On 10 November, 2003, Gerry Florent, and Ralph Abercia, plus his son, Ralph Jr, left the Bellagio Hotel in Las Vegas, and drove to the Stirling Club, a high-end private venue just off the Strip. They were to attend separate meetings with Sir Richard Benson, but had met each other that morning, when they were collectively coached on the etiquette expected of them: speak only when spoken to, stand when he comes in. They were happy to comply. This was a man who had bailed out the Queen, after all.

Both Florent and the Abercias wanted the same thing from Sir Richard: money, of which he had plenty. Sir Richard, who was portly, balding and elderly, explained to them that he owned a company named Sherwin & Noble, which was worth billions and was prepared to finance their business projects. At their meetings, the prospective investors received a glossy spiral-bound summary of S&N’s balance sheet, which showed it to be a financial firm of significant size.

Florent wanted $55m to buy land on which to build a hotel in Florida; the Abercias needed $105m for an “aquarium/entertainment complex” in Houston. In return for the money, all Sir Richard asked was that they pay advance fees (two payments of $412,250 each from Florent, and two payments of $787,500 each from the Abercias) to signal their commitment to the projects. If S&N decided not to go ahead with the loans, the fees would be repaid.

The investors left Las Vegas, instructed their lawyers to wire the first tranche of the fees over, and settled down to wait for their money. They waited. And they waited. When they rang or faxed the S&N office in London, they were reassured that there was nothing to be concerned about. But, over the next few months, Florent and his business associates became suspicious. They held off wiring the second half of the fee, and brought in a private investigator, who discovered that S&N, far from being worth billions, was an empty shell company. The glossy booklet detailing its assets had been copied from the banking company HBOS, with the names changed.

Thus, the fraud fell apart. The Abercias, who had wired the whole fee asked of them, were devastated. “That was a lot of money,” Ralph Sr told a local journalist. “We’re still paying the damgum thing back.”

The whole saga had been scripted by a conman named Lal Bhatia. Sir Richard Benson was an actor. He had never rescued Buckingham Palace from foreclosure. The billions and the knighthood were fictitious. S&N had no assets, beyond a registered presence at a house in London – 29 Harley Street.

Eight years later, on the other side of the world, representatives of a Dutch shipping company named Allseas met the businessman Marek Rejniak to finalise an investment proposal. Allseas had €100m in cash, but it needed more if it was to build a vessel to dismantle oil rigs. The company was looking for ways to increase its capital. Rejniak claimed his team could double any investment in 30 days, and provide €1.2 billion within three years.

At the meeting, which took place on 16 October 2011 in Malta, Rejniak claimed to have links to the US Federal Reserve, the Vatican and the Spanish House of Aragon, which gave him access to lucrative forms of secret trading in financial instruments known as medium term notes. The actual buying and selling would be done in London by someone named Luis Nobre, described by Rejniak as an “A1 trader”. (His companies were called The LARN Holdings and ERBON Wealth Management, their names being derived respectively from Nobre’s initials, and from his surname spelt backwards.)

The next day, Allseas transferred the whole €100m to Rejniak’s Maltese company, and Rejniak sent the money to LARN’s account in London. Once it was in London, Nobre began to spend it.

Nobre is Portuguese. His long, dark hair has a few strands of silver threaded through it, and his beard is carefully groomed. At his trial for fraud at Southwark crown court, which ended in February with him being jailed for 14 years, he wore beautifully cut pinstripe suits, his tie always matching his pocket square. (The police have not yet tracked down his fellow fraudster Rejniak.) Before Nobre’s arrest, he had lived in a suite at Marylebone’s five-star Landmark Hotel, where he left £100-plus tips. The money he defrauded ran through his investment companies, which were – just like S&N – registered at 29 Harley Street.

No 29 Harley Street does not look like a centre of intricate intercontinental fraud. It is a handsome stone-fronted terraced house, a couple of minutes’ walk from the shops and the tourists of Oxford Street. It is five storeys high, with a bay window on the ground floor, an intricate steel balcony at first-floor level, and a stone balustrade just under the roof. Its front door is dark wood, with brass fittings.

Until his death in 1991, this was the home and place of business of Professor Ronald Raven, an internationally renowned surgeon, philanthropist, soldier, pianist, amateur theologian and connoisseur of porcelain. During his lifetime, 29 Harley Street was a trove of beautiful objects: paintings, furniture, clocks, ornaments that he had collected during almost half a century in residence.

