LoginAnalysis: Something To Prove
Operation Usk was a major victory in Trading Standards’ fight against organised crime – and its success was largely the result of one woman’s staunch determination to see justice done
Richard Young, Editorial Lead Writer
Posted 23 June 2025 | JoTS Online
Content Tags: Analysis|Crime|Wales
When Mandy Flood, an Accredited Financial Investigator at the Wales Illegal Money Lending Unit, was asked by Cardiff Trading Standards, Shared Regulatory Services of Cardiff, Bridgend and the Vale of Glamorgan (SRS) to look into the bank accounts of four local shops suspected of selling illicit tobacco, vapes and nitrous oxide canisters during the covid lockdown of 2020, little did she know that she was about to unravel one of the biggest ever cases of its kind in Wales – and one which would, over the course of the next four years, turn her own life upside-down.
The investigation which followed encompassed fraud and money laundering, as well as illicit and underage tobacco sales. It also led to threats of violence and intimidation directed at Flood and her family, and sparked ongoing investigations into suspected child sexual exploitation, domestic violence and human trafficking offences.
Organised crime has become an increasingly hot topic for Trading Standards. In the latest CTSI Member Survey, it was identified as the main emerging threat to consumers and businesses. And as the Cardiff Trading Standards (SRS) investigation – codenamed Operation Usk – reveals, the tendrils of organised crime networks can run deep into local communities, with apparently innocuous shopfronts concealing much darker, more troubling realities.
As Flood explains, Operation Usk began as a fairly routine illicit tobacco investigation. “Trading Standards SRS Officers went to one specific shop time and time again, took them to court, fined them… but when they weren’t even out of the door yet, the shop had restocked with illegal products again. So they asked me to look at the financial records to see if there was any money laundering or anything else that they could add to the offences to possibly get a higher sentence.”
It was a bit like Narnia – you open it up, there’s a false backing, and then behind that were loads of cigarettes
The focus of the investigation quickly expanded from four premises in Cardiff to 57 across South Wales.
“When I started looking at the bank accounts, I could see the funds being transferred between corner shops, laundromats, car washes and barber shops,” Flood says.
Analysis of the suspects’ bank accounts revealed that residential flats above the shops were a key part of the illicit enterprise. “I said to Trading Standards (SRS), we need to get access to those; they obviously don’t store the product in the shops any more because they know you’re looking for it.”
Trading Standards (SRS) requested a search warrant from the local magistrates, but was told there wasn’t enough evidence to link the residential properties to the commercial premises below. It was the first of many obstacles that Flood overcame with perseverance and tenacity. “I could see from the financials that they were paying for these flats above,” she says. “That was enough evidence and intelligence for money laundering warrants, so instead of using the Consumer Rights Act, I used my PoCA 2002 powers, went to Crown Court and got money laundering search warrants for all the flats above the shops.
“We then did a round of inspections in the shops at the same time as the warrants for the flats above.”
Those searches uncovered an Aladdin’s cave of illicit tobacco and vapes. “Hundreds of thousands of pounds worth of tobacco was found in the flats,” Flood says. “You’re talking bedrooms floor- to-ceiling with illicit products, with a mattress on the floor to sleep on because there was no space for anything else.”
But the flats were more than just storage rooms – they were part of a sophisticated system designed to evade the scrutiny of enforcers. “They’d installed pipes behind the skirting boards leading down into the shops. They had walkie-talkies or phones – one guy sat above and then they sent the product down if someone came into the shop.”
On the basis of that overwhelming evidence, Flood requested further warrants for the rapidly growing list of suspects’ home addresses and storage facilities. In one of those homes, she says, “The suspect had built a false wall in his children’s bedroom, and put a wardrobe in front of it. It was a bit like Narnia – you open it up, there’s a false backing, and then behind that were loads of cigarettes.”
The illicit products were also being stored in vehicles parked outside the shops. “They started buying cheap cars that had been in accidents which were still in the original owners’ names. They painted the windows black and parked them on the street corners with all the product in. SRS and Operation CeCe Officers carried out test purchases on video camera, and saw them going out to the cars to get the tobacco.”
As a cat-and-mouse game between Trading Standards Officers and the suspects ramped up, the concealments became more sophisticated. “The spaces where they were hiding stuff got better,” Flood says. “At first they used big electronic magnets and when you turned the electricity off, the hides would open. But then they got to know we were going to turn the electricity off, so they started connecting the magnets to car batteries. Then they started using pulley systems from the flats above.
