How GCUK collapsed in March 2021 and what its administration has done

analysisIn their statutory proposals of April 2021, prepared under paragraph 49 of Schedule B1 to the Insolvency Act 1986, the joint administrators of Greensill Capital (UK) Limited (GCUK) stated that the restructuring and refinancing plan the Greensill group pursued from the end of 2020 could not be implemented and that a number of factors, most particularly the withdrawal of insurance coverage from GCUK, forced GCUK to stop originating new business and left it insolvent. They also stated that during 2020 the exposure of Greensill Bank AG to the GFG Alliance drew increased attention from the Auditing Association of German Banks and from BaFin, the German financial regulator; that BaFin opened an investigation into the bank focused on the concentration of its lending to GFG and set conditions ultimately requiring that exposure to be reduced; and that GFG could not find alternative funding while the group's restructuring, intended to refinance the GFG liabilities, failed. This is the administrators' account, not a court finding, and the insurers' own position on the non-renewal of the policies is a separate matter. BaFin's own decisions and the terms of its conditions are not in the record; according to [2025] EWHC 2631 (Ch), BaFin required the group on 8 December 2020 to accelerate the reduction of its exposure to GFG and on 5 January 2021 blocked withdrawals by the group from Greensill Bank AG; in March 2021 BaFin filed an insolvency application for the bank, and the district court in Bremen appointed Dr Michael Frege as insolvency administrator. ^{1 2 3}

analysisThe administrators state that on 4 March 2021 one of Greensill Capital Pty Limited's financial creditors accelerated a $140 million loan, calling it in before its due date, and demanded immediate payment from GCUK as guarantor, which left GCUK unable to pay its debts as they fell due; the House of Commons Treasury Committee's report published on 20 July 2021 repeats that sequence and identifies the lender as Credit Suisse. On 8 March 2021 the High Court (Mr Justice Michael Green, [2021] EWHC 700 (Ch)) made administration orders for GCUK and its service company, Greensill Capital Management Company (UK) Limited (GCMC), on the application of their directors: the application for GCUK was made by its sole director, Alexander David (Lex) Greensill, and that for GCMC by Alexander David Greensill and Alastair Kenneth Eadie. Administration is a UK insolvency procedure in which licensed insolvency practitioners, the administrators, take control of a company's affairs and property for the benefit of its creditors. The court described GCUK as an arranger of trade finance involving the sale and purchase of receivables and found that GCUK had ceased trading on 2 March 2021, that US$140 million was immediately due from it as guarantor of a Credit Suisse AG facility to its holding company, and that it was cash-flow insolvent, unable to pay its debts as they fell due; GCMC, which provided employees to GCUK, depended on GCUK to fund its payroll for over 500 employees and was therefore also cash-flow insolvent. The court noted that Credit Suisse and PGFT (the Peter Greensill Family Trust, acting through its trustee), lenders to the Greensill group, had been notified of the application and consented to the orders, that the Bank of England had confirmed it did not intend to exercise its powers although the group included Greensill Bank AG, and that Credit Suisse Asset Management, appearing for the noteholders, did not oppose the orders. GCUK's administration is registered as High Court case 000435 of 2021; the judgment was issued under GCMC's case number, CR-2021-000436. On 4 September 2026 the High Court extended both administrations to 7 September 2028, and the administrators intend to end them by conversion to creditors' voluntary liquidations, insolvent liquidations in which the creditors can nominate the liquidator. ^{1 2 3 4}

analysisWhen making the orders, the court recorded that the proposed administrators from Grant Thornton, who had advised GCUK since December 2020, intended a pre-packaged sale, a sale of the business agreed before the administration to be completed on appointment, to Apollo Holdings Plc, which had offered to buy GCUK's intellectual property and IT systems and take on most of GCMC's employees; the court accepted that the purpose of the administrations was a better result for creditors than a winding up, not a rescue of the companies. The sale did not proceed: according to the administrators' proposals, contract negotiations with the proposed purchaser ended on 11 March 2021 because of a substantial reduction in the value of its offer. After the sale process was terminated the administrators made 435 employees of GCMC redundant and retained 135 to help realise assets and wind down the business; to keep pursuing insurance claims on defaulted assets for investors, GCUK retained its insurance professionals, contracted with its broker and engaged the insurance lawyers already acting on its claims. ^{3 1}