Photographs taken towards the end of his life show him to have been grey-haired and distinguished, the very epitome of the successful medical practitioner on a street that has long been synonymous with high-class healthcare. Over the decades, doctors like him have imbued Harley Street with an aura of authority; an aura that surrounds any venture based here.

There are dozens of properties on Harley Street still used by doctors, but No 29 is not one of them. Instead, it is home to a company named Formations House, which, since it was founded in 2001, has made a business out of conjuring corporate vehicles from the West End air. The house is currently home to 2,159 companies, for which it operates as a large, ornate and prestigiously located postbox and answerphone. There is nothing illegal in this but some have used this address for improper purposes.

In its promotional literature, Formations House makes much of its location, stating for example, that: “all your postal [sic] will be received in Central London at a prestigious Harley Street business address”. Company formation agents create the vast majority of the 585,000 new companies formed each year in the UK, and a Harley Street address helps this one stand out from the crowd. Companies are both easy and cheap to establish in Britain – and the process is almost entirely unmonitored. Nobre and Bhatia are far from the only criminals to have realised that they are pretty much the perfect weapon for fraud.

It is an article of faith in modern politics that creating companies should be as easy as possible. They are the building blocks of capitalism, helping investors to form joint ventures, while limiting their exposure to losses if the ventures go wrong. Since Margaret Thatcher came to power in 1979, the UK government has gradually made creating companies easier, and the number of them on the corporate register has grown accordingly. In 1978, 744,000 companies were registered in the UK. By 1989, there were a million. By 2001, there were two million.

Formations House has made a business out of conjuring corporate vehicles from the West End air

This was in an era when applications still had to be filed on paper. “Before the digital age this was often a costly and laborious task,” lamented the World Bank’s 2015 Doing Business report, which included a case study of Britain’s deregulation of the sector. “It involved visits to Companies House, long lines and the higher costs associated with postal mail. Company founders often had to hire solicitors to handle paperwork.”

In 2001, the government did away with all that, and Companies House – the institution that registers British corporations, after which the name of Formations House is presumably modelled – introduced online applications. A boom began, and there are now 3.5m companies registered in the UK.

Dozens of company formation agents popped up to take advantage of this new system – among them Nadeem Khan and his wife Danielle Ardern, the founders of Formations House.

In the most basic sense, company formation agents simply create companies for people who do not want to do it for themselves. The sector has expanded, however, in all sorts of directions: most notably by creating “shelf” companies. Shelf companies are ready-made and available for purchase. Their advantage to the purchaser is that they give a reassuring impression of longevity to what is essentially a brand-new operation, since they have documents extending back years.

By law, all British companies must have two things: a director, who runs the company, and a shareholder, who owns it. They can also (but do not have to) have a secretary who, in a legitimate operation, takes on much of a director’s work. To create shelf companies, company formation agents need directors and secretaries. And this is when things start to get complicated, because they use other companies to do jobs designed for humans.

As soon as companies were involved in owning other companies, as well as being their directors and secretaries, it became extremely difficult to discover who really controlled them (ie who was the “beneficial owner”, the person who received any benefit from the company). In February 2004, for example, Formations House created three companies: Corporate Nominees, Legal Nominees, and Professional Nominees. The second company owns the other two, while itself being owned by the first company. The third company is secretary for the other two, while its own secretary is the first company. The second company is director of the other two, while its own director is the first company. These three companies then became directors, secretaries and shareholders of other structures, in an increasingly baffling multidimensional web of crisscrossing lines of control. If you looked for the companies’ real owners, the most you could eventually discover was that the original three all owned, controlled and managed each other.

To solve problems like this, in 2008 parliament decided that companies must have at least one real person as a director. In response, company formation agents signed up people who, for a fee, would declare themselves directors of newly created companies. Edwina Coales, a serial director of companies registered at 29 Harley Street, is or has been an officer at 1,560 of the companies listed on the Companies House website.

