Guyana Anti Corruption Network

# 🥥 THE BITTER HARVEST: A GACN INVESTIGATION IN FOUR PARTS

## PART FOUR: THE VERDICT – ILLEGALITY, REGULATORY FAILURE, AND A CALL FOR PROSECUTION

**How the $30,000 acquisition of Pomeroon Trading may have violated securities laws, anti‑money laundering statutes, and director’s fiduciary duties – and why law enforcement on three continents must act.**

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### I. Introduction: From Corporate Failure to Criminal Exposure

The previous three parts of this investigation have laid bare a disturbing narrative: a Guyanese coconut farm, publicly celebrated by the Ministry of Agriculture and backed by a future British Deputy Prime Minister, was sold for a mere $30,000 to a Canadian shell company that rebranded itself as a carbon credit enterprise. That company – now called Carbon Done Right Developments Inc. – has since been hit with a cease trade order, saw its revenues collapse by 61%, and remains unable to generate any verified carbon credits from the Guyanese asset it acquired.

But this is not merely a story of failed business ambitions. The pattern of conduct revealed by this investigation raises serious questions about potential criminal and regulatory violations across multiple jurisdictions.

This final part of the series examines the legal exposure of the key players, the duties of the regulators who failed to act, and the specific actions that law enforcement authorities in Canada, the United Kingdom, and Guyana must now take.

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### II. Canadian Securities Law Violations

As the jurisdiction where the publicly traded parent company is listed, Canada has primary responsibility for investigating potential securities law violations arising from the acquisition of Pomeroon Trading.

**A. Material Misrepresentation and Securities Fraud**

The cornerstone of Canadian securities law is the prohibition against making a material misrepresentation – a false statement of a material fact or an omission of a material fact that would reasonably be expected to have a significant effect on the market price or value of a security.

The $30,000 acquisition price of Pomeroon Trading raises an obvious question: did Klimat X (now Carbon Done Right) accurately disclose the true value of the assets it was acquiring? The company’s own press release announcing the Change of Business transaction stated only that the terms were “not disclosed” – a phrase that should alarm any securities regulator. Detailed SEDAR filings that would provide a transparent accounting of the Pomeroon Trading acquisition, including any valuation analysis, due diligence reports, or independent fairness opinions, are not publicly available.

The company publicly promoted the Guyana Coconut segment as a core part of its carbon credit portfolio. Its website states: “Our partnership with Pomeroon – Caribbean Coconuts & Spices will drive sustainability and meaningful impact.” Yet there is no evidence that any carbon credits have ever been generated from this asset. If Klimat X represented to investors that the Guyana Coconut segment was a valuable carbon credit project when it knew – or recklessly disregarded – that no such credits existed or were likely to materialize, that could constitute a material misrepresentation.

Under Canadian securities law, fraud is defined broadly to include any act, omission or course of conduct that results in a misrepresentation that is relied upon by another person to their detriment. The definition of fraud varies by jurisdiction, but CSA members have consistently enforced prohibitions against fraudulent and manipulative trading practices. Individuals and corporations convicted of securities fraud can face significant fines based on the amount of money involved and the impact of the fraud. In addition to criminal penalties, securities regulators can impose administrative sanctions such as fines, disgorgement of profits, and restrictions on future trading or participation in the securities market.

Under British Columbia’s Securities Act, a person who contravenes the Act commits an offence and is liable – in the case of a person other than an individual – to a fine of not more than $1 million and, in the case of an individual, to a fine of not more than $1 million or imprisonment for not more than three years, or both. The most serious offences, such as insider trading and market manipulation, can result in fines of up to $1 million.

**B. The Cease Trade Order: A Regulatory Warning**

On July 30, 2025, the British Columbia Securities Commission (BCSC) issued a failure‑to‑file cease trade order against Carbon Done Right under National Policy 12‑207, which addresses failure‑to‑file cease trade orders and revocations in multiple jurisdictions. The CTO was issued due to the company’s failure to meet crucial filing requirements. All trading in the company’s securities is prohibited until the required filings are made and the CTO is revoked. On August 5, 2025, the Canadian Investment Regulatory Organization (CIRO) formally suspended trading of Carbon Done Right’s stock on the TSX Venture Exchange under the symbol KLX, noting that “Members are prohibited from trading in the securities of the companies during the period of the suspension or until further notice”.