analysisChristine Laverty, Trevor O'Sullivan and William Stagg of Grant Thornton UK LLP were appointed joint administrators of GCUK and GCMC on 8 March 2021. In a letter of 9 July 2021 to the Treasury Committee they stated that they were not administrators or liquidators of the Australian parent, Greensill Capital Pty Limited, which is under the control of different insolvency practitioners. Russell Simpson later replaced Trevor O'Sullivan: Companies House received on 18 July 2022 notice of a court order removing an administrator from office and notice of the appointment of a replacement administrator, and both the High Court's judgment of 19 September 2023 and the administrators' progress report for March to September 2026 name Christine Laverty, Russell Simpson and William Stagg, the latter report as members of Grant Thornton UK Advisory and Tax LLP. ^{5 6 4 7}

analysisIn their proposals the administrators disclosed earlier connections between their firm and GCUK. Grant Thornton UK LLP was introduced to the Greensill companies by their lawyers, Allen & Overy LLP, shortly before 31 December 2020 and was engaged on that date by GCUK, Greensill Bank AG and Greensill Capital Pty Limited to assist with a Better Outcome Review for the Australian parent and with contingency planning for a possible insolvency appointment; GCUK paid Grant Thornton £1,437,784 for that engagement and its addendum, and the administrators state that they gave no contingency planning or other advice to Greensill Bank AG. Grant Thornton had been GCUK's appointed auditor in 2013, resigned as auditor in July 2015 without undertaking the 2014 audit, and in 2014 provided VAT and other tax advice to GCUK for fees of about £90,000. Chris Laverty, Trevor O'Sullivan and Helen Dale of Grant Thornton had also been appointed joint administrators of Caversham Finance Limited in March 2020, when it owed GCUK £30.8 million; that debt was repaid in full in July and August 2020 from asset realisations, and the administrators recorded that there were no further connections between Caversham and GCUK. The administrators stated that before accepting the appointments they considered the firm's prior professional relationships, having regard to their licensing bodies' ethical guidelines, and concluded that those engagements did not give rise to risks compromising the fundamental principles of the Insolvency Practitioners Association Ethics Code, or any of the five threats it identifies. ¹

analysisA statement of affairs is the directors' formal statement of a company's assets, debts and creditors at the date an administration begins. GCUK's, as at 8 March 2021, was made by Alexander David Greensill on 28 April 2021 in the High Court administration case 000435 of 2021 and filed at Companies House (form AM02) on 11 June 2021. It gives total assets of $1,472,148,187 at book value and $475,446,600 estimated to realise; the directors noted that a significant portion of the trade assets and accrued income to which they attributed a low recoverable value benefited from third-party security guarantees which, if invoked, could yield additional recoveries of c.$250m of trade assets and c.$175m of accrued income. On the liabilities side it shows $200,000,000 of debts secured by floating charges and unsecured non-preferential claims of $1,654,699,147 at book value and $1,456,984,613 estimated, giving an estimated deficiency as regards members of $1,181,551,493 after issued share capital of $13,480; the administrators' proposals summarise it as 210 unsecured creditors totalling $1.46 billion, against $14.5 million of unsecured claims in GCMC's statement of affairs. These figures are the directors' estimates at the date of administration and do not account for the costs of the administration. William Crothers, a former director of GCUK, filed a statement of concurrence with the statement of affairs subject to qualifications: that William Crothers ceased to be a director of GCUK on 4 February 2021; relied on the CFO and finance function for the figures, both while a director and for the statement of affairs; had had no up-to-date or detailed knowledge, since resigning, of the judgements and assumptions on recoveries in the statement; and had no access to historical Greensill Capital records, so that the numbers cannot be verified. Given those qualifications, the concurrence ends, the signatory has no reason to believe that the statement of affairs is not accurate. GCUK's administration filings in 2021 also include notice of the establishment of a creditors' committee (form COM1) on 3 August 2021 and the result of a meeting of creditors (form AM07) on 28 August 2021. ^{1 2 3}

