Latest Offenders Neath

Description

A sexual predator has been convicted of raping and sexually assaulting two males and a female under the age of 18 more than 20 years ago. He was brought to justice after one of his victims reported the abuse to police in 2019.

John Webb, 70, was arrested at his home in Neath after an investigation was launched by the force. A further two victims were also identified and provided statements. All three victims were under the age of 18 at the time of the abuse, which took place in Cardiff in the 1990s.

The defendant faced trial at Cardiff Crown Court last year and was convicted of 21 charges including three counts of rape, five indecent assaults, and seven counts of indecent assault on a male. He was sentenced to 24 years imprisonment, at the same court, on March 8.

Following the hearing, detective constable Jenna Hargraves, of South Wales Police, said: "Webb’s actions have taken a massive emotional toll on all three victims. For one of them, their life headed towards criminality because they struggled to cope with what had happened. Another victim described Webb as a violent man. But thanks to their bravery and a thorough investigation, he has been brought to justice.

"South Wales Police takes all reports of sexual violence extremely seriously and it is never too late to report a crime. Help and support is available for all victims of sexual violence, and we would encourage any victims; no matter how long ago the offence happened, to please come forward. If anyone has any more information about this or similar matters, and they have not yet spoken to police, please come forward."

Description

A delivery driver arranged to meet a schoolboy and go back to his house while he was in the course of making drop-offs in the company van, a court has heard. When father-of-two Tyrone Felton arrived at the rendezvous he was was met not by a child but by plain clothes police officers, and an examination of the van revealed its internal CCTV cameras had been covered up.

Sending the 54-year-old to prison a judge at Swansea Crown Court told him the sooner he came to terms with the fact he had "paedophile tendencies" the better it would be for him and for society. He said he sincerely hoped the defendant would take advantage of sex offender education programmes that were available behind bars.

Dean Pulling, prosecuting, said in February this year a decoy profile purporting to belong to a 14-year-old boy was deployed on social media as part of an operation by Tarian, the southern Wales organised crime unit, to identify potential online sex offenders. He said Felton - who was going by the online name Dave1 - made contact with the profile and they began chatting. The court heard the decoy talked about school and made it clear he was aged 14, and Felton said that was fine. During the conversation Felton asked the boy about his underwear and asked if he could "accommodate" if they were to meet.

The court heard Felton told the decoy he was a delivery driver and was currently in Cowbridge heading west to Haverfordwest, and plans were made to meet "at a public place" in Carmarthen so the defendant could pick up the boy and go to the teen's house. At lunchtime Felton arrived at the rendezvous in his van to be met by undercover police officers who had been sent to the location. The court heard that when the defendant's van was searched officers found the internal CCTV cameras in the vehicle had been obscured by a fleece jacket and caps. The defendant was taken to Dafen police station and subsequently answered "no comment" to all questions asked in interview. Mr Pulling said as the Tarian operation was ongoing the name being used by the decoy profile, the social media platforms it was operating on, and the location of the meeting point in Carmarthen would no be revealed in open court.

Tyrone Felton, of Heol Heddwch, Seven Sisters, Dulais Valley, Neath, had previously pleaded guilty to attempting to meet a child following sexual grooming, attempted sexual communications with a child, and arranging or facilitating the commission of a child sexual offence when he appeared in the dock for sentencing. He has a conviction from 1991 for gross indecency with a child and attempted kidnapping of a child, an incident which saw him exposing his penis to young children and inciting them to touch it.

Harry Dickens, for Felton, said the defendant had gone online to meet and talk to men but his use of the apps "spiralled", and he said the father-of-two could not explain what had precipitated offending that was before the court. He said the defendant "wished he had never done it" and was "deeply sorry".

Judge Paul Thomas KC said the defendant's antecedent record showed that he had had "paedophile tendencies" for a considerable period of time and it may be that sometimes they were "latent" and others "active". He said it was clear from the contents of the pre-sentence report that Felton was in denial, and he told the defendant that the sooner he came to terms with that fact he had a problem the better it would be for him and for society. He noted Felton was not particularly remorseful for his actions but was remorseful for the impact on his family.

With a one-third discount for his guilty pleas Felton was sentenced to two years in prison - he will serve up to half that period in custody before being released on licence to serve the remainder in the community. He was made the subject of a sexual harm prevention order for the next five years, and will be a registered sex offender for the same length of time. Judge Thomas told Felton he sincerely hoped he would take advantage of sex offender education programmes that were available in custody.