“As soon as we inspected one shop and found product, the people working in the shop would be shifted on to another one. They changed people working in the shops frequently and it was already difficult to identify them because they kept on changing.
“Most of them were failed asylum seekers. The modus operandi is basically, they start off working in a car wash. If they prove trustworthy, they will go to a corner shop, a barber shop, or run their own shop.
“We found during the investigation that there were links to people trafficking. That information was given to National Crime Agency (NCA). Organised Crime groups target asylum seekers to work in the shops when they are not permitted to. They were paying them very little in cash, or nothing at all, and offering them a place to stay. So they work in the shops and have to live and sleep in them. It was like modern-day slavery – but the asylum seekers did not want to support an investigation.”
Searches and test purchases which took place as part of Operation Usk resulted in more than £600,000 of unlawful tobacco product being recovered – however, it should be noted that this figure does not take into account a single cigarette actually sold to members of the public. The investigation also revealed that more than £2.9m had been laundered through various bank accounts, despite the businesses involved being principally cash-based.
A conservative estimate of the daily takings of each store involved was more than £1,000, based on messages between defendants and written records. The total value of the fraud, based on the number of stores and time period, would therefore be in the region of £3.84m.
They got to know we were going to turn the electricity off, so they started connecting the magnets to car batteries
Backlash
Sarah Smith, Team Manager (Financial Crime and Intelligence), for the Shared Regulatory Services of Cardiff, Bridgend and the Vale of Glamorgan, which also oversees the Wales Illegal Money Lending Unit, says that as the investigation gathered pace, the suspects were pushed out of town. “As soon as we ramped up [enforcement activity] in Cardiff, they displaced to Barry. The upshot was that a number of those premises were closed for some time and we significantly disrupted and displaced that gang.”
However, as the suspects began to feel the pressure, with a watertight case being built against them and a spate of arrests in 2022, they turned their attention to the woman who they blamed for it all. Ahead of the trial, Flood says, “Their shops were closed and they couldn’t return to the flats above, so they all had to get new residential addresses to be released on bail.
“Most of them came to Barry because it was cheaper there. They got flats on the high street, and at the time I lived not even 400 yards from where most of them had their new addresses.
“I should have been more aware. One of them followed me from court to my home address. I started getting phone calls in the middle of the night, saying that they’re going to burn down my house. Asking me if I know the Kurdistan mafia. Telling me they’re going to kill my husband and myself.”
In the face of such intimidation, Flood is amazingly stoic. “I’m from South Africa originally – I was a police officer there,” she says. “So that type of thing doesn’t bother me because in South Africa, that’s part of your job. I never even reported it, not realising that here it’s taken quite seriously.
“They came to my home address on a Sunday demanding their money and mobile phones back, and were quite hostile when I asked them to leave. They also sent me threatening text messages. They would sit on the pavement right in front of my door. Every time the police came around, they’d leave. My car was parked in front of my house and another car smashed straight into the back of it in the middle of the night. It caused £17,000 of damage and was in the garage for three months. I got it back for two weeks and they did it again – £11,000 of damage that time.” Since then Flood and her husband have, understandably, moved away from the area.
Neil Jones, an Investigator at the Wales Illegal Money Lending Unit who was brought in to help with the mountains of paperwork that accumulated as the case was being put together, says that in the wake of that harassment, “We had to become more anti-surveillance aware. Mandy and I tend to work a lot together, so we will do anti-surveillance tactics if we have recently been to court, just for added security.
“And we’ve got a free app where you can use your phone to check if there’s any tracker devices on your cars.”
Getting personal
Despite the constant threat of violence, Flood steadily built her case. “It took two years to get to trial,” she says. “The defendants couldn’t stay in custody so they would start coming out on bail. They used different names, different dates of birth, different addresses. I remember the day that they were starting to get their bail, the solicitors were laughing at me saying, ‘You’re never going to get to trial.’
“It was almost like I had to prove something. We kept tabs on these people. It was a full-time job to keep track of where they were going, what they were doing. They were all over the country. Some were in Birmingham, in Leicester, in Walsall, in London; when they were given bail, the ones who were illegal immigrants didn’t have a fixed address.
“We ended up working with about five different police forces just to keep tabs on the defendants that were granted bail. We didn’t factor in that it was going to take so long. We did about 86 bail applications. It came at a massive cost because it was in Crown Court, so you need a barrister every time you do a bail application or a variation. That alone became a full-time job, so Neil came on board to help with bail applications and to assist the barrister.
