Bluewater Capital: The Security Trustee Nominated on Multiple High-Profile Failed Investment Schemes

Thousands of people who have invested in high-interest property loan notes were told their money was protected by an "independent security trustee". In a large number of schemes, that trustee is a Birmingham firm trading as Bluewater Capital, through Blue Water Capital Limited and Blue Water Trustees Limited.

Several of those schemes have since collapsed and some appear to be on the verge of collapsing. Refundee is helping investors recover their money in a number of these schemes where Bluewater was named as the Security Trustee. To explore your options, you should contact us here. 

The schemes affected include Godwin Capital, which raised around £162 million and is in administration. Alderley Group and the Hunter Jones / HJ Collection group faces High Court action from the FCA over an alleged Ponzi scheme. Acorn Property Invest has now stopped paying investors and has proposed a special resolution to defer repayments for 12 months. Refundee is exploring options for customers in all of these schemes. 

This article reports allegations made by administrators, regulators and the press. Unless stated, they have not been proven in court, and no finding of wrongdoing has been made against Bluewater or its staff.

Who is Bluewater?

Bluewater is a Birmingham based group that has acted as the Security Trustee on a number of loan investment schemes that have gone on to fail. Two companies matter to loan note investors, and both share the same director, secretary, owner and Edgbaston office. The entities that matter are Blue Water Capital Limited and Blue Water Trustees Limited. 

In 2024, a Godwin sales email called it "Fully FCA Authorised Bluewater Capital". Blue Water Capital Limited was in fact authorised when communications went out but its FCA license was cancelled at Bluewater’s request on 17 September 2026 and Bluewater's website now says the firm "is not FCA-authorised and does not need to be".

The FCA authorised status of Blue Water Capital Limited is something that was marketed by some of the failed investment schemes to provide investors with comfort. 

The schemes and what Bluewater was supposed to do

In the below schemes, the issuer granted a debenture (fixed and floating charges) to Bluewater as trustee for the loan note holders, and sales material leaned heavily on that security. The table lists some of the schemes we have documents or Companies House records for.

What the security trust deeds actually say

We have reviewed the security trust deeds for a number of the schemes. They follow the same template, and they give the trustee a far narrower job than the sales material from some of the investment schemes suggested. For example, the trust deeds provide that:

• It acts on instructions, not on its own initiative. The trustee "may refrain from enforcing" the security unless instructed by a Specified Majority of noteholders. In the 2021 and 2023 deeds that means more than 50% by value; in the 2024 HJ Collection 5 deed it rises to more than 75%.
• It can demand to be paid first. It may refuse to act until noteholders give it an indemnity or security, "which may include payment in advance".
• It is not required to check the assets. The deeds say it is not responsible for the accuracy of information supplied by the issuer, and is not obliged to investigate the company's title to the charged assets or to insure them.
• Its costs come out first. On enforcement, recoveries pay the trustee's and administrators' costs first, then noteholders' costs, then noteholders.
• Liability is limited. It is liable only for gross negligence or wilful misconduct, and noteholders must indemnify it for its costs.

Bluewater's own emails say the same thing in plainer words: "as Security Trustee, we do not have a day-to-day role or oversight" of the issuer's activities.

Has the security helped investors?

In Refundee’s view, where Bluewater has acted, it has mostly done so after the money was gone: appointing administrators, passing on updates and approving administrators' fees.

So far, based on the investment schemes Refundee has reviewed, there is very little evidence that the security has helped investors. The clearest case is Godwin: investors were sold a "first legal charge" equal to a bank's security, and are now looking at 1p to 2p in the pound as a recovery in the administration process. As costs escalate, it may be less than that or nothing at all. This is why Refundee thinks Authorised Push Payment bank reimbursement claims are the best option. 

Three problems recur across the schemes:

1. The charge can sit over the wrong company. A charge over a fundraising vehicle is only as good as what that vehicle owns. In Godwin's case, the charged company lent the money on, unsecured, to other group companies, so the charge covered a near-empty shell rather than land or buildings.
2. Nobody was required to check. The deeds excuse the trustee from verifying the assets, the issuer's information or how money was used. A charge registered at Companies House looked like protection, but its value depended entirely on the issuer's honesty.
3. Enforcement came late and costs come first. The trustee can wait for instructions from a majority of noteholders, who rarely know there is a problem until payments stop. By then, the trustee's, lawyers' and administrators' costs are paid before investors see anything.

Bluewater did act once the schemes failed: it appointed administrators for Godwin and Empire, wrote to investors, and its deeds never promised to monitor the businesses. 

What investors can do now

The best route for reimbursement in loan note cases where you are not being paid is almost always via APP Reimbursement claims involving the underlying schemes themselves. You need to act fast as for some claims, you need to report the case to your bank within 13 months of your last payment to be eligible. So don’t wait around when a scheme stops paying you. Refundee has an unmatched track record of recovering money for investors in loan note schemes. You can see some examples of the large cases we’ve won – like Black Capital, Raedex, Gallant Building Services and many more – on the Group Actions section of our website. We’ve received coverage in the Times recently, after winning a case that opens up the potential for more than £100m of reimbursement. 

Refundee is helping investors in Godwin Capital, Alderley Group, Acorn Property Invest and HJ Collection / Hunter Jones. If you invested in any scheme where Bluewater acted as security trustee, get in touch to find out whether you have a claim.