And that’s only the start of it. Formations House does not just create companies in Britain, but also in Gambia, Hong Kong, the Seychelles, the British Virgin Islands, Ireland, the US state of Delaware, Panama, Gibraltar, Jersey, the Isle of Man, Belize and Mauritius. Its website boasts of having formed more than 450,000 corporate entities: that is more companies than there are in Jersey, Guernsey and the Cayman Islands put together. It has 25,000 shelf companies available for purchase right now, with nominee directors, secretaries and shareholders available too. Yet, its office is not in a tax haven in the Caribbean or the English Channel. It is right in the heart of central London, half an hour’s walk from the Houses of Parliament, churning out companies for whoever wants them. Media outlets in Britain, the US, Norway, Italy, Ukraine and Romania have all made allegations of fraud against certain companies registered at 29 Harley Street.

Khan and Ardern (nee Coales) were born in November 1960 and February 1959, respectively. Not much is known about either of them, although Khan told police in a 2012 interview that he blogged under the name “Sam Soloman”.

The Formations House website is available in French, German, Russian, Italian, Spanish and Arabic, and welcomes clients from all over the world. When Formations House created Sherwin & Noble (it was initially called Q&Q, then renamed, presumably to make it sound posh enough for “Sir Richard Benson”), Khan was its shareholder and secretary, his wife Ardern was its director, and “Sam Soloman” was the person to be contacted if Companies House had any queries.

As the years went by, Khan and Ardern began to distance themselves from the companies they formed. When Formations House created companies for Nobre – The LARN Holdings Ltd, and ERBON Wealth Management Ltd – in 2011, the secretary was Nominee Secretary Ltd, a Harley Street shell owned by Corporate Nominees Ltd, and thus by the triangle of interlocking companies at the heart of Formations House. Nominee Secretary Ltd’s director was the serial nominee Edwina Coales, born 16 April 1935. It is not known how Coales’ relationship with Formations House began, but it is perhaps relevant that she was born 23 years before Ardern and that her surname is the same as Ardern’s maiden name.

Formations House has abided by the letter of British law, but successfully created structures that are all but impossible to penetrate for anyone trying to discover who really owns them.

“If organised crime depends on financial secrecy, untraceable shell companies are the most important means of providing it,” wrote the authors of a 2012 study of company formation agents, Global Shell Games. “Shell companies that cannot be traced back to their real owners are widely held to be one of the most common means of laundering money, giving and receiving bribes, busting sanctions, evading taxes, and financing terrorism.”

In the book, the authors tracked to what extent company formation agents in different countries requested their clients identify themselves before selling them shelf companies. In Britain, almost half of agents were happy to sell a company without checking the identity of the person buying it. If the agent does not record the beneficial owner of a company, then there is no way law enforcement officers can discover that information. And that is a problem, because the qualities that so endear companies to legitimate businessmen are just as attractive to organised criminals. Fraudsters like to obscure their identity and avoid liability as much as, if not rather more than, the next man. It is simply easier to commit fraud if you can do it anonymously, unobtrusively, and behind the protective cover of a prestigious London address.

Formations House has abided by British law, but created structures that are all but impossible to penetrate

“The question for me is this: as a police officer, what would I like?” asked Commander Chris Greany of the City of London police, the force that leads efforts by UK police to fight fraud. “Well, I’d like everything to be locked down tight, of course I would, but that isn’t the real world in which we all live. Society wants convenience, doesn’t it? And the price of convenience today is there might be fraud on the back of it.”

Formations House is probably no better or worse than any of its competitors, of which there are around 300 listed in the Yellow Pages, it is just more visible. Its address is so unlikely that few journalists can resist mentioning the Harley Street connection when a company such as Sherwin & Noble, The LARN Holdings or ERBON Wealth Management gets caught up in a fraud prosecution. And that has left a paper trail over the years, showing quite how many people have been ripped off by companies created in Professor’s Raven old home.

Illustration by Michael Kirkham

VAT fraud may lack the glamour of some of the scams laid bare by the Panama Papers, but few financial crimes are more prevalent or more damaging. Her Majesty’s Revenue and Customs (HMRC) estimates that the UK misses out on £500m to £1bn every year, from VAT being claimed back illegally. Across the whole of the EU, the “VAT gap” – the amount missing through non-compliance or non-collection – was estimated in 2013 at €193bn. That would be enough to pay off Ireland’s entire national debt, with a few billion left over to help the Greeks.