analysisThe creditor schedule filed at Companies House with the statement of affairs is an image-based filing whose amount column and total are marked in pounds sterling, while the statement of affairs form itself gives creditor amounts in US dollars, so individual amounts carry that currency caveat; the administrators' figure for unsecured claims, $1.46 billion, is in US dollars. The schedule gives total claims of £1,278,780,154.75 and lists Credit Suisse AG, London Branch with 318,560,000.00. Group companies among the creditors include Greensill Capital Pty Ltd (245,497,076.30), Greensill Bank AG (32,705,156.43), Greensill Capital Management Company Limited (9,806,850.67) and Greensill GmbH (1,043,418.83), together with Greensill Limited (UK), Greensill Capital Trading 2 Limited, Greensill Capital Trading 3 Limited, Greensill Trading Limited (UK), Greensill Capital Investments (UK), GC Trading Ltd and Greensill Switzerland SARL, the names of the UK special-purpose companies being given as they appear in the schedule. Among other creditors are Marsh Limited with 27,950,020.00 and Marsh Limited (UK) with 2,103,121.57, GFG (with a Singapore address) with 12,105,337.92, Tradeshift Holdings Inc. with 5,160,050.19, and SIMEC International UK Limited and Aar Tee Commodities (UK) Limited with 2,017,556.32 each; these amounts too are as printed in the sterling-marked column. The schedule also names Peter Greensill Family Co Pty. Ltd. as trustee for and on behalf of the Peter Greensill Family Trust, in a closing block with further entries for Greensill Bank AG and Credit Suisse AG, London Branch; in the filed image the amount on the trust's line cannot be matched to it with certainty, and the administrators' proposals report separately that the trust's floating charge secured a balance of $60 million at the date of administration. ^{1 2}

analysisThe administrators' proposals describe GCUK as the main trading entity of the group and the recipient of most of its income, and as providing funding to most other group entities. Before the administrations GCUK facilitated about $140 billion of transactions a year. Assets under its management totalled $17,738 million at 8 March 2021, of which GCUK was beneficially entitled to only $490 million, the economic benefit lying predominantly with third-party investors; $3,738 million had been collected by 16 April 2021, of which $32 million was for GCUK. In the administration GCUK was to keep collecting sums due from obligors, the businesses owing the receivables, pursue recoveries and submit insurance claims on notes protected by insurance policies, while the administrators negotiated with the investors who held the main beneficial interest in those assets to cover the costs. By 16 April 2021 anchor investors had paid retainer fees of $5 million into the estate to cover costs while funding arrangements were finalised; the administrators' US dollar receipts and payments account for 8 March to 16 April 2021 shows $5,000,000.00 of third-party funding received and $573,346.27 paid for trade insurance. ¹

