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Wirecard's_Underhand_Practices_How_It_Incriminated_Itself
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Disclaimer & License<br />
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By downloading this document, you explicitly agree to the terms of this disclaimer including<br />
the risk of financial losses, fraud and misrepresentation.<br />
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Furthermore, you agree to undertake and will, undertake your own <strong>research</strong> and due<br />
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Securities, which, are impacted by the contents of this report, you should consider the<br />
quality or otherwise of their <strong>research</strong> and due diligence.<br />
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Should you be motivated to undertake a transaction after reading this report you should<br />
seek the advice of appropriate qualified and experienced securities professionals.<br />
Any conclusions contained herein are the opinion of Zatarra and are based on<br />
interpretation.<br />
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Wirecard AG (WDI GR)<br />
Wirecard’s Underhand Practices & How It Incriminated Itself<br />
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Wirecard AG<br />
Ticker: WDI GR<br />
Exchange: Xetra<br />
Price Target: €0/share<br />
Share Price: €37.68<br />
Market Cap: €4.67B<br />
52-week high: €48.96<br />
52-week low: €31.88<br />
Shares count: 123.6M<br />
P/E: 30.5<br />
EV/EBITDA: 17.2<br />
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Summary of Findings<br />
Wirecard has avoided publicly responding to the issues we raised. Instead, Wirecard has<br />
disseminated false and misleading information to ‘Sell Side’ analysts and Investors.<br />
Wirecard has been caught in one of its lies. Having been confronted with evidence from<br />
UK Companies House, Wirecard now admits it did incorporate Wire Card UK Ltd.<br />
This is a significant and devastating admission that directly connects Wirecard to online<br />
gambling <strong>com</strong>panies and <strong>com</strong>panies laundering money into the United States.<br />
The United States Secret Service was unaware of Wirecard's incriminating connections<br />
to these <strong>com</strong>panies at the time of its investigation. The important <strong>com</strong>pany filings that<br />
show these connections were filed after the U.S. Secret Service’s initial investigation.<br />
This is significant and new evidence demonstrating Wirecard's central involvement in<br />
transmitting unlawful monies into the United States. Evidence that the United States<br />
Secret Service is now be<strong>com</strong>ing aware of.<br />
Zatarra will reveal new evidence demonstrating the fraudulent nature of Wirecard’s<br />
operations in due course.<br />
Questions to Wirecard<br />
1. Why does Wirecard refuse to make a public statement, specifically addressing the<br />
issues we have raised?<br />
2. Why did Wirecard deny any awareness of the existence of Wire Card UK Ltd, nor the<br />
involvement of its former or current officers with Wire Card UK Ltd?<br />
3. After denying association with Wire Card UK Ltd, what prompted Wirecard to admit a<br />
few days later that it did incorporate Wire Card UK Ltd?<br />
4. Why was Wire Card UK Ltd registered to a residential housing address in Consett,<br />
County Durham, United Kingdom?<br />
5. Why did Wire Card UK Ltd share the same shareholders, Fermoya Ltd and BMIE Ltd, as<br />
Bluetool Ltd? Bluetool was the <strong>com</strong>pany at the center of a United States Secret Services<br />
investigation into money laundering and the violation of the Wire Act.<br />
6. Why did Wire Card UK Ltd share the same shareholders, Fermoya Ltd and BMIE Ltd, as<br />
Bluemay Enterprises Ltd? Bluemay was a <strong>com</strong>pany found in 2014 to be a front for an<br />
online gambling site, 7red.<strong>com</strong>, with €36 Million in credits to a Wirecard Bank account.<br />
7. What is Wirecard’s relationship with Fermoya Ltd, BMIE Ltd, Bluetool Ltd, and Bluemay<br />
Enterprises Ltd?<br />
8. Who other than Zatarra’s Internet Service Provider, has Wirecard initiated legal action<br />
against? Zatarra has received no <strong>com</strong>plaint from Wirecard or its legal representatives<br />
despite our contact details being readily available.<br />
Bonus Questions:<br />
9. Did Wirecard process payments on behalf of Full Tilt Poker, into the United States at<br />
any time during the period 2006 to 2011?<br />
10. Has Wirecard processed payments on behalf of any online poker <strong>com</strong>panies, into the<br />
United States since 2011?<br />
We will demonstrate how Wirecard has made further false statements, and reveal<br />
further evidence of the fraudulent nature of Wirecard’s operations in due course.
