Greensill Capital (UK) Limited, the Covid loan schemes and lobbying

analysisThe Coronavirus Large Business Interruption Loan Scheme (CLBILS) was launched by the British Business Bank on 20 April 2020 for businesses with turnover above £45 million. Loans were made by accredited lenders, commercial lenders approved to lend under the scheme, normally up to £50 million per borrower group, or up to £200 million for lenders accredited to its Larger Scheme Facility; the government guaranteed 80% of each loan, repaying the lender that share if the borrower did not repay, provided the lender had complied with the scheme rules. Lex Greensill first contacted the Bank's Chief Commercial Officer about accreditation on 17 April 2020. Greensill Capital (UK) Limited (GCUK) submitted an Expression of Interest on 19 April and, on 23 April 2020, a Formal Proposal asking for a lending allocation of £1 billion, based on a pipeline of 40 to 50 borrowers with facilities averaging £35 million and on three products: supply chain finance, accounts receivable and accounts receivable portfolio. The application stated that the Greensill business had provided more than £120 billion of financing in 2019, 30% of it relating to UK buyers or sellers, that it had no external debt, that an investment of $1.7 billion received in the previous 18 months valued it at around $4 billion, and that its default rate was 0.03% for 2019, with defaulted assets at 0.43% of total assets in March 2020. These were the applicant's own statements. The National Audit Office (NAO) later reported that the Bank performed limited due diligence and accepted key information at face value, that the £120 billion figure could not be verified from publicly available information, and that a more sceptical process might have led the Bank to question the statements on default rates, borrower exposure and the business model. The Bank told the NAO that the purpose of its due diligence was not to assess Greensill's financial position in detail but, given the policy direction to accredit lenders quickly and a greater reliance on audits after accreditation, to confirm that lenders could reliably deliver money to borrowers. In July 2021 the Treasury Committee noted the NAO's finding that a more sceptical process might have prevented the acceptance of Greensill as an accredited lender. ^{1 2}

analysisA paper submitted to the Bank's Investment Committee on 4 May 2020 recommended accrediting GCUK with an allocation of up to £1 billion, stated that limited due diligence had been carried out, and named three key risks: scrutiny of supply chain finance, including its link to the collapse of Carillion in 2018; GCUK's relationship with Sanjeev Gupta's firms through Liberty Steel Group; and its connection to former Prime Minister David Cameron. On 12 May 2020 the Committee ruled GCUK's supply chain finance product ineligible for CLBILS and approved accreditation with a £1 billion allocation for the other two products. On 3 June 2020 the Bank's Chief Commercial Officer set the allocation at £400 million, and on 4 June 2020 GCUK, the first non-bank lender accredited under CLBILS, was formally accredited with a maximum of £50 million per borrower group. GCUK applied on 12 June 2020 for the scheme's term loan and revolving credit facility variants and for the Larger Scheme Facility, which would have allowed loans of up to £200 million. The Bank's Managing Director Forum agreed on 3 July 2020 to refuse the Larger Scheme Facility because GCUK was not permitted to use the Internal Ratings Based approach, a regulatory method of measuring credit risk with a lender's own models, and GCUK was accredited for the two variants on 8 July 2020 within its existing £400 million allocation. ¹

analysisGCUK's individual loan limit remained £50 million, although whether it could be raised was the subject of messages and enquiries in 2020. In mid-June 2020 David Cameron sent messages to Nadhim Zahawi MP, then Parliamentary Under-Secretary of State for Business and Industry, and to Richard Sharp about whether the £50 million CLBILS limit could be raised for Greensill; HM Treasury told the House of Commons Treasury Committee that the Bank never approached it with a proposal for enhanced accreditation. The NAO found that the Department for Business, Energy & Industrial Strategy (BEIS), aware that GCUK financed Liberty Steel and that Liberty Steel had sought around £160 million to £180 million of government support early in the pandemic, made eight email enquiries of the Bank over 19 weeks between April and September 2020 about GCUK's accreditation and whether it could lend more than £50 million per borrower. The Department described these as informal approaches, while the Bank called the level of departmental interest unusual; the Bank did not prioritise the application, and its legal review concluded that external parties had not influenced the accreditation. GCUK also applied on 16 July 2020 to lend under the Coronavirus Business Interruption Loan Scheme (CBILS), which covered businesses with turnover up to £45 million, and was accredited on 21 September 2020 with a £50 million allocation. It lent £18.5 million under CBILS through four revolving credit facilities of £5 million each, one of them later reduced to £3.5 million after the borrower was found to have an existing CBILS facility with another lender. ^{2 1}

