Hon David Lammy MP (Deputy Prime Minister, Lord Chancellor & Secretary of State for Justice)
Scope: TBD.

3. The Banking Supply-Chain, TPRM, & Financial Conduct Review (Pending)

Minister Responsible: Lucy Rigby KC MP (Economic Secretary to the Treasury & City Minister)
Scope: TBD.

4. The Law Enforcement Vetting Review (Pending)

Minister Responsible: The Rt Hon Shabana Mahmood MP (Home Secretary)
Scope: TBD.

5. The Residential Security Review (Pending)

Minister Responsible: The Rt Hon Steve Reed OBE MP (Secretary of State for Housing, Communities and Local Government)
Scope: TBD.

Propertycorruption.com invites formal engagement from the relevant heads to discuss the progression of this multi-jurisdictional review. To ensure the secure and systematic handover of several thousand pages of case-specific documentation concerning NatWest Group, Nationwide, TLT Solicitors, and AXA, it is essential to establish a verified protocol for evidence transfer. Correspondence is requested to determine the most effective channels for the integration of this data into the active Lead Procurement, Law Enforcement, Judicial Process, and Banking Supply-Chain reviews.

Siloed investigations into interconnected financial and legal entities often fail to capture the systemic nature of institutional malpractice, as they treat isolated symptoms rather than the underlying contagion. By integrating the reviews of NatWest Group, Nationwide, TLT Solicitors, and AXA, the Integrated Governments Initiative (IGI) ensures that the “hand-offs” between banking, legal services, and supply-chain procurement are not lost in the gaps of departmental jurisdiction.

Further documents: IGI Global Framework (password protected)

Update:

OPEN LETTER: URGENT REQUISITION FOR EVIDENCE VERIFICATION

To: The Court Manager, Brighton County Court

To: Crown Commercial Service (Investigation Team – Review ****)

Date: 9 March 2026

RE: VERIFICATION OF HEARING STATUS – CASE M4PP**** (PHASE 1 EVIDENCE)

To assist us with putting together the first batch of evidence for Crown Commercial Investigation TO20**/02***, we request Brighton County Court to provide email confirmation regarding the status of the hearing for case M4PP**** on 10 February 2026.

Specific Query: Did this hearing occur? If it did not occur, why was it listed on PCOL (Possession Claims Online) and why is it still listed as an active event in the digital record?

Request for Formal Intervention: As Brighton County Court has already refused to clarify this by not opening emails on this topic, we now request that Crown Commercial Service (CCS) makes a formal, high-level request for these details and a full audit of this case file.

We could wait months for further stonewalling through standard channels, but as you are aware of the gravity of the allegations—including life-safety threats and systemic fraud—this verification is urgent. We require this confirmation by 10 March 2026.

Update 2:

Open Letter sent as email:

From: Info@propertycorruption.com
Subject: Propertycorruption.com: Update to Front Page Story M4P**** and TO****
Date: Mar 8 2026, at 9:05 pm
To: info@crowncommercial.gov.uk, Brighton County, Hearings hearings.brighton.countycourt@justice.gov.uk

From: CCS Service Desk noreply@crowncommercial.gov.uk
Subject: Thank you for your email – Case ref: 01851174.
Date: Mar 8 2026, at 9:05 pm
To: info@propertycorruption.com

Thank you for your recent enquiry.

Email Subject: Propertycorruption.com: Update to Front Page Story M4**** and TO****/0****

Your case reference is 01****

Update 3:

20 hours later, the email verifying the 10 Feb ‘Ghost Hearing’ remains unopened by Crown Commercial and Brighton Court. So we have Brighton Court continuing to not open emails on the topic and Crown Commercial who only opened our last email after a week when we wrote an article on it.

Update 4:

Oakley Property didn’t hold the quarterly Dec 2025 residents meeting but Annual March 2026 meeting to be held where safety concerns can’t be discussed.

Update 5

10 March 2026 – Crown Commercial and Brighton Court still not opening email from 8 March 2026.

Would Nick Thomas-Symonds MP say that despite a review being granted that the government has decided on joining the corruption? We encourage him to read the latest FCA article here.

Update 6

Should Natwest Group carry on pretending nothing is wrong? Is it business as usual? Are law firms and regulators doing adequate due diligence? From Macfarlanes website:

“Macfarlanes is advising Evelyn Partners, one of the UK’s leading wealth managers, on its sale to NatWest Group plc for a £2.7bn enterprise value. The transaction, which is subject to customary regulatory approvals, is expected to complete in the summer of 2026.
The Macfarlanes team is led by M&A Partner Tom Rose, supported by M&A Senior Associate Steve Siopis, and Associates Helen Connolly, Cassandra Triandos and Will Davison.

