If you invested in the Halcyon Retreat, you are now being offered help from every direction. English solicitors offer no win, no fee claims against banks. Claims companies run surveys. A Facebook group administrator tells you to cut out the lawyers. And a French liquidator is waiting for claims that most of these people never mention.
These offers are not competing versions of the same remedy. They target different people, under different laws, in different countries. Some are open to you, some are closed, depending on where you live and which bank you paid from. One deadline is fixed and near: creditors living outside metropolitan France must file their claim in the liquidation of SAS Halcyon Retreat by 9 November 2026.
This article sets out each route, its legal basis, who it is aimed at and who it leaves out. The detail of the French liquidations is covered in a separate guide.
Invested in the Halcyon Retreat resort in France? Where your claim really stands
Can a Halcyon investor claim in England and in France? The short answer
Yes, a Halcyon investor can claim in England and in France, but the two sets of routes target different defendants. English routes claim against a solvent third party: your bank (Financial Services and Markets Act 2023, s. 72), a regulated adviser or pension operator before the Ombudsman, or the compensation scheme when that firm has failed. French routes claim against the Halcyon companies and the suspects: a proof of claim in the liquidation (art. R. 622-24 French Commercial Code) and civil-party status in the Bordeaux investigation (art. 87 French Code of Criminal Procedure). A non-UK investor usually has access to the French routes only.
Three different targets, three different logics
Every recovery route answers one question: who pays?
- Your own bank, for having executed a payment obtained by fraud. This is the English bank reimbursement route.
- A regulated professional, for having advised you or accepted the investment into your pension. This is the Ombudsman route, and the compensation scheme when that professional has failed.
- The Halcyon companies and the individuals behind them, whose assets are frozen or under the control of a liquidator. These are the French routes.
The first two target solvent institutions, which is why English firms can work on a no win, no fee basis. The third targets the wrongdoers themselves, whose assets must first be traced, seized and distributed. Knowing which target each adviser is aiming at tells you what they can realistically deliver.
The English routes
Can your UK bank reimburse a payment made to Halcyon?
Yes, a UK bank can reimburse a payment made to Halcyon if it qualifies as an authorised push payment fraud. Since 7 October 2024, reimbursement is mandatory for payments sent by Faster Payments or CHAPS between UK accounts, up to £85,000 per claim (Financial Services and Markets Act 2023, s. 72). Earlier payments fall under a voluntary banking code, the Contingent Reimbursement Model Code, in force from 2019.
The conditions are strict. The claim must be made within 13 months of the last payment for the mandatory scheme. International payments are excluded. So are « civil disputes », meaning an investment in a genuine business that simply failed. Gross negligence by the customer is a defence for the bank.
That civil dispute exclusion explains the timing of the English offers. For years, a bank could answer that Halcyon was a property development that went wrong. The criminal investigation changes the picture. One Manchester firm wrote that the arrest of Robin Barrasford « may make it easier for us to make claims on behalf of our clients ». The route it names is « bank fraud reimbursement models » (Richardson Hartley Law, Halcyon Retreat help page). The suspects remain presumed innocent until a court rules otherwise.
What does the Financial Ombudsman Service do for Halcyon investors?
The Financial Ombudsman Service decides complaints against UK regulated firms, and its decisions bind the firm once the investor accepts them (Financial Services and Markets Act 2000, s. 228). For Halcyon, its main use is against the operators of self-invested personal pensions (SIPPs) that accepted Halcyon investments into a pension wrapper.
The leading example is a published decision against London & Colonial Services Ltd (Financial Ombudsman Service, decision DRN-4910126). An investor had transferred £154,000 into a SIPP and placed £134,000 in the Château de la Cazine. The Ombudsman found that the operator had accepted business from an introducer, ARLWM Ltd, without adequate checks. It had not verified the development, the guarantees or the financial standing of the guarantors. The complaint was upheld: compensation for the loss, interest and £750 for distress.
The same logic has reached other links in the chain. In two further published decisions, the Ombudsman upheld complaints against the investors’ former pension providers, which had allowed transfers to self-administered schemes (SSAS) that then invested in Halcyon, without the checks and warnings expected at the time (Financial Ombudsman Service, decisions DRN-4986428 against ReAssure Limited and DRN-5231926 against Zurich Assurance Ltd).