analysisGCUK lent £400 million under CLBILS, the maximum it was permitted, in eight loans of £50 million each, all of them revolving credit facilities, which made it the fifth-largest CLBILS lender by value; with the £18.5 million lent under CBILS and the 80% guarantee, the NAO put the government's maximum exposure under both schemes at £335 million (£334.8 million in its detailed figure). The first CLBILS loan, £50 million to SIMEC International (UK) Limited, a GFG Alliance company, had an initial draw date of 31 July 2020. The second, £50 million to Aar Tee Commodities (UK) Limited, had an initial draw date of 27 August 2020; the Bank noted that the owner of Aar Tee Commodities had previously been a board member of GFG's charitable foundation and of GFG's strategic board, and the NAO counted the company among seven CLBILS borrowers with connections to the GFG Alliance. On 30 September 2020 GCUK made six further loans of £50 million each, £300 million in all, to Speciality Steel UK Limited, Liberty Commodities Limited, Liberty Industries UK Limited, Liberty Steel Newport Limited, Liberty Pipes (Hartlepool) Limited and Liberty Merchant Bar Plc, companies that appeared to the Bank to be associated with the GFG Alliance. ^{1 2}

analysisOn 2 October 2020 the Bank became concerned that GCUK's seven CLBILS loans to Gupta Family Group (GFG) Alliance borrowers, totalling £350 million, breached the rule that lending to one borrower group could not exceed £50 million without Larger Scheme Facility accreditation, which GCUK lacked; treated as one group, the lending was £300 million above GCUK's limit. GCUK told the Bank that day that it considered the loans compliant. The Bank, which had restated the group rule to GCUK in May 2020, escalated its concerns to HM Treasury on 7 October and to BEIS on 9 October 2020. This was the Bank's concern and provisional view as the NAO described it in July 2021, not a court finding of breach. On 12 October 2020 the Bank's Investment Committee agreed to investigate GCUK's compliance with the CLBILS rules, and on 13 October the Bank told GCUK that it could make no more loans until the issues were resolved, reducing its allocation to zero under both CLBILS and CBILS; from October 2020 it engaged Ernst & Young to review the CLBILS loans. According to the Bank, GCUK said at that 13 October meeting that it had received “political steers” that its support for the steel industry was welcome. A press report of April 2021, cited by the Treasury Committee, stated that the GFG Alliance had split companies so that Greensill could lend it more under CLBILS while keeping each transaction within the £50 million cap. This is a press account reported by the Committee, not a finding; the Department for Business and Trade later relied on related grounds when it terminated the guarantees, which Greensill Bank AG disputes in pending litigation. Lex Greensill, declining to discuss individual customers, told the Committee on 11 May 2021 that each facility had been reviewed by a top-tier London law firm and that in Lex Greensill's opinion every facility complied with the Bank's rules. ^{1 2}

analysisOn 2 March 2021 the Bank sent GCUK a Letter of Concern setting out provisional findings that it had breached the CLBILS guarantee agreement and giving notice that the Secretary of State's guarantee obligations were suspended. A second Letter of Concern, dated 26 March 2021 in the NAO's timeline, concerned the loan to Aar Tee Commodities (UK) Ltd; these were the only such letters issued under CLBILS, and a Supplemental Letter of Concern followed on 27 May 2021. On 9 April 2021 GCUK's joint administrators, Chris Laverty, Trevor O'Sullivan and Will Stagg of Grant Thornton UK LLP, replied that GCUK denied the allegations in the Letter of Concern, considered its loans compliant with the scheme rules, including those on group lending, and regarded any cancellation of the guarantees on those grounds as a breach for which GCUK reserved the right to seek damages. They also said that the time given to respond was procedurally unfair, to which the Bank replied on 16 April 2021 that the process was set out in the Letter of Concern; this is GCUK's position as the NAO reported it. As of 30 June 2021 the investigation was ongoing and the guarantees remained suspended, with GCUK's deadline for representations extended to 20 August 2021. According to the Department for Business and Trade's written case reported in January 2026, the government then terminated the CLBILS guarantees in April 2022 and the CBILS guarantees in September 2023; Greensill Bank AG denies, in pending High Court proceedings, that the Department was entitled to do so. ^{1 2 3}