While a failure‑to‑file CTO is not itself evidence of fraud, it is a significant regulatory red flag. The BCSC has a dedicated Criminal Investigations Branch that investigates offences under BC’s Securities Act – known as “quasi‑criminal offences” – and securities‑related offences in Canada’s Criminal Code. In 2014 alone, the BCSC conducted 22 administrative and three criminal proceedings, with the most common violations including those related to unregistered activity, illegal sales of securities and fraud. The fact that Carbon Done Right has attracted the attention of the BCSC – and that its shares remain suspended as of the date of this report – should prompt a deeper investigation into the company’s entire acquisition history, including the Pomeroon Trading transaction.

**C. The Reverse Merger: A Regulatory Loophole Exploited?**

The transaction that brought Pomeroon Trading into the public markets was a reverse takeover (RTO) – also known as a “back door listing” – involving a shell company, Earl Resources Limited, that was already listed on the NEX board, a market for relatively inactive or “shell” companies.

In a reverse takeover, a private company bypasses the regulatory hurdles of a traditional IPO by merging with a small, often dormant, shell company that already has a public listing. As legal commentators have noted, a reverse takeover “is generally regulated only by a stock exchange rather than, for a typical IPO, a securities commission or commissions tasked with the review and receipt of a prospectus”. This lighter regulatory touch creates opportunities for abuse.

The Canadian Securities Administrators (CSA) has itself published guidance on “regulatory concerns with certain asset or business acquisitions,” noting that those “primarily taking place in venture markets” raise “concerns regarding misleading disclosure”. The TSX Venture Exchange has codified policies governing Changes of Business and Reverse Takeovers, but these policies rely heavily on the accuracy of the disclosures made by the companies involved.

In the case of Klimat X, the company’s own press release announcing the Change of Business transaction stated that the terms of the acquisition of Pomeroon Trading were “not disclosed.” This lack of transparency – combined with the astonishingly low $30,000 valuation – should have triggered immediate scrutiny by the TSX Venture Exchange and the BCSC.

**D. Director’s Conflict of Interest: The Passmore Problem**

Perhaps the most glaring legal issue in this entire transaction is the role of Neil James Passmore.

Passmore was a co‑founder of Pomeroon Trading. Following the acquisition, he was appointed as a Director of Klimat X and its Director of Corporate Development. Critically, MarketWatch records show that on June 29, 2022 – the day of the acquisition – Passmore engaged in a transaction with the company at $0.00 per share.

Under the Canada Business Corporations Act (CBCA) and the British Columbia Business Corporations Act (BCBCA), directors owe a fiduciary duty of loyalty to the corporation. They must act honestly and in good faith with a view to the best interests of the corporation. When a director finds themselves in a conflict of interest, they must promptly disclose the conflict and, where necessary, recuse themselves from board deliberations. The director must avoid being in a position where his or her personal interest would come into conflict with that of the corporation and must act in a disinterested manner. A director who discloses a conflict of interest must refrain from voting on any resolution to approve the contract or transaction giving rise to such conflict of interest. Where a director is prohibited from voting on a resolution due to a conflict of interest, the conflicted director is also prohibited from attending the portion of a meeting during which the transaction at issue is discussed.

In the Klimat X transaction, Passmore appears to have occupied both sides of the deal: as a founder of Pomeroon Trading, he was a seller; as a director of Klimat X, he was a buyer. This is a classic conflict of interest. There is no public evidence that Passmore disclosed this conflict, recused himself from board deliberations, or abstained from voting on the acquisition. If he failed to do so, he may have breached his fiduciary duties under the CBCA – a breach that can result in personal liability and, in egregious cases, criminal prosecution.

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### III. Anti‑Money Laundering and Financial Intelligence Concerns

The $30,000 acquisition of a company that had publicly claimed millions in investment also raises questions under Guyana’s Anti‑Money Laundering and Countering the Financing of Terrorism (AML/CFT) Act.

Guyana’s Financial Intelligence Unit (FIU) is responsible for receiving and analyzing Suspicious Transaction Reports (STRs) from reporting entities such as banks, law firms, and other financial intermediaries. Under Section 18 of the AML/CFT Act, reporting entities must pay special attention to all unusually large business transactions, whether completed or not, and to all unusual patterns of transactions and to insignificant but periodic transactions which have no apparent economic or lawful purpose. If a transaction is suspected on reasonable grounds to be connected to the proceeds of criminal activity, money laundering or other infractions, the reporting entity must file an STR.