These complaints do not always succeed. In another decision, the adviser was not held liable for the Halcyon loss, because the Halcyon investment was made two years after its advice, which broke the chain of causation (Financial Ombudsman Service, decision DRN2356401 against Alexander Beard).
Time limits apply. A complaint must generally be brought within six years of the event, or within three years of the date the consumer knew or should have known there was cause to complain; after a firm’s final response, the consumer usually has six months to refer the complaint to the Ombudsman (Financial Ombudsman Service, time limits). For investors who entered in 2011 to 2015, that question has to be examined first.
The Ombudsman’s award limit was £415,000 for acts after 1 April 2019 and £190,000 for earlier acts, as set on 1 April 2023 and indexed each year (Financial Ombudsman Service, award limits). The service is free for the consumer.
When the adviser has failed: the FSCS
The Financial Services Compensation Scheme pays compensation when a regulated firm has failed and cannot meet a claim for bad advice. ARLWM Ltd, trading as Montgomery Financial Consultants, was declared in default on 4 March 2020 (FSCS, failed firm page). Its former clients may claim.
The limit for bad investment advice is £85,000 per person per firm for failures after 1 April 2019 (FSCS, what we cover). A figure of £120,000 circulates in some investor communications. That figure is the limit for bank deposits since 1 December 2025, not the limit for investment advice.
What the English routes cannot do
The English routes do not reach the Halcyon companies, the frozen estate or the suspects’ assets. They are also closed to most non-UK investors. A Belgian, Dutch, Danish or Omani investor who paid from a bank in their own country has no English bank to claim against. Unless they dealt with a UK regulated adviser or pension operator, the Ombudsman and the FSCS are out of reach too.
The French routes
Filing a proof of claim in the liquidation of SAS Halcyon Retreat
SAS Halcyon Retreat (RCS Guéret 529 259 160) was placed in judicial liquidation by the Commercial Court of Guéret on 23 June 2026. The liquidator is Maître Axel Ponroy, of Saulnier-Ponroy et Associés. The judgment was published in the BODACC, the official gazette, on 9 July 2026 (BODACC A n° 129, notice 2906).
The deadline to file a proof of claim (déclaration de créance) is two months from publication. It is extended by two months for creditors living outside metropolitan France (art. R. 622-24 French Commercial Code). That gives 9 September 2026 for creditors in metropolitan France, and 9 November 2026 for everyone else.
A creditor who missed the deadline is excluded from distributions. The only way back is an application for relief (relevé de forclusion) by 9 January 2027, six months after publication (art. L. 622-26 French Commercial Code). The creditor must show that the delay was not their fault, or that the company omitted them from its list of creditors. The conditions are set out in a dedicated article on relief from forfeiture in the Halcyon liquidation.
A distinct position belongs to investors whose loan notes were issued by a UK special purpose vehicle and guaranteed by SAS Halcyon Retreat. The claim under the guarantee can be filed in the French liquidation without waiting for the borrower’s formal default (art. L. 622-25 French Commercial Code), as explained in a dedicated article on Halcyon loan notes guaranteed by SAS Halcyon Retreat.
Joining the criminal case as a civil party
A judicial investigation is open in Bordeaux, before the specialised financial crime court (JIRS), for organised fraud and money laundering. An investor joins the existing investigation by filing as a civil party (constitution de partie civile, par voie d’intervention), without a new complaint (art. 87 French Code of Criminal Procedure).
Civil-party status gives access to the file through a lawyer, the right to request investigative steps, and the right to claim damages at trial. A civil party living outside the jurisdiction must give an address in France, which is usually the lawyer’s office (art. 89 French Code of Criminal Procedure). The seized estate is held by the French asset recovery agency, the AGRASC.
Can you claim against a French or EU bank instead?
In principle, no French or EU equivalent of the English mandatory reimbursement exists. A transfer executed to the account number given by the customer is deemed correctly executed (art. L. 133-21 French Monetary and Financial Code). A bank’s liability then depends on proving that it ignored an obvious anomaly, which is a far narrower route than the English scheme (see, in French, fraude au virement bancaire et remboursement par la banque).