Description

A child sex offender was found trying to find a secret phone that he had not told the police about - the third time he has been caught breaching a sexual harm prevention order.

Paul Evans has been required to log any mobile he owns with police after being convicted of attempting to meet a 12-year-old girl for sex following online grooming. But an unannounced visit by police to the hotel where he was living uncovered a secret phone. Swansea Crown Court heard the 55-year-old has been assessed as posing an on-going risk of reoffending.

Brian Simpson, prosecuting, said in on July 28 this year police officers went to Evans' room in the Ambassador Hotel in Neath town centre after receiving information that the defendant may be in possession of a phone. The officers knocked on the door and the defendant answered "in a state of undress" having apparently just go out of bed. Evans asked for time to dress but officers became suspicious of the time he was taking and entered the room - they found him trying to hide a mobile phone under his pillow. The court heard the phone was being used to carry out a video call with a woman.

The prosecutor said the phone had not been notified to the police, and Evans was arrested on suspicion of breaching a sexual harm prevention order (SHPO). The SHPO was imposed in 2018 after the defendant was convicted of sending hundreds of explicit messages to what he thought was a 12-year-old girl and leaving sexual voicemails on her phone before turning up to an arranged meeting. In fact Evans had been communicating with a "decoy" account being run be so-called paedophile hunters, and he was subsequently sentenced to two years in prison. However, just a matter of months after being released on licence from prison from that sentence he acquired a Motorola G7 smartphone which he kept hidden from the police. On that occasion his offending was spotted by eagle-eyed staff at a Job Centre who contacted detectives, and he was subsequently sentenced to eight months in prison for breaching the SHPO.

The court heard Evans breached the SHPO again in October 2021 when he once again contacted a social media profile that purported to be that of a 12-year-old girl but which was in reality a decoy account. The pair's conversation moved to the WhatsApp messaging service where, despite being repeatedly reminded of the girl's supposed age, Evans talked about sexually explicit matters, told the girl he loved her, asked her for sex, and invited her for "sleep-overs" at his house. The pair arranged to meet at the McDonald's restaurant in Baglan on the evening of November 13 and when the father-of-two turned up at the allotted time he was met by members of the paedophile hunter group who then called the police. Evans was sentenced to two years and eight months in prison with the judge noting it was "unfortunate" that the Crown Prosecution Service had made an error in charging Evans, an error that meant he could not consider imposing an extended sentence on Evans.

Paul Evans, formerly of Kennel Row, Briton Ferry, Neath, but now of The Parade, Neath, had previously pleaded guilty to breaching a SHPO when he appeared in the dock for sentencing. Giles Hayes, for Evans, said after being released from his last prison sentence in April this year the defendant had been housed in the Ambassador Hotel. He said Evans had formed a relationship with a woman and had been using the phone to contact her rather than for "sinister purposes".

Judge Catherine Richards told Evans he had committed a deliberate breach of the court order and, given his previous convictions and the assessment of probation staff, it was clear he posed a high risk of causing very serious harm and there was no alternative to immediate custody. The judge said that the appropriate sentence after trial on the guidelines was one of 30 months in prison - with a one-third discount for his guilty plea Evans was sentenced to 20 months. The defendant will serve up to half that period in custody before being released on licence to serve the remainder in the community.

Description

A SCHOOL crossing patrol man has been jailed after he was caught attempting to meet who he thought was a 15-year-old girl for sex.

Stephen Cordy, 55, messaged a social media account set up by a member of a paedophile hunter group on April 11.

They began messaging, and the decoy account stated she was 15 years old.

Cordy said he worked in a school, and asked how he would know the account was not an undercover police officer or a decoy, prosecutor Sian Cutter said.

The decoy sent two pictures of an “age appropriate” girl, and Cordy replied that she was “pretty” and asked about the school she went to.

They arranged for him to come to her house in Drefach on Sunday, April 16.

He asked if he should bring anything, and when asked what, Cordy suggested she might want to tie him up.

“She said she wanted a cwtch, and [Cordy] said it may lead to other things,” Ms Cutter said.

He added he would bring a condom, and when the decoy expressed surprise, the defendant said she “would be fine as [she] had done it before”.