The transaction involves a number of teams across the firm, including: Tax Partner Jeremy Moncrieff, Senior Associates Jack Slater and Beth Leggate, and Associate Alec Siegert; Reward Partner Rob Collard, Senior Counsel Mark Petch, and Associate Clio Pialorsi; Pensions Partner Faye Jarvis and Associate Scarlett Yu; Commercial Partner Rosie Duckworth, Senior Counsel Martha Campbell, Senior Associates Alishea Patel and Andrew Hill, and Associates Matthew Bennett and Katie Shingler; Real Estate Associate Russell Fancourt; and Employment Senior Associate Louise Pereira.

Evelyn Partners is a long-standing client of the firm. Other recent mandates have included the sale of Evelyn Partners’ Professional Services business to funds advised by Apax Partners, the sale of Evelyn Partners’ Fund Solutions business to Thesis, the acquisition of Haines Watts’ northern city offices, and the merger between Tilney and Smith & Williamson including Warburg Pincus’ co-investment alongside Permira.”

That Natwest Group and Apax are both involved in our main corruption case study – maybe Tom Rose has questions for us? or is the truth not good for business?

Tom Rose

Update 7

Keiran Foad is now “traveling” in Portugal, see linkedin here.

A common place to choose if he might be considering…

Portugal’s updated post-2024 high value professional residency targets:

Executives, directors, or specialists with high-level management experience
People with significant salaries, stock compensation, or pension streams
Individuals who contribute to strategic economic activity (finance, tech, research, investment)

Keiran Foad:

Former CRO of NatWest Group
Years of senior banking experience
Likely has vested shares and multi-million-pound income streams
Could easily claim “high value professional” status

To claim tax residency, he needs to spend 183 days in the country or show an “intent to stay”. Will be interesting to see if he’s still there in August 2026.

Here are the 3 key ways his “Portugal Pivot” helps him hide from a potential investigation:

1. The “Jurisdictional Delay” (Service of Process)

In the UK, the Serious Fraud Office (SFO) or a civil claimant can serve legal papers relatively easily. Once he is in Portugal, the complexity spikes:

The Hague Service Convention: Any formal “Service of Process” (the delivery of legal papers for a court case) must now go through the Foreign Process Section of the Royal Courts of Justice and the Portuguese Ministry of Foreign Affairs.
The “Translate and Wait” Loop: Papers often need to be translated into Portuguese. Every step of this diplomatic “handover” can take weeks or months.

2. The “Right to Silence” Sanctuary

Portugal’s legal system (rooted in Civil Law) offers incredibly strong protections for the accused, particularly the Privilege Against Self-Incrimination.

3. The “Financial Exit” and Asset Shielding

By establishing himself as a “High Value Professional” in Portugal, he severs his primary financial link to the UK:

The 10-Year Tax Shield: Under the NHR 2.0 (IFICI) program, he can re-structure his wealth into Portuguese “Life Assurance Bonds” or offshore portfolios that are compliant with local law but “opaque” to standard UK forensic clawback attempts.
Clawback Resistance: If a UK court later orders a “Clawback” of his bonuses or shares , enforcing that judgment on assets held in a Portuguese tax-advantaged structure is a nightmare. Portuguese courts generally do not recognize “Punitive Damages,” only compensatory ones, meaning a UK “fine” might be legally unenforceable in Lisbon.

Of course, it might just be traveling but given that Sean Pilcher his interim replacement has refused our full Keiran Foad dossier – we think it could be more.

The first episode titled “The Story of Keiran Foad” of our documentary “Borderless Accountability” will be released May 1st 2026.

Keiran Foad linkedin on 13 March 2026:

Update 8

Macfarlanes rather than asking questions or giving feedback has blocked us. Interestingly, Warburg Pincus’ and Permira ironically are pretending to care about risk analytics with their other ongoing deal…

The Clearwater Acquisition (March 2026)

Deal Value: $8.4 billion all-cash take-private acquisition ($24.55 per share).
The Consortium: Led by Permira and Warburg Pincus, including Temasek and Francisco Partners.
“Go-Shop” Result: Expired Jan 23, 2026; 44 potential buyers were contacted, but no superior bids emerged.
Status: Expected to close H1 2026; HSR regulatory waiting period expired in February.
Objective: To expand “next-generation” risk analytics and front-to-back solutions for institutional investors.

Update 19/3/2026

Entities now stopped opening emails: Fire Service, Virgin Money who have now joined a dozen other entities not opening emails.

Permira and Warburg Pincus’ refused our emails – is that how they manage serious risk?

Update 20/3/2026

An interim major bank CRO is a rare event in the last 20 years:

The only other example was an interim-to-permanent transition at HSBC. Therefore, if NatWest Group does not make Sean Pilcher the permanent CRO within the next month, the Keiran Foad departure will become a black swan event. For NatWest Group, this ‘Black Swan’ would suggest that Keiran Foad’s departure was so abrupt (occurring one day after the release of our six-month review) that no succession plan existed and indicating a potential fear of a permanent replacement.

Entities That Should Deeply Care (The “Contagion List”)

These entities are now “on notice” because an unstable risk function at the top of NatWest threatens their own regulatory standing, deal valuations, or safety.