When the convicted persons do not pay: AGRASC, SARVI and CIVI
A civil party awarded damages that remain unpaid can ask the French asset recovery agency, the AGRASC, to pay them in priority from the assets confiscated from the person convicted (art. 706-164 French Code of Criminal Procedure). How far that reach extends abroad is explained in a dedicated article on seizing Halcyon assets abroad.
A criminal judgment awarding damages is only worth what can be recovered. When the damages remain unpaid two months after the decision becomes final, an individual victim can apply to the SARVI, the victims’ recovery assistance service (art. 706-15-1 French Code of Criminal Procedure). It pays the full amount up to €1,000; above that, it pays 30% of the award, with a minimum of €1,000 and a maximum of €3,000, then pursues the offender for the balance (Fonds de garantie, SARVI page). The application must be filed within one year of the decision becoming final (Fonds de garantie, SARVI page). A common mistake is to think that the SARVI must be approached within two months of the final decision. The two months are only the period during which the offender must have failed to pay; the application itself can be filed for a year. The two schemes are compared, in French, in an article on CIVI, SARVI et FGTI.
The CIVI, the victims’ compensation commission, also covers fraud. Its access is limited by income conditions and a serious material or psychological situation (art. 706-14 French Code of Criminal Procedure).
Can you use the English and French routes together?
Yes, a UK investor can pursue English and French routes together, because they target different debtors. A bank reimbursement does not extinguish the claim against SAS Halcyon Retreat.
What is not settled is the effect of a partial English recovery on the French claim. Two readings are possible. On the first, the investor declares the full loss and accounts for any English recovery at distribution. On the second, a bank that reimbursed may seek to take over part of the investor’s claim. The terms of the reimbursement will decide between them. In both readings, the conduct is the same: file the French claim in full before the deadline and disclose any English recovery.
Why a French lawyer cannot act on a no win, no fee basis
French law forbids a lawyer’s fee fixed solely by reference to the result (art. 10 of Law No. 71-1130 of 31 December 1971). A success fee is lawful only on top of a fee for the work done. French lawyers therefore work on a retainer, with an agreed hourly rate, and sometimes an additional success fee.
This is not a matter of choice. An English firm can act on a contingency basis because English law allows it and because its target, a bank or a regulated firm, is solvent. A French lawyer filing against a liquidated company and suspects whose assets are frozen cannot legally take that bet.
Recovery advocates: questions to ask before you send your documents
Alongside solicitors, individuals present themselves as independent advisers to victims. One example comes from the Facebook group REVIVE (Reimbursement for Victims of Investment Violations & Exploitation). Its administrator posts as « Jack Russell », on a page titled « Jack Can Get Your Money Back ». He wrote to Halcyon investors:
« Law firms will typically charge about 30% (inc VAT) which gets deducted from any settlement. […] I have worked as a consultant for law firms for years. […] Cut out the law firms, deal directly with a fraud recovery advocate like myself. You’ll get better service, more experience and you’ll pay a lot less in costs. »
The same administrator published a registration form for Halcyon investors for « collective litigation against the banking industry in the UK ». In another post, he wrote: « I can introduce victims to law firms that provide litigation facilities. » Investors in the group have also asked where to obtain an « M1-Law, Halcyon application form ». M1 Law Limited is a firm of solicitors regulated by the Solicitors Regulation Authority (SRA number 8001710).
The service described is therefore paid, and it ends, for litigation, with a law firm. In the United Kingdom, advising on or investigating a financial services claim, and referring potential claimants, are regulated claims management activities (Financial Services and Markets Act 2000 (Regulated Activities) Order 2001, arts 89G and 89H). Carrying them on without authorisation is prohibited (Financial Services and Markets Act 2000, s. 19).
Before sending bank statements, contracts or identity documents to anyone, whether an individual, a company or a law firm, ask five questions:
- What is your full legal name, and that of your company?
- What is your FCA or SRA registration number? Check it yourself on the FCA register or the SRA register.
- Which insurer covers your professional liability, and up to what amount?
- How are you paid, and do you receive anything from the firm you refer me to?