 A school crossing patrol man was caught attempting to meet who he thought was a 15-year-old girl for sex (Image: Stock Image)

On the agreed date, Cordy messaged the decoy saying he was at the address. The man behind the decoy account left his address and walked down the street to confront him – recording the meeting.

“He said he was only planning to meet her for a coffee and a chat,” said Ms Cutter.

Cordy tried to walk away, but the man threatened to post the video on social media if he did. Cordy admitted bringing condoms to the meeting, but said he always carried them.

Following the confrontation, Cordy drove off, and the man noted down his registration number.

The court heard the man did not contact the police – later saying he was busy moving house – but did post the video on social media.

Ms Cutter said several members of the public contacted the police concerned about the content of the video.

Cordy was arrested by police on April 28 while parked in a layby near Neath.

Ms Williams, defending, said: “I cannot offer the court any reasons for the offending.

“He expresses a willingness to work with the probation service, but because he won’t recognise his offending behaviour for what it is, they feel they are unable to manage the risk.  

“I’m afraid I’m in a difficult position to argue for anything other than an immediate prison sentence.”

Ms Williams said that Cordy, who had pleaded guilty to the offences, had no previous convictions.

The court heard Cordy remained silent when interviewed by police.

“You had nothing to say. You couldn’t have said anything. The game was up,” said Judge Huw Rees.

“This is a significant fall from grace for you in terms of your relationship with your wife, your accommodation, and your job prospects in the future.”

Judge Rees sentenced Cordy to 13 months in prison for meeting a child after sexual grooming, and six months – running concurrently – for attempting to engage in sexual communication with a child.

Cordy, of no fixed abode, must register as a sex offender for 10 years, and was made the subject of a sexual harm prevention order for the same period.

Description

A man has been jailed after he groomed a vulnerable young girl and committed multiple sexual offences against her. Dennis Davies, aged 64, carried out the string of abuse over the course of around a year after “significant planning and grooming”.

Davies, previously of Pen y Bryn in Skewen, near Neath, was found guilty of two counts of assaulting a girl under 13 by penetration and five counts of sexual assault on a girl under 13 following a trial last month. At a sentencing hearing held at Swansea Crown Court on Monday, prosecution barrister Ian Wright outlined the severity of Davies’ crimes, and the fact that he knew of his victim’s vulnerability and implored her not to tell anyone of the sexual offences he was inflicting upon her.

In a victim impact statement read in court, the victim said that what she endured left her so distraught that she tried to take her own life, while her mother also had a statement read out in court in which she explained the “massive change” she has seen in her daughter since the abuse started. In mitigation, defence barrister Ieuan Rees said Davies had no previous convictions and had been a “productive member of society” who had “never been in trouble of any sort before”.

As Judge Geraint Walters summed up the case, two people in the public gallery got up and left the courtroom, such was the severity of the “multiple offences” he was describing. He said: “Over a period of about a year you routinely and persistently sexually abused her. You recognised her vulnerabilities. You carried out a variety of sexual offences against her.” The Judge concluded his remarks by saying that the victim has been “left with life-long consequences” because of what Davies did.

Davies was sentenced to a total of 16 years in prison, made up of 15 years plus an extension of a year due to being “an offender of extreme concern”. He was told that he will not be considered for early release for at least two-thirds of that sentence, and that he will have to remain on the sex offenders’ register for the rest of his life. A life-long restraining order was also made, prohibiting him from contacting his victim ever again.

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Christopher Burford's despicable crime was discovered by police investigating the downloading of indecent images

A man photographed himself as he sexually abused and assaulted a baby. Christopher Burford's vile activities were uncovered by police who initially suspected he had been downloading indecent images from the internet and seized his mobile phone for analysis. The 45-year-old has now been given extended sentence as a dangerous offender.

Swansea Crown Court heard that, acting on intelligence, officers attended Burford's house in Pontneddfechan at the top of the Neath Valley in February this year. Ian Wright, prosecuting, said the defendant's phones were subject to an on-the-spot examination and evidence of indecent material was found. The defendant was arrested and interviewed and told officers that he had met a man on an adult swinging website who disclosed sexual offending and claimed he had then begun to carry out an investigation into paedophiles in the area because he wanted to keep children safe. Burford was released on bail while a full digital analysis of his phone was carried out.