I. The Deal-Makers (M&A Risk)

Evelyn Partners: Their £2.7bn sale to NatWest is now tethered to a bank with an “unanchored” risk department.
Macfarlanes: As lead advisors on the Evelyn deal, they are overseeing a transaction where the buyer’s risk leadership is a statistical anomaly.
Apax Partners: Having sold businesses to Evelyn Partners, they are indirectly exposed to the stability of the final parent company. Also being exposed through Veriforce ownership.
Warburg Pincus & Permira: As they hunt for “next-gen risk analytics” (Clearwater deal), should they ignore our warnings?

II. The Regulators (Fiduciary Risk)

The U.S. SEC (Paul S. Atkins): Must assess if NatWest’s U.S. interests are being managed by a stable, permanent executive.
The FCA (Nikhil Rathi): The “Senior Managers Regime” (SMR) is designed to prevent exactly this type of accountability vacuum.
The Prudential Regulation Authority (PRA): They oversee the capital and safety of UK banks; a “Black Swan” CRO departure is a direct threat to “Safety and Soundness.”
The Bank of England: As the lender of last resort, they require absolute certainty in the risk leadership of “Systemically Important” banks.

III. The Shareholders & Institutional Investors

The UK Government (HM Treasury): As a major shareholder, the taxpayer is exposed to any “Black Swan” governance collapse.
State Street & BlackRock: Major institutional holders who rely on “CRO Stability” for their ESG and Risk ratings.
Schroders: A top-tier UK asset manager that must justify holding NatWest stock to its own clients.

IV. The “Wrapped” Entities (Narrative Risk)

Brighton College: As the months go by, will this scandal get worse for them?
AXA: As the insurer of these troubled directors and buildings, they are insuring a “Grey Zone”.
Nationwide Building Society: Their CRO Gavin Smyth has known about Nationwide’s exposure for 14 months and his staff are having mental issues due to the cover up stress, why is he still at Nationwide?
Barclays who embeds the law firm at the centre of this scandal TLT Solicitors within their own teams.

V. The Auditors & Forensics

Ernst & Young (EY): If they are auditing NatWest’s risk controls while the CRO is “Interim,” their audit quality is under fire.
PwC & Deloitte: Often brought in for “Section 166” reviews; they know an Interim CRO is a signal of internal distress.
The Serious Fraud Office (SFO): A “Black Swan” departure often precedes the discovery of “Hidden Liabilities.”

VI. The Legal Gatekeepers

TLT Solicitors: Their conduct in the “Lead Procurement Review” is now being overseen by an Interim risk function at their biggest client.

Update 21/3/2026

Example of How Risk Spreads

Sold Properties in one impacted Oakley Property managed building

If we take the last 2.5 years, with building safety being questioned for two of those years, there have been only three properties sold, all in 2025. This raises the critical question: How did this happen?

Sale One: 27 June 2025. Oakley issued a Stage One debt escalation in June 2025—a move likely designed to force the sale through. No follow up on the Stage One after the initial contact. All Brighton conveyancing firms had been warned at that point.
Sale Two: 15 Sept 2025
Sale Three: 23 Oct 2025

Further Corruption

Oakley issued another Stage One in December 2025, accompanied by what appeared to be faked previous service charge records—an action subsequently reported to the police. As of 21 March 2026, this Stage One has not progressed. Concurrently, the Oakley Property staff most involved in these escalations have disappeared from both the company’s “Meet the Team” page and LinkedIn. The freeholder mentioned in an email they were now managing the Service charge but didn’t send any service charges and both Oakley/Moreland Estate refuse to answer emails to confirm.

Future Sales & Contagion

Evidence suggests another property has been sold in 2026 but has not yet completed. This sequence of events creates a “contagion” effect that extends far beyond a single building:

Level One: The 2025/2026 sales currently in question.
Level Two: Sales in other Oakley Property managed buildings where these systemic issues were not disclosed during the sale process.
Level Three: Nationwide and NatWest Mortgages. As both lenders are involved in this specific case study, their exposure to Oakley-managed buildings and beyond represents a significant institutional risk.
Level Four: The entirety of Oakley Property’s estate agency business for the last two years.
Level Five: Involved agents like Aston Vaughan that ignored all warnings and went ahead with sales.
Level Six: Any Brighton conveyancing firms involved and their sales in the last 2 years.
Level Seven: As TLT Solictors who are used by Natwest and Nationwide and are now at the centre of a government review – does that unravel their mortgage related work?
Level Eight: The building insurer AXA who ignored all warnings and their broader portfolio.
Level Nine: Natwest and Nationwide whole businesses as they actively avoiding accountability which is well documented in the case study.
Level X: And the list goes on, we believe into vast amount of undisclosed risk and liability across over 20 entities.

All of these are currently under review and will form part of future articles.

NatWest Group – Is this Insider Trading?