analysisGreensill Bank AG has issued legal proceedings against the Secretary of State for Business and Trade concerning its CBILS and CLBILS investments and the underlying guarantees, and GCUK, as the accredited lender, has been joined as a defendant and is providing disclosure, according to the joint administrators' 2026 progress report; the claim remains pending. A press report (January 2026) of a High Court hearing described the Department's written case: it terminated the CLBILS guarantees because six of the eight borrowers were “ultimately owned” by Sanjeev Gupta, so that GCUK had lent £300 million to them when the sum “ought not to have exceeded £50m”, and it terminated the CBILS guarantees saying that GCUK “did not exercise a level of care, control and diligence consistent with the standard required”. Counsel for Greensill Bank AG stated that the six companies were not “partner or linked enterprises” and that GCUK “did not act in bad faith”, and Greensill Bank AG denies that the Department was entitled to terminate the guarantees. The same report said that Greensill Bank AG seeks more than £331 million in damages, alleging that the Department wrongly terminated the guarantees and that there was “considerable political pressure” from the Department to accredit GCUK to lend to Sanjeev Gupta's companies; the Department is defending the claim: its counsel said it had lawfully determined that GCUK failed to act in good faith by treating six Gupta-owned borrowers separately to avoid the restrictions on lending to groups, and called the bank's pleaded case “highly inadequate”. Both sides' positions are as reported in the press and have not been decided by a court: the hearing before Mr Justice Robin Knowles dealt with procedural issues, and the trial is expected to begin in late 2027 and could last up to eight weeks. Credit Suisse Asset Management's December 2022 investor Q&A also referred to the UK government's decision to remove the CLBILS guarantees on Greensill loans to GFG, and said that its supply chain finance funds were not beneficiaries of those guarantees. ^{3 2 4}

analysisTwo other routes to government-backed funding were refused in 2020. The Covid Corporate Financing Facility (CCFF), which the Bank of England operated for HM Treasury to buy short-term commercial paper, was not open to financial institutions. Greensill applied after the market notice of 18 March 2020 and proposed changes to the criteria, such as accepting assets from securitisation vehicles in the European Economic Area and insurers' credit ratings in place of borrowers' ratings. On 30 March 2020 HM Treasury told the Bank of England that the Chancellor did not intend to change the criteria, and the Bank told Greensill that its application did not meet them; the NAO records this as HM Treasury's rejection of GCUK. After further proposals and a confidential HM Treasury call for evidence in May 2020, HM Treasury told Greensill for the final time on 26 June 2020 that it would not be eligible, in a call by Second Permanent Secretary Charles Roxburgh with Lex Greensill, then GCUK's chief executive, and Bill Crothers, a GCUK director. Economic Secretary John Glen MP confirmed the decision by letter to Lex Greensill and by text to David Cameron, and Greensill never gained access to the facility. In February 2020 Standard Chartered, as one of GCUK's lenders, asked UK Export Finance for an Export Development Guarantee covering 80% (£400 million) of a £500 million five-year loan to GCUK. UK Export Finance rejected the application in June 2020 as not aligned with the product's policy intent and in September 2020 rejected a revised one-year proposal of £100 million to £200 million, its due diligence having identified concerns about GCUK's governance and its exposure to some of its customers. The Treasury Committee's July 2021 report cited these refusals as an example of other government agencies paying attention to the reputational issues around Greensill. ^{1 2}

analysisCharles Roxburgh told the Treasury Committee that, on the administrator's figures, Greensill owed $8 million to HM Revenue & Customs (HMRC), about $168,000 to two local authorities and $10,000 to one foundation trust, a direct public exposure of £5 million to £6 million before recoveries, while the indirect exposure lay in the 80% CLBILS guarantees, which were suspended during the British Business Bank's investigation. This was HM Treasury's evidence in 2021, based on provisional administration figures that do not name the debtor company, and the Committee noted that Greensill contested the rationale for suspending the guarantees. According to the NAO, which found published HMRC data showing a Greensill company claiming between £10,001 and £25,000 in each of January and February 2021, Greensill Capital Management Company (UK) Limited received between £20,002 and £50,000 from HMRC under the Coronavirus Job Retention Scheme (the furlough scheme). The Committee's report of 20 July 2021 also states that Greensill provided the financing for the Pharmacy Early Payment Scheme, which let pharmacies receive funding earlier than under the standard government payment schedule; according to the Chancellor's evidence, the Department of Health and Social Care introduced the scheme in 2013 with Citibank as provider, and in 2018 Taulia replaced Citibank under a contract with the NHS Business Services Authority, made through a Crown Commercial Service framework, and contracted Greensill to provide the financing, HM Treasury having no record of involvement in that process. ^{1 2}