The court heard a total of 1,032 images of children being sexually abused were discovered on Burford's Samsung device and while most had been downloaded from the internet it appeared some had been taken by the defendant himself. Further work was done on the phone and it emerged that more than 100 pictures showing a baby being sexually assaulted had been taken by the defendant. Police were subsequently able to identify the child involved. Mr Wright said it was not possible to establish the dates when Burford had taken the pictures. The defendant was interviewed for a second time following the discovery that he had taken some of the photos and this time he answered "no comment" to all questions asked.

Burford, aged 45, of Dinas Street, Pontneddfechan, Glynneath, admitted four counts of sexual assault of a child under 13, two counts of assault by penetration of a child under 13, the taking of indecent images of Category A, Category B, and Category C, and possession of indecent images. He has no previous convictions. Read about a 63-year-old man with an "unhealthy interest in young girls" sent teens vile messages.

Dyfed Thomas, for Burford, said the best mitigation he could put before the court were the defendant's guilty pleas though he acknowledged they had been entered in the face of "overwhelming" evidence of guilt. He said while the pre-sentence report into Burford questioned his remorse for what he had done he was instructed that his client was genuinely remorseful.

Judge Geraint Walters said Burford had abused a "helpless" baby and said while the courts deal with cases of sexual offending every day some stand out due to the nature of the offending and this was just such a case. He said he was satisfied the defendant should be categorised as a dangerous offender in meaning of the relevant legislation and therefore made the subject of an extended sentence.

Burford was given an 18-year extended sentence comprising 12 years in prison followed by a six-year extended licence period. He must serve two-thirds of the custodial element of his sentence before he can apply for release but it will be for the Parole Board to determine when he is safe to be let out and on what conditions. The defendant will be a registered sex offender for the rest of his life and was made the subject of an indefinite sexual harm prevention order.

Description

A paedophile who tried to groom a young girl on Instagram was caught after a mum became concerned about changes in her daughter's behaviour, a court has heard.

The mother asked to look at the schoolgirl's mobile and saw she had sent a friend a screen shot of a conversation she had had with a man on the social media site during which the unknown male had asked her for a photo, and discussed meeting. The mum subsequently contacted a so-called paedophile hunter group which took over the youngster's accounts.

Over the following weeks Jose Pardinez-Olea sent a series of sick sexual messages and requests to what he still believed was the 12-year-old girl he had originally been chatting to, including videos of himself masturbating and urinating. Sending the 41-year-old to prison, a judge told him he had no doubt he had intended harm to the girl.

Swansea Crown Court hard that in early 2020 the mother of a girl living in the county of Rhondda Cynon Taf became concerned about changes in the youngster's behaviour, including in the way she was eating and way she used her phone.

Dean Pulling, prosecuting, said the mum asked to see her daughter's mobile, and on the device found an Instagram screenshot the girl had sent a friend which showed a conversation she had been having with an unknown male calling himself Josh. During the course of the conversation Josh had asked the girl to send him a photograph of herself, and had mentioned meeting at his house in Port Talbot.

The prosecutor said the original conversation had been deleted but the mum was so concerned she synced her phone to her daughter's so she could monitor her social media activity. The man calling himself Josh continued to message the Instagram account, and the mother began to reply as her daughter until Josh sent a photo of his penis - at that point the woman contacted the police and a paedophile hunter group.

The court heard a member of the group took over the running of girl's accounts, and over the following weeks Josh - later revealed as Pardinez-Olea - sent a series of highly sexual messages as well as naked pictures of himself via WhatsApp. The court heard the defendant also sent photographs of scenes from pornographic films he was watching, videos of himself masturbating and urinating, and tried to get the youngster to perform sexual acts on herself.

The paedophile hunter group running the accounts then contacted a similar group in Wales who confronted Pardinez-Olea at his then-home address at Ynys Street in Port Talbot. Police were called and the defendant was arrested. Officers seized his phone, and also recovered a small amount of cannabis from the property.

The court heard police sent the evidence in the case to the Crown Prosecution Service (CPS) for a charging decision in early 2021 but the file was returned as it was incomplete. It took another six months for the file to be resubmitted, and the CPS authorised charging in August though it was not until February 2022 that the defendant was charged via postal requisition. The prosecutor said the delay was "clearly not acceptable".