analysisGCUK's own assets were of several kinds. According to the proposals, its accrued income consisted mainly of about $194 million of structuring and advisory fees and about $24 million of data-driven revenue from securitised contracts, principally in the telecoms sector; the largest fee, $175 million, was due in equal instalments on 31 March and 30 June 2021, and after the first instalment was not received the administrators were pursuing the obligor, whom the proposals do not name. The proposals also list an equity warrant in a US-based mining business held at a book value of $50 million and $4 million owed by a former shareholder after GCUK brokered the sale of its shares to another party, which the statement of affairs treats as fully recoverable; neither the mining business nor the former shareholder is named. Other group entities owed GCUK $107.4 million at the date of administration, chiefly Greensill Inc ($46.3 million), Omni ($19.3 million), Earnd UK ($10.9 million), Finacity ($9.4 million), Omni Technologies SAS ($7.4 million) and Greensill Capital Asia PTE ($5.9 million), of which the directors estimated $13 million as recoverable; GCUK's loan notes of about $37 million in the Omni entities, owned by Greensill Capital Pty Limited, were dealt with in a sale completed on 22 April 2021 that realised about $9 million for GCUK. At the date of administration GCUK held about $59 million in 36 bank accounts in 18 currencies, plus about $50 million in a segregated account relating to Credit Suisse's security; long-term cash deposits of about $6 million were collateral for letters of credit provided to insurers, and about $1.8 million held in escrow in Citibank reserve accounts for trustee and issuer fees did not form part of the estate. ¹

analysisA charge is security over a company's assets: a fixed charge attaches to specific property, while a floating charge covers a changing class of assets such as receivables. The Companies House register lists four charges over GCUK, three outstanding and one satisfied. The oldest, created on 24 June 2016 in favour of Citibank Europe PLC and still outstanding, is described by the administrators as a fixed charge over a designated bank account under a corporate deposit deed securing amounts due in connection with standby letters of credit issued by Citibank, under which nothing was outstanding at the date of administration. Two charges were registered in favour of Peter Greensill Family Co Pty. Ltd. as trustee of the Peter Greensill Family Trust: one created on 19 May 2020 and satisfied on 23 October 2020, and one created on 22 October 2020, in which the trustee acts as security agent and security trustee. The administrators describe the latter as a floating charge over GCUK's receivables, subordinate to the Credit Suisse security, securing GCUK's guarantee of a $60 million loan by the trust to Greensill Capital Pty Limited made on 22 October 2020; by April 2021 nothing had been paid to the trust under that security. Charge 0812 6173 0004, created on 22 October 2020 and delivered to Companies House on 9 November 2020, is registered in favour of Credit Suisse AG, London Branch and contains a floating charge; according to the administrators it covers a specified account and GCUK's receivables and secures GCUK's guarantee of a $140 million loan made by Credit Suisse to Greensill Capital Pty Limited on 22 October 2020, the full $140 million being due at the date of administration. The administrators stated in April 2021 that they were obtaining legal advice on the validity of the security, and that none of the secured creditors was a qualifying floating charge holder under the Insolvency Act 1986, the status that would have allowed a lender to appoint administrators itself. ^{1 2 3 4}

analysisCredit Suisse enforced its security before the administration began. Receivership is a remedy in which a secured lender appoints receivers to take control of the charged assets and realise them for its benefit. On 5 March 2021 Credit Suisse appointed Geoffrey Paul Rowley and Anthony John Wright of FRP Advisory Trading Limited as receivers of the secured account, receivables and related rights of GCUK; the receivers had Citibank, as account bank, pay Credit Suisse about $50 million from the secured account, leaving about $90 million outstanding, which Credit Suisse also claimed against the receivables held by GCUK. Companies House received two notices of appointment of a receiver or manager on 23 March 2021 and, on 28 April 2021, two notices of ceasing to act and a receiver's abstract of receipts and payments to 14 April 2021. The security of Credit Suisse and of the Peter Greensill Family Trust, whose validity the administrators said in April 2021 they were examining with legal advice, neither lender being a qualifying floating charge holder, was dealt with in 2026: on 5 June 2026 the administrators executed a confidential settlement involving a payment from the estate, which concluded all secured creditor claims, and their progress report records that payments in that period included one in full and final settlement of the trust's purported secured creditor claim. Their US dollar receipts and payments account for 8 March 2021 to 7 September 2026 records cumulative payments to floating charge creditors of 100,028,425.28 to Credit Suisse AG and 17,750,051.00 to the Peter Greensill Family Trust, the trust's payment falling in the six months to 7 September 2026. These figures are read from an image of the filed account and are given as the administrators' account; the trust's period and cumulative columns print slightly different amounts (17,760,081.90 and 17,750,051.00), so the exact figure is uncertain. ^{3 4 2}