The $30,000 acquisition price – a fraction of the value that Pomeroon Trading had publicly claimed – would, in any reasonable analysis, be considered an “unusual” transaction. A Guyanese asset was sold to a Canadian company at a price that bore no apparent relationship to its claimed value. If any financial intermediary – a bank, a law firm, or an accounting firm – facilitated this transaction without filing an STR, it may have breached its obligations under the AML/CFT Act. The FIU has the power to impose sanctions on reporting entities for failure to comply with AML/CFT obligations.

Moreover, the discrepancy between the claimed value of Pomeroon Trading (US$3 million invested, an US$8 million processing facility planned) and the actual sale price ($30,000) raises the possibility of trade‑based money laundering – the practice of using legitimate trade and businesses as cover to move illegally attained assets around the world. If funds were moved from Guyana to Canada or the United Kingdom under the guise of a legitimate agricultural investment, the transaction should be scrutinized by the FIU, the Bank of Guyana, and the Guyana Securities Council.

The GACN Investigation calls on the Financial Intelligence Unit of Guyana to:

1. Request from all Guyanese financial institutions any records relating to the transfer of funds in connection with Pomeroon Trading.
2. Determine whether any Suspicious Transaction Reports were filed in relation to the $30,000 acquisition or any other transactions involving Pomeroon Trading.
3. Refer any evidence of money laundering to the Director of Public Prosecutions for criminal investigation.

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### IV. The United Kingdom: Bribery of a Foreign Public Official and Director’s Liability

The involvement of David Lammy – a senior British politician who was at the time an MP and is now Deputy Prime Minister and Justice Secretary – introduces potential liability under the UK Bribery Act 2010.

Section 6 of the Bribery Act makes bribery of a foreign public official a stand‑alone distinct crime. A person (“P”) who bribes a foreign public official (“F”) is guilty of an offence if P’s intention is to influence F in F’s capacity as a foreign public official. The Act defines a “foreign public official” broadly and includes individuals holding legislative, administrative or judicial positions in a country outside the UK.

If any person or company associated with Pomeroon Trading offered, promised or gave any financial or other advantage to a Guyanese public official – including officials of the Ministry of Agriculture – in order to obtain or retain business or an advantage in the conduct of business, that would constitute an offence under section 6 of the Bribery Act.

The GACN Investigation has not uncovered direct evidence of bribery. However, the speed and enthusiasm with which the Ministry of Agriculture embraced Pomeroon Trading – issuing press releases, providing technical support, and publicly complimenting the investment – combined with the company’s subsequent collapse, warrants scrutiny. The Ministry of Agriculture held multiple meetings with Pomeroon Trading executives in 2018 and 2021. It is not known whether any gifts, hospitality, or other advantages were provided to Guyanese officials by the company or its representatives.

Moreover, section 7 of the Bribery Act creates a corporate offence: a commercial organisation is guilty of an offence if a person associated with it bribes another person intending to obtain or retain business or an advantage in the conduct of business for the organisation. The only defence is that the organisation had “adequate procedures” in place to prevent bribery. If Pomeroon Trading or Klimat X failed to maintain such procedures – and there is no evidence that they did – they could be liable under section 7.

In a striking irony, David Lammy – the very politician who was an unpaid adviser to Pomeroon Trading – announced in December 2025 that the UK would expand its domestic corruption unit at the City of London police, giving it £15 million in new funding to focus on bribery and other misconduct in UK financial services and public bodies. The GACN Investigation calls on that same unit to examine whether any of the individuals or companies involved in the Pomeroon Trading transaction – including Lammy himself – have violated the Bribery Act.

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### V. Guyana: Fraudulent Misrepresentation and Breach of Director’s Duties

Within Guyana, the conduct of Pomeroon Trading and its directors may have violated the country’s criminal and corporate laws.

**A. Fraudulent Misrepresentation to the Ministry of Agriculture and the Public**

Fraudulent misrepresentation occurs when a false statement is dishonestly made to someone, that person relies on the statement, enters into a deal, and then suffers a loss as a result. The false statement must be made knowingly or with reckless disregard for the truth. In some cases, fraudulent misrepresentation can lead to criminal charges, especially if it involves financial fraud.

Pomeroon Trading made repeated public statements about its financial condition and future prospects:

– In 2017 and 2018, the company claimed to have made a “massive investment” in the Guyanese coconut industry, planting 5,000 trees every month.
– In 2021, the company announced a US$8 million (G$1.7 billion) processing facility.
– The company claimed to have invested approximately US$3 million since its founding.
– The company announced plans for an IPO at US$7.50 per share.

