Is this not fraud or something very close to it? It is certainly misappropriation of monies. If a limited company misappropriates monies it should set aside for PAYE, then HMRC comes down like a ton of hot bricks.
Here is a tip for you, Ms. Titcomb. If the FSA receives a complaint from members of a network that a network is withholding monies, send in one of your Swat teams and instruct the network that unless they pay what they owe to the businesses that support their existence, the FSA will shut them down and force them to pay what they owe. Is that clear enough for you?
Harvest IFM, Bristol