- Where do I complain if something goes wrong? An authorised claims company or a solicitor answers to a regulator and to the Financial Ombudsman Service.
A professional who answers all five in writing has nothing to fear from them. As for the 30% figure, the FCA caps a claims company’s fee on financial services claims at between 15% and 30% depending on the amount recovered, with a maximum of £10,000 (FCA Handbook, CMCOB 5.2). A complaint to the Ombudsman or the FSCS made by the investor directly costs nothing.
Questions Halcyon investors are asking
I filed a claim in the Château La Cazine liquidation. Am I covered?
No, a claim filed in the Château La Cazine liquidation does not cover SAS Halcyon Retreat. They are two companies with two registration numbers (538 239 823 and 529 259 160), two judgments and two deadlines. Many investors filed by 28 February 2026 in the first liquidation, as advised on review sites. If your contract or payment points to SAS Halcyon Retreat, a second filing is needed by 9 November 2026.
I issued county court proceedings in England. Is that enough?
No, English court proceedings do not replace a proof of claim in the French liquidation. Once SAS Halcyon Retreat is in liquidation, individual actions for payment against it are stopped in France (arts L. 622-21 and L. 641-3 French Commercial Code). A claim against a UK entity, such as Halcyon Retreat UK Ltd, is a separate matter, governed by English law.
I reported the fraud to the City of London Police and to my MP. Am I a party to the French case?
No, a report to a UK police force or to an MP does not make you a party to the French investigation. Only a civil-party filing with the investigating judge in Bordeaux does (art. 87 French Code of Criminal Procedure). A UK report remains useful: it adds to the evidence shared between police forces.
The company promised me repayment in writing. Does that help?
Yes, a written promise of repayment helps, in two ways. It is evidence of the debt and of the representations made to you. It may also restart the French limitation period, since an acknowledgment of the debt by the debtor interrupts it (art. 2240 French Civil Code). This matters for investors from 2011 to 2014, where the five-year period (art. 2224 French Civil Code) would otherwise be a serious obstacle. Keep every email, payment plan and investor update.
What percentage can I expect to recover?
No one can say today. The recovery depends on what the liquidator realises and on the order of payment, where employees, costs of the proceedings and secured or preferential creditors come before ordinary creditors (art. L. 643-8 French Commercial Code). The assets seized in the criminal case follow a separate track. Any figure quoted now, whether 0% or 10%, is a guess.
Can we bring a class action?
The French routes described here are individual. Each investor files their own proof of claim and their own civil-party application, even if a group of investors coordinates and instructs the same lawyer. A group helps to pool evidence; it does not replace individual filings.
Your next step, depending on where you live and how you paid
You live in the UK and paid from a UK bank
You may have up to four routes: your bank, the Ombudsman if a regulated adviser or pension operator was involved, the FSCS if that firm has failed, and the French routes. The English routes are handled by an English solicitor or authorised claims company. The French proof of claim must still be filed by 9 November 2026, whatever happens in England.
You live elsewhere in the European Union
The English bank route is closed to you if you paid from an EU account. Your recovery rests on the French proof of claim, the civil-party filing and, after a conviction, payment from confiscated assets through the AGRASC (art. 706-164 French Code of Criminal Procedure) or the SARVI. Your deadline for the proof of claim is 9 November 2026.
You live outside Europe
The same applies: French routes, same deadline. The civil-party filing will require an address in France for service of documents.
You live in metropolitan France
Your deadline to file expired on 9 September 2026. Relief from forfeiture remains possible until 9 January 2027, if the delay was not your fault or if the company omitted you from its list of creditors (art. L. 622-26 French Commercial Code). The civil-party route remains open until the investigation is closed.
In all cases, the first document to produce is proof of payment: it shows which company received your money, and therefore which liquidation and which route are yours.
Suing in France: a Practical Guide for Foreign Claimants
Your case, not the general rule
What the rules do not say is how they apply to your own contract, your own payments and your own country of residence. Two investors in the same building can hold claims against different companies, under different deadlines. The facts count as much as the law, and that is where a lawyer’s work begins.
Valentin Simonnet is a member of the Paris Bar (avocat au Barreau de Paris). He practises in business litigation and white-collar criminal defence.