Yet, in June 2022, the company was sold for $30,000. This disparity – between the public claims and the actual sale price – is so vast that it raises an inference that the public claims were false or, at a minimum, recklessly exaggerated.

If the Ministry of Agriculture and the Government of Guyana relied on these representations in deciding to support Pomeroon Trading – issuing press releases, providing technical assistance, and publicly endorsing the company – then the government itself may be a victim of fraudulent misrepresentation. The elements of fraudulent misrepresentation appear to be present: a false statement of a material fact (the value and prospects of the company), made knowingly or recklessly, intended to induce reliance, and actual reliance by the government to its detriment (the government’s reputation and resources were committed to a company that had no real value).

Under Guyana’s Companies Act, officers of a company who are in default of their duties can be guilty of an offence and liable to a fine. Fraudulent acts are punishable with imprisonment, fines, or both.

**B. Breach of Duty to Zena Stoll**

The civil lawsuit brought by Zena Stoll against Pomeroon Trading – alleging unpaid rent of $387,000 and damages of $500,000 – also raises potential criminal exposure. If the court finds that Pomeroon Trading obtained the lease from Ms. Stoll through fraudulent misrepresentation – for example, by falsely representing its ability to pay rent or its intentions for the estate – that could constitute obtaining property by false pretences, a criminal offence under Guyanese law.

The GACN Investigation calls on the Director of Public Prosecutions of Guyana to:

1. Review the evidence gathered in Zena Stoll’s civil lawsuit to determine whether criminal charges should be filed against Pomeroon Trading and its directors.
2. Investigate whether Pomeroon Trading made false representations to the Ministry of Agriculture, and whether those representations constitute fraudulent misrepresentation under Guyanese criminal law.
3. Consider whether the Ministry of Agriculture itself bears any responsibility for failing to conduct due diligence before endorsing the company.

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### VI. The Role of Law Enforcement and Financial Regulators: A Roadmap for Action

The web of potential violations spans three countries. Each jurisdiction has authorities with the power to investigate and prosecute. The GACN Investigation calls upon the following bodies to act:

**A. Canada**

1. **British Columbia Securities Commission (BCSC)** : The BCSC should expand its existing inquiry into Carbon Done Right beyond the failure‑to‑file cease trade order. The Commission should investigate whether the company made material misrepresentations in its disclosure documents concerning the Pomeroon Trading acquisition and the value of the Guyana Coconut segment. The BCSC’s Criminal Investigations Branch should examine whether the $30,000 transaction involved securities fraud.

2. **TSX Venture Exchange**: The Exchange should review whether Klimat X complied with Policy 5.2 governing Changes of Business and Reverse Takeovers. If the company failed to make adequate disclosure, the Exchange should consider delisting the company’s shares.

3. **Royal Canadian Mounted Police (RCMP) – Integrated Market Enforcement Team (IMET)**: The RCMP’s IMET is responsible for investigating serious capital market fraud. The RCMP should examine whether the Pomeroon Trading acquisition involved market manipulation, insider trading, or other criminal offences under the Criminal Code.

4. **Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)**: FINTRAC should review any financial transactions between Canada and Guyana or the United Kingdom relating to the acquisition to determine whether any money laundering or terrorist financing indicators are present.

**B. United Kingdom**

1. **Serious Fraud Office (SFO)** : The SFO has jurisdiction to investigate serious or complex fraud, including bribery and corruption involving UK companies or citizens. The SFO should examine whether any UK‑based individuals or companies – including Neil Passmore and the UK companies he controls – engaged in fraudulent conduct in connection with the Pomeroon Trading acquisition.

2. **City of London Police – Domestic Corruption Unit**: As noted above, David Lammy announced the expansion of this unit with £15 million in new funding. The unit should investigate whether any bribery or corruption occurred in connection with the company’s interactions with Guyanese public officials – and whether any of the individuals involved, including Lammy himself, have violated the Bribery Act 2010.

3. **National Crime Agency (NCA)** : The NCA should examine whether the movement of funds between the UK, Guyana, and Canada in connection with Pomeroon Trading constitutes money laundering.

**C. Guyana**

1. **Financial Intelligence Unit (FIU)** : The FIU should request STR filings from all Guyanese financial institutions that handled transactions involving Pomeroon Trading. The FIU should also determine whether any transaction constituted trade‑based money laundering.