Jose Pardinez-Olea, now of Elias Street, Neath, had previously pleaded guilty to attempting to cause a girl under 13 to engage in sexual activity, attempting to engage in sexual communication with a girl under 13, attempting to cause a girl under 13 to watch images of sexual activity, and possession of cannabis when he appeared in the dock for sentencing. He has one previous conviction for one offence, that of driving with excess alcohol.

Giles Hayes, for Pardinez-Olea, said the defendant's arrest had been a "wake up call" for him, and he had stopped drinking and taking drugs, and had returned to work. He said his client was keen to stress that his behaviour at the time of the offending had been effected by isolation, loneliness, and substance misuse.

Recorder David Harris noted that the author of the pre-sentence report concluded that with appropriate treatment there were good prospects of rehabilitation, but he told the defendant he had no doubt that he had intended to cause harm to the child he believed he was communicating with.

With a one-third discount for his guilty pleas Pardinez-Olea was sentenced to a total of four years in prison. He will serve up to half that period in custody before being released on licence to serve the remainder to the community. He will be a registered sex offender for the rest of his life, and was made the subject of an indefinite sexual harm prevention order.

Description

A sex offender was found hiding a boy and a girl who were from children's homes in a wardrobe in his bedroom. Just weeks after police made the shocking discovery, Jamie Roberts took two boys - again vulnerable teens living in care - back to his house where they drank alcohol and took drugs - and he suggested getting amphetamine as it "makes you really horny".

Roberts, who also goes by the name Jamie Whelan, is currently subject to a sexual harm prevention order after being convicted of child abduction.

Swansea Crown Court heard that early in the morning of December 21 last year police in Swansea were notified that two teenagers - a girl and a boy - had failed to return home to their respective care homes by the allotted curfew times the previous night. Kevin Jones, prosecuting, said the police investigation led to Roberts' flat in Skewen, and at 3.40am officers knocked on his door. The court heard the lights were on in the property but the officers' knocks went unanswered, though they noticed the blinds in a window were twitching. Officers kept knocking and eventually Roberts answered - despite being fully clothed he told his callers he had been asleep.

The house was searched and it initially appeared Roberts was alone. However, officers noticed a big pile of bedding and clothes stacked up in front of a wardrobe in one of the bedrooms. And when officers moved the items, and opened the wardrobe, they found the missing children hiding inside. The teenagers were returned to their care homes and Roberts was arrested. In his subsequent interview the 35-year-old defendant provided a prepared statement in which he said the children had asked him to hide them, and that they had taken cocaine and amphetamine. After being questioned Roberts was released under investigation.

The court heard the second incident happened on February 28 this year and involved the same teen boy along with another male youth who was also living in care. The prosecutor said on this occasion Roberts met the boys at Swansea railway station and took them back to his home in Skewen. During the evening the trio drank alcohol and the two teens smoked cannabis, and Roberts suggested getting amphetamine as it "makes you really horny". At around 4am an argument broke out and Roberts chased the boys from his flat - apparently at knife-point. One boy rang his care home and a member of staff drove to Skewen to collect him. Roberts was again arrested and admitted arranging to pick up one of the boys from the station - but said he had been surprised to find the youngster was not alone.

Jamie Paul Roberts, of New Road, Skewen, Neath, had previously pleaded guilty to breaching a sexual harm prevention order when he appeared in the dock for sentencing. He has 19 previous convictions for 22 offences including a number for sexual offences beginning with the indecent assault of a girl when he was a juvenile - this involved him assaulting a girl in public toilets on a beach. In 2005 he was convicted at Swansea Crown Court of breaching a sexual harm prevention order, and convicted of the same offence two years later at Stratford Crown Court. However, the court did not hear details of these breaches.

In 2021 he was sentenced to a two-year community order for child abduction - this offence involved a young boy staying in his property in defiance of a child abduction warning notice issued by police following concerns raised by the boy's dad about the nature of the defendant's relationship with his son.

Ian Ibrahim, for Roberts, said the defendant's childhood had been "nothing short of a disaster for him". He said Roberts was taken into care at the age of four and put on anti-psychotic drugs because of his behaviour, and that was followed by a period of living with 10 different foster families and in five foster homes, as well as being bullied at school. The barrister said the defendant had subsequently been diagnosed with a number of conditions including personality disorder, attention deficit hyperactivity disorder, obsessive-compulsive disorder and depression. Mr Ibrahim said Roberts had been the victim of a serious assault in Cardiff's Bute Park - the same area where Dr Gary Jenkins was murdered in a homophobic attack - and had also been the victim of so-called cuckooing when a drugs-gang took over his Neath flat.