analysisGreensill Bank AG claimed part of the money held by GCUK. The administrators reported in their April 2021 proposals that part of the collections from GCUK's trade assets might be subject to a claim by the bank arising from an agreement of 14 July 2020 under which it advanced €90 million to GCUK, and that they were taking legal advice on the validity of that claim; its resolution is not stated in the retained progress report. GCUK also held a foreign exchange hedging account at Citibank, through which it also hedged foreign exchange positions of Greensill Bank AG, backed by a cash deposit of about €70 million; after the administrators' appointment Citibank closed the account because GCUK could not meet further margin calls and set the closure costs off against the deposit, leaving about €40 million, which was subject to a potential claim by Greensill Bank on the basis that the deposit funds originated from the bank. On 8 December 2021 the administrators applied to the High Court for directions, a ruling on how they should proceed, on whether GCUK or Greensill Bank AG was the beneficial owner of funds that had come to GCUK through foreign exchange transactions; the bank's insolvency administrator, Dr Michael Frege, was later joined as a respondent, and the court described the dispute as hostile litigation between the two companies. A Part 36 offer is a formal settlement offer under Part 36 of the Civil Procedure Rules, which carries set costs consequences. In [2023] EWHC 2429 (Ch), given on 19 September 2023, Sir Anthony Mann held that CPR Part 36 can apply to administrators' directions proceedings and that a Part 36 offer made by Greensill Bank AG on 14 September 2022 to settle its claim to the disputed funds had been accepted by the administrators and bound the bank. Greensill Bank had argued that Part 36 did not apply, that the administrators' rejection of the offer in December 2022 ended it, that the offer was conditional on a court ruling and had been withdrawn in August 2023, and that offer and acceptance did not correspond; the judge rejected these arguments and left the bank's further arguments on mistake and the rule in Ex parte James, a principle requiring officers of the court such as administrators to act fairly, for a later hearing. The judge made a reporting restrictions order preventing any reporting of the contents of without-prejudice offers, including Part 36 offers, in the matter, so the terms of the offer are not stated here. ^{1 2 3}

analysisThe administrations of GCUK and GCMC have been extended repeatedly after their first year: according to the administrators' progress report filed on 10 October 2026, the period was extended by creditors' consent to 7 March 2023, then by the court for 24 months to 7 March 2025 and, by order of 18 March 2025, for 18 months to 7 September 2026, and GCUK filed the corresponding notices of extension (form AM19) on 17 February 2022, 17 March 2023 and 19 March 2025. The administrations did not end on 7 September 2026: on 4 September 2026 the High Court extended both by a further 24 months to 7 September 2028 and gave the administrators permission to make interim distributions to GCUK's unsecured creditors during the administration, and GCUK filed a further notice of extension on 16 September 2026. The administrators intend to convert GCUK's administration into a creditors' voluntary liquidation for a final distribution. The timing and amount of any interim dividend were uncertain at the September 2026 report. By 7 September 2026, on the administrators' own totals, the administration had cumulative receipts of £380.6 million and payments of £265.6 million, converted to pounds at the exchange rates of that date, and the administrators' cumulative time costs and expenses stood at £51.8 million and £41.0 million. They reported that the directors had estimated unsecured claims at about $1.6 billion for GCUK and about $14.5 million for GCMC, that certain creditors had lodged claims of significant value above the directors' estimates, that claims had not yet been called for or formally adjudicated, and that further contingent claims could arise from trade credit insurance policies or litigation by obligors, insurers or others. The Insolvency Service's press release of 4 June 2026 describes GCUK as having collapsed into administration with liabilities of more than £1.6 billion, a figure the same release also gives for the combined liabilities of the three Greensill companies of which Lex Greensill was a director; the directors' and administrators' figures are in US dollars. ^{1 2 3}