2. **Director of Public Prosecutions (DPP)** : The DPP should review the evidence gathered in Zena Stoll’s civil lawsuit to determine whether criminal charges should be filed against Pomeroon Trading, Neil Passmore, and Duncan Turnbull for fraudulent misrepresentation, obtaining property by false pretences, and breach of director’s duties under the Companies Act.

3. **Guyana Police Force – Major Crimes Unit**: The police should investigate whether any Guyanese public official received any financial or other advantage from Pomeroon Trading or its associates.

4. **Guyana Securities Council**: The Council should review whether any Guyanese securities laws were violated in connection with the company’s announced IPO, which never took place.

5. **Parliamentary Select Committee**: The National Assembly should convene a Select Committee to investigate the Ministry of Agriculture’s role in endorsing Pomeroon Trading, including what due diligence was performed and why no action has been taken since the company’s collapse.

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### VII. Obstacles to Justice: What Stands in the Way?

The GACN Investigation recognises that justice in this case will not be easily achieved. Several obstacles stand in the way:

**A. Jurisdictional Fragmentation**

The key players are located in three different countries: Canada (Klimat X/Carbon Done Right, James Tansey), the United Kingdom (Neil Passmore, David Lammy), and Guyana (Zena Stoll, the Ministry of Agriculture). Evidence is scattered across jurisdictions. No single law enforcement agency has clear jurisdiction over the entire transaction. Cooperation between the BCSC, the SFO, and Guyana’s FIU will be essential – but such cooperation is notoriously slow and politically sensitive.

**B. Political Connections**

David Lammy is now the Deputy Prime Minister and Justice Secretary of the United Kingdom – the very official responsible for the UK’s justice system. Any investigation that touches Lammy will face enormous political pressure. The fact that Lammy was an unpaid adviser to Pomeroon Trading and held shares in the company creates an obvious conflict of interest. The GACN Investigation calls upon the UK’s Independent Adviser on Ministerial Interests to examine whether Lammy’s conduct violated the Ministerial Code.

**C. Corporate Dissolution and Asset Shielding**

As of the date of this report, Carbon Done Right remains under a cease trade order, and its shares are suspended. The company may be on the verge of insolvency. If the company collapses, its assets – including whatever value remains in the Guyana Coconut segment – may be shielded from creditors and claimants, including Zena Stoll. Law enforcement agencies must act quickly before evidence is destroyed or assets are dissipated.

**D. The Carbon Credit “Green Shield”**

Carbon credit companies often enjoy a presumption of good faith because they are associated with environmental protection. This “green shield” can make regulators and the public less sceptical of their claims. The GACN Investigation urges regulators to look past the environmental rhetoric and examine the underlying financial transactions with the same rigour they would apply to any other public company.

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### VIII. Conclusion: A Verdict of Systemic Failure

The story of Pomeroon Trading is not merely the story of a failed coconut farm. It is the story of a systemic failure of oversight and accountability across three countries.

In Guyana, the Ministry of Agriculture embraced the company without due diligence, issued press releases celebrating its investment, and has since remained silent as the company collapsed and a 91‑year‑old landowner was left with a ruined estate.

In Canada, a shell company acquired a Guyanese agricultural asset for a nominal price, rebranded itself as a carbon credit enterprise, and raised capital from public markets – all while making misleading disclosures and failing to file required documents, ultimately triggering a cease trade order.

In the United Kingdom, a senior politician served as an unpaid adviser and shareholder of the company, publicly championed its IPO, and then – according to the landowner – abandoned her when she needed his help.

And across all three countries, the regulators who should have been watching – the BCSC, the TSX Venture Exchange, the FIU of Guyana, the SFO – failed to intervene until it was too late.

**The Bitter Harvest is not yet over. But it can be. Law enforcement and financial regulators now have the evidence. The question is whether they will act.**

The GACN Investigation calls upon the authorities in Canada, the United Kingdom, and Guyana to launch immediate, coordinated, and transparent investigations into the Pomeroon Trading acquisition and the conduct of all individuals and entities involved. The people of Guyana – and especially Zena Stoll – deserve nothing less.

