[Stephen] Raven is described by his friends as "old school". He is 70 now, although he retains the matinee idol looks for which many in the City remember him. He had a distinguished career before joining Madoff. He was on the London Stock Exchange Council for 16 years, sat on the board at Warburgs and was a founding director of Liffe.

The futures market brought him and Madoff together. The American was keen to do business in London and Raven became his chief executive here. The two, while of similar vintage, complement rather than resemble each other. My source said: "Stephen is charm personified. Madoff can be magnetic but there's a whiff of the backstreets there." - Keith Dovkants, UK Evening Standard ,12/16/08

You have to hand it to Bernie. He put in a board of directors in London who all look good on paper.

As Anthony M. Destefano reported today in Newsday,  Irving Picard, Madoff bankruptcy trustee, claims $220 million was sent back and forth between Bernie's firm in NY and his London firm, Madoff Securities International Ltd., in 2008. Picard is investigating the possibility that funds were diverted to a bank on the Isle of Man, an offshore tax haven situated in the Irish Sea.

But what no one to date has said is whether the $192 million in cash and cash equivalents reported in the 2007 MSIL financial statements is a good number to begin with (The MSIL financials and other shareholder information are available online at Companies House for a nominal fee). The financials, audited by KPMG, do not break out which portion of the cash balance was invested in treasury bills or some other similar liquid investment but interest income from such investments is reported to be $7 million.

In 2007, Bernie boosted MSIL's cash on hand and equity by injecting $96 million in cash into MSIL as an addition to shareholder capital and forgiving $62 million in loans he made to MSIL in 2000 and 2001. In hindsight, it looks like Bernie used MSIL as an excuse to shift cash out of the U.S. in 2007. Whether the funds came from his personal account or BMIS is not disclosed in the notes to the financials.

Christopher James Dale, the MSIL Finance Director, has to be concerned as well as KPMG. Dale joined the company in 2003 as a director in 2003 and was the compliance officer from  mid-2006 to mid-2008. According to the UK FSA register, Dale appears to have had oversight of Credit Suisse's money laundering reporting from 2003 to 2004.

I would think Picard or the DOJ will interview Peter Robert Allen, the MSIL secretary who resigned in mid-2006, and anyone else who might have had reasons to resign from the firm other than in the ordinary course of business.

Not too hard to figure out why the British authorities didn't rush to investigate Bernie's UK business affairs.