Further Reporting of Offences to Police Scotland

The Register of Persons Holding a Controlled Interest in Land was established under Part 3 of the Land Reform (Scotland) Act 2016 to provide greater transparency on who owns land. It requires partnerships, trusts, unincorporated bodies and overseas entities to register details of the recorded person (the entity that owns the land) and any associates (those who control the entity) by 1 April 2024. Failure to do so is an offence with liability on summary conviction to a fine not exceeding level 5 on the standard scale (currently £5000).

Following previous blogs on non-compliance by North Glen Estates Ltd. and Astel Ltd. have resulted in reports being submitted to the Crown Office and Procurator Fiscal Service (COPFS). However, these two are just the tip of a very large iceberg of non-compliance. I have compiled a list of over 200 landowning entities who have not complied with the regulations. There will be many, many more.

Now that Police Scotland and COPFS have hopefully established protocols for dealing with offences under the regulations, I have today submitted a further 10 complaints to Police Scotland in relation to offences under Regulation 10 and Regulation 14.

Under Section 136 of the Criminal Procedure Act (Scotland) Act 1995, proceedings in relation to a summary offence need to be commenced with a six month time limit from the date of any contravention of the regulations. It is thus quite important that these complaints are dealt with promptly. For this reason I am not listing all of the persons about whom I have complained but they include the following.

• Agro Invest Overseas Limited registered in Guernsey and the part owner of the 11,086 hectare Ben Alder Estate.

• Andras Limited registered in the Cayman Islands and the owner of the 12,047 hectare Braulen Estate.

• Compania Financiera Waterville SA registered in Panama and the owner of Dannaspidal,Corrievarkie and Camusericht Estates (11,562 hectares).

• River Road Limited registered in the Isle of Man and owner of the 9166 hectare Altnafeadh Estate.

• Trustees of the Forestry Carbon Sequestration Fund registered in Guernsey and owner of 1020 hectares at Stobo Hopehead

The complaint was submitted in similar terms to the following;

I am contacting you to report an offence under the the Land Reform (Scotland) Act 2016 (Register of Persons Holding a Controlled Interest in Land) Regulations 2021 as amended. A company called Andras Limited, registered in Grand Cayman No. 357756, PO Box 219, 5th Floor, Butterfield House, Georgetown, Grand Cayman, Cayman Islands is the registered owner of Braulen Estate, Beauty, INVERNESS. An application for voluntary registration of Braulen Estate in the Land Register was made to the Keeper of the Registers of Scotland on 23 February 2026 under title number INV59514.

Andras Limited has failed to make an entry in the Register of Persons Holding a Controlled Interest in Land under the 2021 Regulations (as amended) despite being required to do so by 1 April 2024 as it is not an exempt body under Schedule 2 of the Regulations.

Andras Limited has therefore committed an offence under regulation 10(8) through failure to register details of any recorded person.

Associates of Andras Limited have also potentially committed an offence under regulation 14(3).

I look forward to these and other offences being investigated and prosecuted.