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*This is Part Four of a four‑part investigative series by the Guyana Anti‑Corruption Network (GACN).*

*If you have any additional information about this case – including documents, financial records, or witness testimony – please contact the GACN directly.*

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### References for Part Four

**Reference 1**
Céline Dostaler. (2024, September 24). What Is Securities Fraud in Canada? Retrieved from https://www.celinedostaler.ca

**Reference 2**
British Columbia Securities Commission. (n.d.). Enforcement FAQs. Retrieved from https://www.bcsc.bc.ca

**Reference 3**
British Columbia Securities Commission. (n.d.). Securities Act [RSBC 1996] Chapter 418. Retrieved from https://www.bclaws.gov.bc.ca

**Reference 4**
Investment Executive. (2002, September 27). Regulator introduces new penalty guidelines for trading violations. Retrieved from https://www.investmentexecutive.com

**Reference 5**
CSA Staff Notice 51-364. (2025, July 3). Continuous Disclosure Review Program Activities for the fiscal years ended March 31, 2024 and March 31, 2025. Retrieved from https://www.securities-administrators.ca

**Reference 6**
Ainvest. (2025, July 30). Assessing the Long-Term Viability of Carbon Done Right Amid Regulatory Challenges. Retrieved from https://www.ainvest.com

**Reference 7**
Stockwatch. (2025, July 31). Carbon Done Right suspended by BCSC. Retrieved from https://www.stockwatch.com

**Reference 8**
Stockwatch. (2026, April 3). C-KLX News. Retrieved from https://www.stockwatch.com

**Reference 9**
CSIMarket. (2025, July 31). Carbon Done Right Developments Faces Regulatory Setback with Cease Trade Order. Retrieved from https://csimarket.com

**Reference 10**
CIRO. (2025, August 5). Canadian Investment Regulatory Organization Trading Halt – KLX. Retrieved from https://iiroc.mediaroom.com

**Reference 11**
Globe NewsWire. (2025, July 30). CARBON DONE RIGHT DEVELOPMENTS INC. ANNOUNCES CEASE TRADE ORDER. Retrieved from https://www.globenewswire.com

**Reference 12**
InsiderTracking.com. (n.d.). Carbon Done Right Developments Inc. (V:KLX*CA). Retrieved from https://www.insidertracking.com

**Reference 13**
Lexpert. (2026, January 26). Reverse takeover deals: Key steps, risks and advantages for issuers. Retrieved from https://www.lexpert.ca

**Reference 14**
The Globe and Mail. (2011, September 14). OSC head urges more scrutiny of reverse takeovers. Retrieved from https://www.theglobeandmail.com

**Reference 15**
Endeavor Law. (2024, September 19). Going Public In Canada: Reverse Takeovers (RTOs). Retrieved from https://www.endeavorlaw.ca

**Reference 16**
Law Works Lawyers. (2024, July 24). Corporate directors’ conflicts of interests. Retrieved from https://www.lawworks.ca

**Reference 17**
McMillan LLP. (2025, June 10). Boardroom Ready: Duties and Best Practices for Canadian Directors. Retrieved from https://mcmillan.ca

**Reference 18**
Thomson Reuters Practical Law. (n.d.). Duties of Directors: Conflict of Interest Regime (Canada). Retrieved from https://ca.practicallaw.thomsonreuters.com

**Reference 19**
Zonebourse. (n.d.). Neil Passmore – Director/Board Member at Carbon Done Right Developments Inc. Retrieved from https://www.zonebourse.com

**Reference 20**
Financial Intelligence Unit of Guyana. (2022, December 1). Issue No. 4: Measures to prevent Money Laundering and Terrorist Financing. Retrieved from https://fiu.gov.gy

**Reference 21**
INews Guyana. (2025, November 18). FIU rejects mischievous claims by VPAC. Retrieved from https://inewsguyana.com

**Reference 22**
Financial Intelligence Unit of Guyana. (2022, November 28). Reporting Entities. Retrieved from https://fiu.gov.gy

**Reference 23**
Moody’s. (2022, July 21). Trade-based money laundering: do you know the signs? Retrieved from https://www.moodys.com

**Reference 24**
UK Bribery Act 2010. (c. 23). Section 6 – Bribery of foreign public officials. Retrieved from https://www.legislation.gov.uk

**Reference 25**
The Guardian. (2025, December 7). UK will not be haven for dirty money, Lammy to say in corruption crackdown. Retrieved from https://www.theguardian.com

**Reference 26**
The Globe and Mail. (2025). Carbon Done Right Announces Non-Brokered Private Placement and Shares for Debt Settlement. Retrieved from https://www.theglobeandmail.com

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*If you have any additional information about this case, please contact the GACN directly.*