In the most common scam, shelf companies move shipments of high-value goods (typically, mobile phones) in and out of EU states and pick up VAT repayments each time. The first company imports the goods, and sells them on via a chain of companies, which charge VAT on every sale. The final company then exports the goods, and claims back from the Treasury the VAT it has paid, while the first company disappears without passing on the VAT it has charged. The fraudster has thus earned free money, without having to do anything but register a series of sales. To commit the crime, all they require are several shelf companies, with their own bank accounts and VAT numbers, so they can do business with each other. You can buy such companies from a number of outlets, including Formations House. On its website Formations House does not give a price for this product, but competitors provide similar vehicles for as little as £59.99). It is a near-perfect crime, almost impossible to uncover as long as the fraudster does not get greedy.

We know about the most famous scam to have involved 29 Harley Street precisely because the criminals did not follow that advice. Aoife Madden, an actress and the niece of a member of the Northern Irish assembly, and an Iraqi investor, Bashar Al-Issa, along with three associates, used one corporate vehicle, Evolved Pictures Limited (registered at 29 Harley Street), to invoice another for services supposedly related to the production of a film. They then tried to claim back £1.5m in VAT and almost as much again in film tax relief, a tax break designed to encourage film-making. Their crime was to claim it without actually making a film, and to charge VAT without passing it on to the Treasury.

“Falsely claiming VAT that is not due is illegal, so we are pleased that instead of this film flop going straight to DVD, these small-screen z-listers could go straight to jail,” said John Pointing, HMRC’s assistant director of criminal investigation, following their conviction in 2013.

The five did indeed go to jail, but they remained curiously naive fraudsters. While awaiting trial, they set to making a film – called, improbably, Landscape of Lies – in the forlorn hope that its existence would erase the crime they had committed by not making one in the first place. The film was shot on the cheap. Its Middle Eastern scenes had clearly been filmed somewhere in the Home Counties, and its star was ex-GMTV weather girl turned Loose Women presenter Andrea McLean. Madden and Al-Issa neglected to tell the cast or the director they hired – an ex-bouncer named Paul Knight – that they were awaiting trial, however. When the case started, he was left without payment. So he looked for compensation at their company’s registered office.

“After about three months of trying, I thought well, I’m just going to turn up on the doorstep, mate,” Knight told me. The prospect of Knight turning up on anyone’s doorstep is a daunting one – he is a big bloke, but that didn’t do him any good in this case. “Lo and behold, you realise that the swanky Harley Street address was just a building with a few letter boxes. It kind of put the final cherry on the cake,” he said.

He had discovered one of the great features of a corporate structure, which is how totally it can distance the owner from anyone trying to track them down. Knight never got his money, though Landscape of Lies gained a certain notoriety and indeed won an award at the Las Vegas film festival. (The festival rescinded the Silver Ace, however, after realising it had given a prize to a feature used as an unsuccessful alibi.)

If it was difficult for a Brit to discover that a registered address at 29 Harley Street was meaningless, it was even harder for a Ukrainian. In the early years of Viktor Yanukovych’s presidency, investigative journalists in Kiev could see that a piece of state-owned land in a forest outside the capital had been illegally privatised, but they did not know who by. The lakeside property, which was near the village of Sukholuchya, was transformed in the years after Yanukovych was elected in 2010 into a luxury residence, complete with a shooting range, chapel, yacht harbour, outdoor barbecue area, and more.

The owner was clearly rich and influential, but any attempt to definitively track down his identity came up against Astute Partners Limited, registered at 29 Harley Street, legal owner of the Ukrainian company that owned the land. Astute Partners was owned by Blythe (Europe), another Harley Street company, which was in turn owned by P&A Corporate Services Trust, registered at the Liechtenstein offices of an Austrian lawyer named Reinhard Proksch.

Why would a wealthy Ukrainian want to own property via central London? According to Borys Danevych, a Ukrainian lawyer who has himself struggled to identify the owners of shell companies while investigating corporate structures, a key reason 29 Harley Street was chosen as a base was that it looked prestigious, but in reality was just a front. Astute Partners had to declare its shareholder, but that shareholder was a trust in Liechtenstein, which does not reveal company ownership, so the declaration was meaningless.

Ukrainian court proceedings last year showed that the actual owner of the property was Yanukovych, who was overthrown in 2014. Proksch denies any wrongdoing, or any connection between Astute Partners and Yanukovych, and in 2014 insisted the companies belonged to “UK/US and UAE based clients and foreign investors”. The Ukrainian judge was not convinced, however, and the court took the land back into state ownership. Proksch failed to reply to my calls and emails requesting comment.