Judge Paul Thomas QC said he had no doubt Roberts' contact with the young children from care homes had been sexually-motivated grooming behaviour. He said it was clear the defendant posed a risk of serious harm to children but said it was not possible to pass an extended sentence for the offences currently before the court.

With a one-quarter discount for his guilty pleas Roberts was sentenced to three-and-a-half years for breaching the sexual harm prevention order, and the judge re-sentenced the defendant for the previous child abduction offence imposing a six month sentence for that to run consecutively, making an overall sentence of four years in prison. Roberts will serve up to half that period in custody before being released on licence to serve the remainder in the community.

Description

A man has been sentenced to six years in custody after being found guilty of committing six sexual offences against a 12-year-old girl.

Karl Richard Walsh, 41, denied all the charges but he was convicted following a trial at Swansea Crown Court earlier this week.

The officer in charge of the case, Detective Joanne Williams of South Wales Police, has praised the 12-year-old child for the way in which she has conducted herself throughout her horrific ordeal.

“I would like to commend the bravery of the girl in this case,” she said.  “Not only has she had the courage to report what had happened to her, but she has continued to support the investigation right to the end.  As a result of this child’s bravery, Walsh will now spend years in prison to reflect on his behaviour.”

Walsh, of Burnside, Neath, will remain on the sex offenders’ register for life.

Meanwhile the number of sex offences recorded by police in Wales has reached its highest level since 2002, according to latest crime figures. 

Statistical analysis shows that 3,973 crimes were recorded against children in Wales in the 12 months to June 2019.  This figure is up from 3,920 the previous year and the highest number since records began in 2002.  The findings confirm that the figure has more than doubled in the last five years alone.

The spike may be the result of an actual rise in the number of child abuse crimes, but it may also be linked to more victims feeling able to come forward to speak about their ordeals and also a better recording process by police.

Sexual crimes which are being committed against children include rape, sexual exploitation and the grooming of children under the age of 16.

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John Paul Bullingham was described by a court as a 'committed, if unsuccessful, paedophile'

A paedophile attempted to meet a fictitious young girl and made threats to someone he thought was an 11-year-old girl, a court has heard.

John Paul Bullingham was caught with indecent images of children by police and he was released pending further investigation.

But in the meantime Swansea Crown Court heard how Bullingham, of Bowen Street in Neath, sexually communicated online with people he thought were young girls. During the exchanges he encouraged lewd behaviour, attempted to arrange to meet another, and made threats to a third.

Judge Paul Thomas QC told the defendant: "Having heard the evidence in this case you are a committed, if unsuccessful, paedophile.

"You had an index of category A images of children and those images had children as young as five part of a collection accumulated over a year.

"Having been caught you were released under investigation by the police but that did not stop you.

"After being released under investigation you communicated sexually online with children online. One of those was who you thought was a 14-year-old girl which you encouraged to masturbate herself.

"You arranged to meet in Neath who you believed was a 13-year-old girl and if she had been real I have no doubt you would have committed sexual offences in relation to her.

"Possibly the most unsavoury and most dangerous aspect of what happened was concerning who you thought was an 11-year-old girl. You said to the fictitious girl that you would contact her friends and others online if she did not do what you wanted her to do. That is a particularly sinister aspect of this case."

Bullingham appeared for sentencing after being found guilty by a jury following a trial of five counts of possessing indecent photographs of a child, one count of possessing indecent images of a child, five counts of attempting to engage in sexual communication with a child, and a further count of attempting to cause or incite a child to engage in sexual activity.

Paul Hobson, mitigating, said: "At the age of 32 this is his first significant experience of custody. He has a relatively limited antecedent history. This is a defendant with a mild intellectual disability."

Sentencing Bullingham, Judge Thomas said: "I believe you pose a high risk of causing serious harm to others in future."

He handed Bullingham an eight-year sentenced comprising five and a half years in prison and the remainder on extended licence. He has also been given an indefinite sexual harm prevention order and an indefinite notification requirement.