Business and Property Courts, Insolvency & Companies List (ChD) Court Number: CR-2025-002375
in Special Administration
10024682
UNDER REGULATION 20 OF THE PAYMENT AND ELECTRONIC MONEY INSTITUTION INSOLVENCY REGULATIONS 2021 AND RULE 112 OF THE PAYMENT AND ELECTRONIC MONEY INSTITUTION INSOLVENCY (ENGLAND AND WALES) RULES 2021
5 AUGUST 2026
On 14 April 2025 upon an application under regulation 8(1) of the Payment and Electronic Money Institution Insolvency Regulations 2021 (“the Regulations"), Blackthorn Finance Limited (company number 10024682) (“the Company") entered into special administration by order of Chief ICC Judge Briggs. By the same order, Adam Stephens, Philip Hemming and Kevin Ley of S&W Partners LLP, 45 Gresham Street, London, EC2V 7BG were appointed to act as joint special administrators of the Company (together, “the JSAs").
In accordance with regulation 20 of the Regulations and rule 112 of the Payment and Electronic Money Institution Insolvency (England and Wales) Rules 2021 (as amended by The Payment and Electronic Money Institution Insolvency (England and Wales) (Amendment) Rules 2022) (the "Rules"), the JSAs hereby give notice of a first interim distribution of relevant funds.
1. Interim Distribution Notice
1.1 On 16 April 2025, to expedite the return of relevant funds, the JSAs set a soft bar date of 28 May 2025 (the "Bar Date") inviting claims to relevant funds that were held by the Company on behalf of its customers.
1.2 On 9 July 2025, the JSAs sent emails and letters to all customers yet to submit a claim (and for whom the JSAs held contact details) providing them with a copy of the notice in accordance with rule 111 of the Rules.
1.3 On 27 April 2026, the JSAs, in their capacity as joint special administrators, submitted an application to the High Court of Justice, Business and Property Courts of England and Wales (“the High Court”) for the approval of a distribution plan (“the Distribution Plan”), pursuant to rules 112(2) and 114(2) of the Rules.
1.4 On 15 July 2026, following the hearing of the Distribution Plan application on 3 July 2026, the JSAs received a copy of the sealed order from the High Court, confirming that the Distribution Plan in respect of the Company was approved pursuant to Rule 114(5) of the Rules.
1.5 Accordingly, the JSAs hereby declare a first interim distribution of relevant funds to customers with an Admitted Unrestrained Relevant Funds Claim (as defined within the Distribution Plan) of 60 pence in the pound.
2. Hard Bar Date
2.1 The High Court also ordered that the JSAs shall be permitted to set a hard bar date (“the Hard Bar Date”) in accordance with regulation 21(3) and 22(1)(a) of the Regulations upon the occurrence of the trigger event for the Hard Bar Date (“the Hard Bar Date Trigger”). In this regard, the Hard Bar Date Trigger will be the determination by the JSAs that:
a. No further recoveries will be made by the Company and that, accordingly, no further moneys will be transferred to a relevant funds account pursuant to Regulation 13(8); and
b. There are no relevant funds held by the Company which are the subject of restraint or confiscation proceedings or have been segregated due to concerns that they may constitute criminal property pursuant to the Proceeds of Crime Act 2002.
3. Further Distributions
3.1 The JSAs intend to declare a second and final distribution, as soon as reasonably practicable following the Hard Bar Date, to customers who have submitted an Admitted Unrestrained Relevant Funds Claim.
3.2 In accordance with the Distribution Plan, the Costs Reserve will be reviewed quarterly to determine whether it can be reduced. Any relevant funds released from the Costs Reserve following this assessment shall be distributed in accordance with the Distribution Plan.
4. Next Steps
4.1 This notice will:
(a) be sent to all Customers
(b) be advertised in the London Gazette;
(c) be sent to the FCA; and
(d) be placed on the JSAs’ dedicated special administration webpage (accessed at https://www.ips-docs.com/ using the login details previously provided).
4.2 A hard copy of this notice may be requested from the JSAs using the contact details below.
4.3 Any general queries in relation to this notice should be directed to +44 (0)20 7397 2594 or blackthorn.finance@swgroup.com. We encourage any person unsure about the scope and effect of this notice to seek independent professional advice from a legal or financial advisor.
The Joint Special Administrators act as agents of the Company and without personal liability.
Adam Stephens and Philip Hemming, Joint Special Administrators
5 August 2026
Ag TK50952
Recorded in The Gazette, issue 65151, 13 August 2026