On a recent Friday afternoon, I decided to incorporate myself. I registered for a profile on the Companies House website, entered the information it asked for, chose a name for my company, and paid for it – all in just nine minutes. Some 36 hours later, on the Sunday morning, the email came through that my incorporation was successful. Oliver Bullough was now sole shareholder and director of Crooked Crook Crook Limited (under which name I receive a surprising number of letters. Just the other day, I was offered corporate car hire). Crooked Crook Crook is free to conduct business, its liabilities limited by legal guarantee, and no one at Companies House asked for any proof that the information I provided was accurate. It cost me £15.

The lack of checks is not wholly surprising. There were 200 new companies registered last year for every one of Companies House’s 3,000 employees, on top of the millions of regulatory filings that existing companies make. There is clearly no way such a small number of people can process this mound of paperwork, which is why the accuracy of the registry relies on the honesty of the people providing it with information.

If registering a birth or death was this easy, the opportunities for mischief would be endless. You could create as many “persons” as you liked, then use them to claim benefits, vote, register businesses, or apply for a passport, then kill them off if they got into trouble. The rights of companies are more limited, but the opportunities for fraud are almost as broad.

From 2010 to 2013, cold callers harassed thousands of British households with claims that land near the Brazilian seaside town of Fortaleza would rocket in price thanks to the then-forthcoming World Cup. The cold callers seemed plausible, and 600 people put up a total of £19m. But, in 2013, the Insolvency Service stepped in, forcibly winding up a group of related companies involved in the scam, among them Pantheon Limited, and Pantheon Realty Consultancy Limited, both registered at 29 Harley Street.

The only culprits the authorities could find were Ismael Rajabi and Ahmed Mohammadi, both from Afghanistan, whose names appeared on the companies’ registration documents. They are real people, but Companies House had, of course, not checked if they actually were the owners of the companies, which they were not. The real shareholders vanished, taking the investors’ money with them, and all the law could do was disqualify Rajabi and Mohammadi from being directors for 11 years.

Some of the defrauded investors asked Chris Corney, a solicitor from Carter Lemon Camerons in London, to look into launching a civil action to recover their money. He advised them against it, since bringing a case would have cost them more than it could have recovered. “London is such a free-for-all. We think of it as an orderly, well-regulated, law-bound economy, and you realise that actually it’s incredibly laissez-faire. You’ve got to run an awfully long way before the authorities will engage with you,” he said.

Yet Companies House’s “policy team” insisted that this wide-open system was key to keeping Britain in business: “The aim of UK government is to not impose burdens of unnecessary regulation on companies, and risk discouraging people from setting up and running a business, the vast majority of whom are honest.”

So, if it is this easy to create a company, why employ an agent to do it? Simply, company formation agents do more than create companies, they also answer the phone, receive post, and do other administrative tasks. The Las Vegas fraud would have been impossible without the semblance of legitimacy these services provided, for example, and the proceeds contributed to the torrent of dirty money that pours into London each year.

Prime Minister David Cameron has pledged to cleanse Britain of this ill-gotten cash. His government has made it possible for anyone to search Companies House for free on the internet, and, from June, new companies will have to publish their beneficial owners – the people who really control them. That information provided will not be checked any more thoroughly than it is now, however, which leaves law enforcement agencies as overstretched as ever.

So, are the company formation agents who offer these services breaking the law? Nigel Kirby, deputy director of the National Crime Agency’s Economic Crime Command, told me his team was investigating several agents, though he declined to specify which ones, and hoped to hand evidence to the Crown Prosecution Service this year. He said prosecutions could be brought under several sections of 2015’s Serious Crime Act. Among the new law’s provisions is one that obliges professionals to cease a business relationship if they are unable to discover the true identity of their client. “If you don’t do so, you’re liable to two years, and an unlimited fine,” Kirby said.

If his team does investigate Formations House, however, it may come up against the same difficulties that I did in finding anyone to talk to. Company filings record that Edwina Coales, the serial Formations House nominee who is still director of 49 companies, lives in a flat on Crawford Street in central London. However, when I visited the flat, the man who answered the door told me Coales had died “around two years ago”. Danielle Ardern, meanwhile, has no registered address except her office at 29 Harley Street, where I failed to find her when I showed up recently.