analysisIn their progress report for March to September 2026 the administrators stated that their investigations concerning former directors were continuing and that they were advancing actions in that regard, without giving details so as not to prejudice their position; their remaining work includes negotiations with third parties, including pre-appointment GCUK directors, to recover contributions to the estate's losses. Settlements following their statutory investigations reached in the period had a total consideration of £1.8 million, of which £1.19 million was received in the period and £570,000 remained due on deferred terms, with a final payment scheduled for March 2028; the report names no director, states no claim amount and does not identify the settlement counterparties. A Part 7 claim, a claim started under the standard procedure of Part 7 of the Civil Procedure Rules, BL-2025-000562, Greensill Capital (UK) Limited (in administration) v Greensill and others, was filed in the Business List of the High Court on 29 April 2025 and is listed as a claim for breach of fiduciary duty against seven defendants: Alexander (Lex) Greensill, Sean Hanafin, Divya Eapen, Alastair Eadie, Neil Garrod, Jonathan Lane and Bartholomeus Ras. A court docket summary and a press report (April 2025) describe it as a claim brought by the company's administrators against former directors. The claim is the company's allegation against the defendants; its particulars, the sums claimed and any defences are not in the record, no hearing or judgment was found, and no response by the defendants was found. ^{2 4 5}

analysisThe same report describes the main open recoveries and proceedings. About $587.2 million (at March 2021 exchange rates) remained outstanding from GFG across 33 separate balance sheet items, with no recoveries in the period; the administrators said that significant time had passed in numerous unsuccessful negotiations and non-binding term sheets on GFG settlement offers, and that they continued to explore recovery under the security and guarantees granted by GFG in connection with the GFG programmes. GCUK remained an inactive party to the Australian insurance proceedings, providing discovery with costs covered by the active parties; it remained joined to two English insurance proceedings between investors and insurers, stayed against GCUK except for discovery under court orders dated 22 November 2024; and it had been joined as a defendant, as accredited lender, to proceedings by Greensill Bank AG against the Secretary of State for Business and Trade over the bank's investments in loans under the government-guaranteed Coronavirus Business Interruption Loan Scheme (CBILS) and Coronavirus Large Business Interruption Loan Scheme (CLBILS) and the guarantees. ²

analysisChapter 15 of the US Bankruptcy Code allows a US court to recognise a foreign insolvency proceeding, which can then protect the debtor against lawsuits in the United States; recognition as a foreign main proceeding treats the foreign case as the principal one. On 18 August 2021 the joint administrators Christine Mary Laverty, Trevor Patrick O'Sullivan and William George Edward Stagg, as foreign representatives of GCUK, filed a Chapter 15 petition in the United States Bankruptcy Court for the Southern District of New York (case 21-11473 (MEW)) seeking recognition of GCUK's English administration as a foreign main proceeding. An order of 13 September 2021 in Bluestone Resources Inc. v Greensill Capital (UK) Limited in the US District Court for the Southern District of New York refers to the bankruptcy court's order granting recognition of a foreign main proceeding involving GCUK and stays that case against GCUK. In the Chapter 11 case of Greensill Capital Inc. (21-10561 (MEW)), under a revised assignment of intellectual property filed as Exhibit C to the second plan supplement, Greensill Capital Inc. agreed, as part of a global settlement of disputes between the estates, to assign to GCUK, acting by its administrators, its rights in software and related intellectual property developed for GCUK; the parties were also bound by a Services Agreement effective 25 March 2021. In the six months to 7 September 2026 GCUK received $446,854 as a final dividend from Greensill Capital Inc., and its administrators continued to monitor the liquidations of Greensill Asia and Greensill India for possible recoveries for GCMC's estate. ^{1 2 3 4}