analysisThe Treasury Committee found that most of the lobbying on behalf of Greensill in 2020 was carried out by Lex Greensill, then chief executive of GCUK, Bill Crothers, a GCUK director, and former Prime Minister David Cameron, an adviser to Greensill Capital, and that David Cameron or David Cameron's office made 56 contacts with the government on Greensill's behalf in the period it examined. The Committee accepted that David Cameron did not break the rules governing lobbying by former ministers, while saying those rules were not strong enough; David Cameron told the Committee that lobbying the UK Government “was never intended to be part of my role”. The Committee concluded that the Treasury took the right decision in preventing Greensill from accessing the CCFF, and a press report (January 2026) stated that an inquiry later found David Cameron's actions to have been within the rules and that David Cameron had not been required to register as a lobbyist. On the terms of the role, David Cameron's own account was that Greensill paid “a generous annual amount—far more than what I earned as Prime Minister” and that the adviser held shares, not share options, in the business, vesting over the term of the contract; the exact remuneration was described as a private matter, and no amount or shareholding is stated in the record. The Committee also recorded the use of Greensill's private jets, which David Cameron said were short-haul flights on which tax was paid for any benefit. In a letter to the Committee David Cameron said that the role involved invitations to most routine Greensill Board meetings but no directorship, board-committee seat, voting rights or executive responsibility, and that the last Board meeting David Cameron attended was on 10 November 2020; the letter does not name the Greensill company whose board is meant. GCUK's joint administrators told the Committee on 9 July 2021 that, from an initial review of the minutes of GCUK's 2020 board meetings, David Cameron did not appear to be recorded as an attendee at any of them, and declined to provide the minutes, citing commercially sensitive and legally privileged content; the record therefore does not show which group board the meetings David Cameron described belonged to. ^{1 2 3}

analysisThe Committee also looked at when concerns about Greensill first arose. It reported that the Prudential Regulation Authority (PRA) received limited information from BaFin, the German financial regulator, in March 2020 suggesting a “possible weakness in controls” at Greensill, which the Bank of England did not then pass to HM Treasury. The potentially serious nature of Greensill's financial difficulties became apparent to PRA supervisors in October 2020, with a much stronger concern from BaFin about Greensill Bank AG, and the information reached HM Treasury on 3 November 2020. Sam Woods, Deputy Governor of the Bank of England, told the Committee that BaFin's concerns in March 2020 were about systems and controls rather than Greensill Bank's solvency, that BaFin later gave reassurance on which the Bank put some weight, and that the Bank did not pass the information to HM Treasury at that time because it conveyed less serious concerns than the October information and did not add materially to the concerns about Wyelands and its relationship with the GFG Alliance that the Bank was already sharing with HM Treasury. Lex Greensill told the Committee that the first concerns about Greensill as a company arose in December 2020, following interactions with the German regulator; David Cameron also dated first concern about the company's financial position to December 2020, after a call from Lex Greensill reporting that a planned capital raising was not going as well as hoped. These are the witnesses' own accounts, which the Committee set beside its record of the information the Bank of England had received from BaFin in March and October 2020. ¹

analysisIn later written evidence Lex Greensill corrected earlier oral evidence, stating that Greensill Capital had provided a facility to a subsidiary of General Atlantic, which the Committee said had bought a minority stake in Greensill in 2019, that the facility was repaid in full in 2021, and that Greensill Capital had a special approval process for lending to any shareholder or affiliate. That is Lex Greensill's own statement, which gives no amount; the Committee had cited reports that General Atlantic borrowed €300m from Greensill, and the amount of the facility is not confirmed in the record. In a June 2021 letter annexed to that evidence, Bill Crothers stated that in summer 2015, after discussions with Cabinet Secretary Sir Jeremy Heywood, Civil Service head John Manzoni and the Head of Propriety and Ethics, a three-month transitional arrangement allowed Bill Crothers to work part time for the Civil Service while advising Greensill Capital for about one day a month; the Civil Service work covered only commercial capability, and responsibility for the Crown Commercial Service passed to John Manzoni for that period. This is Bill Crothers' own account, with no separate official confirmation in the record; the 2019 accounts of GCUK describe Bill Crothers as a former senior civil servant whose last government role was UK Government Chief Commercial Officer. Separately, a review by Nigel Boardman, conducted at the request of the Prime Minister, examined decisions on the development and use of supply chain finance and associated schemes in government, especially the role of Lex Greensill and Greensill Capital; the Treasury Committee, reporting in July 2021, said that it had been due to report to the Prime Minister by 30 June 2021. ^{4 5 1}