The door buzzed open into a grand, marble-floored hall leading into the depths of the house. A staircase rose up to the left, and pictures of Egyptian antiquities hung on the walls. A young man emerged from a corridor to ask my business, and then ushered me into a conference room, where I waited until a young woman, with long dark hair and a slight European accent, came to ask what I wanted. I explained that I was interested in what happened in the building, and she looked concerned. “We would normally require information in writing, you understand,” she said. “Most publications can be not very positive, so we are careful.” She wrote down her email address in my notebook, told me her name was Charlotte, and showed me out. I emailed her a list of questions about her place of work, but she did not reply to them, or return the phone messages I left for her.

And that left just Nadeem Khan, the enabler of fraud on a grand scale. We know slightly more about him, thanks to the prosecution of Nobre, the Portuguese conman. After Nobre was arrested on 3 December 2011, the money he had obtained from Allseas was frozen. But Nobre continued to live in expensive hotels in Mayfair and St James’s, with the funds coming from his Wembley-based lawyer Buddika Kadurugamuwa. (In February, she was convicted on one count of transferring criminal property, but avoided jail.)

Although the police informed Nadeem Khan by fax in December that Nobre was under arrest, Khan continued to deal with him, and only filed a suspicious activity report on 6 January 2012, the day he was visited by a police officer. According to the prosecution, Khan did rather more than just sell companies to Nobre. “His actions … were key in allowing Nobre to launder more of the stolen Allseas money,” the barrister’s opening note stated.

Prosecutors said Nobre had paid Khan £160,000 before the funds were frozen, nominally to buy four shelf companies. In reality, Khan used that money to finance pre-paid credit cards funded via a Cypriot bank and thus gave it back to Nobre by an obscure route, allowing the fraudster to keep spending Allseas’ money even while on police bail. Nobre appears to have thought that filing a suspicious activity report protected him from any criminal liability. “We assumed that it was [approved], we had the all-clear to deal with him, so we continued to deal with him,” Khan told police, according to comments quoted by the prosecuting barrister.

Khan assumed wrong, and was charged alongside Nobre and Kadurugamuwa. He died last year, shortly before the trial began, so the jury had no chance to decide the merits of the crown’s case against him. However, considering the sheer volume of frauds that have been publicly linked back to his office on Harley Street, it is hard not to wonder whether he played a similar role in other crimes too. He presumably would have charged handsomely for these backdoor services, as he did for the London phone numbers, the fax forwarding, the accountancy, and all the other legitimate services his company provided for his clients. If he did, where is the money? And, perhaps more importantly, who now owns this business in the heart of London that some have used for fraud?

Formations House Ltd is owned by Nominee Director Ltd, which is owned by another Harley Street company – our old friend Legal Nominees Ltd. Professional Nominees Ltd is still the secretary for Legal Nominees, and Corporate Nominees Ltd is still a director. The other director, required by law to be a person, is a 37-year-old Pakistani man, who plays the same role in 1,033 other companies. But the business structure has changed since this triangle of companies was created in 2004 to guard the inner sanctum of Formations House. Perhaps it was not quite impenetrable enough.

Since at least 2014, 200,000 shares in each of Legal Nominees Ltd, Corporate Nominees Ltd, and Professional Nominees Ltd have been owned by Sigma Tech Enterprises, which is registered at a service address in Hong Kong. There, however, is no company with that name on the Hong Kong corporate register. The Formations House website says that any disputes over the company’s privacy policy will be decided under Seychelles law, so the whole 29 Harley Street operation may ultimately be owned on an Indian Ocean archipelago, although we cannot be sure, since the Seychelles does not open its corporate register.

Public discussion about offshore tends to focus on the Seychelles, the British Virgin Islands or Panama: sunny places for shady people; remote countries full of dodgy money. But if 29 Harley Street tells us anything, it is that offshore isn’t a place, it’s an idea. Formations House is about as offshore as a place can be, and our government appears powerless to bring it back onshore again.

Main illustration: Michael Kirkham

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• This article was amended on 20 April 2016. An earlier version said that Nadeem Khan used a pseudonym of “Sam Soloman” and went on to say that Soloman/Khan presented himself as an expert on Islam and was commissioned to write a Charter of Muslim Understanding. We accept that although Khan was understood to have used the pseudonym Sam Soloman, he was not the Sam Soloman we described.