We kept tabs on these people. It was a full-time job to keep track of where they were going, what they were doing
Days in court
Flood was determined to throw everything she could at the case to ensure that justice was done, and that any criminal activity was disrupted as much as possible. And that meant thinking outside the box. “It became so big, we just used everything we could against them. We even got the electricity companies to come out and look at the wiring in the shops, and the water companies to look at the car washes. We found everything that was wrong and just hit them all the time.”
The Cardiff Trading Standards (SRS) team also got in touch with some of the landlords of the business premises being used for nefarious purposes. At three of the shops, Smith says, “We worked extensively with the landlord and their family. The initial landlord was completely on board, and wanted them out. Unfortunately he passed away during the period, and his family were happy to let anyone take the shop for the income. So we had hurdles to overcome, but on the whole it was more positive – the landlords decided to work with us rather than face money laundering offences, for example.”
When the case did eventually come to court, for logistical reasons it was necessary to whittle down the number of defendants from 54 to 12 – and even then, it was by no means plain sailing. “The court said that they could only deal with 12 defendants at a time due to administrative reasons,” says Flood. “But what they didn’t take into consideration, and we didn’t either, was that suddenly none of them could speak English, so they all had to have a translator. They each had their barrister and because the case was so big, some also had junior barristers and solicitors.
“There wasn’t a courtroom big enough, so they had to split the case in half. The first part of the trial was seven weeks, then a few weeks’ rest, and then we had the same trial again for seven weeks, with six defendants each time, which made it extremely expensive.
“During the trial, because it was so complex to see the links between the different shops, and I was the only one who knew how they linked financially with the next person or the next shop, it was decided that I would be the only witness and I had to read all the admissions in court. I was reading admissions and testifying every day, all day for seven weeks, and then another seven weeks.”
The trial threw up a litany of frustrations. “None of them would plead guilty,” Flood says. “A couple of them changed barristers a few times. At one stage, one of the defendants was so disrespectful, he wore shorts and cycling pants to court. The judge had to stop one of them twice and send the jury out, because he was saying, ‘I can’t see why I’m here, it’s just cigarettes. If you release me today, tomorrow I will do it again because I don’t see anything wrong with it.’ He was very disrespectful and argumentative to the court, the judge and the prosecutions barrister Lee Reynolds.”
The trial resulted in convictions of 11 members of an organised crime group for the sale of illicit tobacco, vapes and psychoactive substances, and for participating in a fraudulent business contrary to Section 9 of the Fraud Act 2006. The estimated value of the fraud was £3.84m, and five defendants were also convicted of money laundering offences, to the tune of more than £2.9m.
Operation Usk also resulted in a mass of intelligence and evidence relating to further criminal activities, including domestic violence, benefit fraud, child sexual exploitation and illegal drugs. That evidence has been referred to other agencies and investigations are ongoing.
Between them, the 11 defendants received a combined total of 27 years of immediate custodial sentences, and seven years of suspended sentences – although, because of prison overcrowding, some of those who were jailed for three years and less have already been released on licence. Proceeds of Crime Act confiscations are also on the cards, with hearings scheduled for August 2025.
Positive outcome
The outcome of Operation Usk is testament to the commitment and hard work of Flood and her colleagues. Smith believes it also establishes a benchmark for multi-agency working, and highlights the key role Trading Standards has to play in the fight against organised crime. “It was an absolutely massive case in terms of local authority resources over such a prolonged period of time,” she says. “I think the sentences absolutely reflected that. It shows the link between illegal tobacco supply and significant criminality. This case raised the profile of Trading Standards within regional policing. It was the highest scoring job in the region for some time, and it raised questions within the police as to why Trading Standards are dealing with this level of criminality.
“It was such a successful operation in terms of partnership working with immigration, HMRC, NCA and local police, especially South Wales Police Sergeant Jacob Rollnick and his team. It really cemented some of those relationships, which is great. Operation Usk also helped set up a local strategic multi-agency tasking group – Operation Taxus – where partners can bring a case to the police and everyone pitches in.”
Flood also believes that the case provides valuable lessons about how we should think about organised crime and the pervasive economic and societal damage it does. “The Government want to get rid of the deficit,” she says. “If they are serious about that, the reality is, they need to hit the streets, and hit these organisations. Because there is a huge amount of money tucked away in them.”
PLEASE NOTE: This content originally appeared on our standalone Journal of Trading Standards website (www.journaloftradingstandards.co.uk), which we are gradually migrating over to the Journal's new home on the CTSI website. Please bear with us while we complete this process. This will not affect the production of our Print Edition.
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Content Tags: Analysis|Crime|Wales