Wirecard’s Underhand Practices and<br />
Defamation<br />
Wirecard has feebly attempted to distract by questioning Zatarra’s credibility. However,<br />
there can be no question as to the credibility of UK Companies House nor every other source<br />
of publicly available and the irrefutable evidence we provided.<br />
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Since the publication of Zatarra’s <strong>research</strong> note “Wide Scale Corruption and Corporate<br />
Fraud”, the Zatarra website has been under constant cyber-attack. These attacks largely<br />
stem from Germany.<br />
Wirecard’s management has avoided responding publicly to the issues we raised.<br />
Instead, Wirecard’s legal representative, Gowling WLG, has threatened our internet service<br />
provider (ISP). To provide a flavor of matters, Gowling WLG threaten everything without<br />
specifying precisely which illegal activities it claims Zatarra and its ISP are undertaking.<br />
Although Wirecard’s legal firm writes at length to our ISP about this and that, its main bone<br />
of contention is how our report impacted upon Wirecard’s market valuation.<br />
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We note that while Wirecard has indicated to parts of the media that it has taken legal<br />
action, none of this has been directed towards Zatarra itself. Zatarra’s website clearly states<br />
an easy mode of <strong>com</strong>munication through which we can be contacted. And yet we have not<br />
received one single email or letter from Wirecard’s legal representative.<br />
Wirecard has asserted that BaFIN is investigating Zatarra. This appears to be another<br />
example of Wirecard misleading the market. The reality is that Zatarra itself has contacted<br />
BaFIN with our evidence and contact details to liaise with the German regulator.<br />
When a <strong>com</strong>pany’s management pursues underhand practices, <strong>com</strong>plimented by<br />
defamation, it is an absolute certainty that the management has something to hide.<br />
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Wirecard Changes its Story<br />
Zatarra has been made aware 1 that Wirecard has changed its statement with regards to the<br />
incorporation of Wire Card UK Ltd (UK Companies House).<br />
Initially, Wirecard denied any awareness of the existence of Wire Card UK Ltd and any links<br />
to Wire Card UK Ltd by any former or current employees. Morgan Stanley went as far to<br />
reveal this statement in its note, "Addressing Concerns", published on March 1, 2016.<br />
Now Wirecard states that it did incorporate Wire Card UK Ltd.<br />
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<br />
This demonstrates that Wirecard has again misled investors, analysts and the media.<br />
Wirecard now continues to mislead investors, analysts. and the media.<br />
Wirecard's management have moved from denying any involvement or even awareness of<br />
Wire Card UK Ltd to now confirming that it did incorporate Wire Card UK Ltd.<br />
Wirecard changed its version of events AFTER we presented the incontrovertible evidence<br />
easily obtained from UK Companies House.<br />
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We reproduce the email that Wirecard’s VP Corporate Communications and Investor Relations, Iris Stöckl<br />
sent to ‘sell-side’ analysts at the end of this note.
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Figure 1 Morgan Stanley <strong>research</strong> note from March 1, 2016 - highlighting Wirecard management stating no<br />
such awareness of Wire Card UK Ltd<br />
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Now Wirecard States it Incorporated Wire Card UK Ltd<br />
In section 5 of Wirecard’s email to ‘sell side’ analysts, Wirecard now states that it did<br />
incorporate Wire Card UK Ltd.<br />
“5. Wire Card UK Limited (<strong>com</strong>pany number 05888415) was incorporated on 27<br />
July 2006. This was for the purpose of establishing a subsidiary for Wirecard in the<br />
UK.”<br />
Aside from misleading investors and analysts and the media, in its updated statement,<br />
Wirecard has now confirmed its direct association with Wire Card UK Ltd.<br />
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Wirecard Incriminates Itself with its Association with Wire<br />
Card UK Ltd<br />
We urge Regulators, MasterCard and Visa to investigate the ownership of Wire Card UK Ltd<br />
and Bluetool Ltd (UK Companies House).<br />
Bluetool Ltd is the <strong>com</strong>pany that was at the center of a United States Secret Service<br />
investigation into Money Laundering - Court Document Michael Schuett.<br />
Bluetool Ltd was the <strong>com</strong>pany transmitting unlawful monies into the United States from its<br />
Wirecard Bank account.<br />
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Figure 2 Ownership of Wire Card UK Ltd and Bluetool Ltd<br />
The filings for Wire Card UK Ltd and Bluetool Ltd show that each <strong>com</strong>pany was owned by<br />
Fermoya Ltd and BMIE Ltd. Wirecard now states that it incorporated Wire Card UK Ltd and<br />
this <strong>com</strong>pany had the same owners as Bluetool Ltd.<br />
Wire Card UK Incorporation Documents for Wire Card UK (Page 17)<br />
Bluetool Ltd Incorporation Documents (Page 18)<br />
We believe that the United States Secret Service will investigate Wirecard's connection to<br />
Wire Card UK Ltd and Bluetool Ltd and we have updated on these developments.<br />
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Further Incriminating Evidence<br />
Fermoya Ltd and BMIE Ltd were also reported as the owners of Bluemay Enterprises Ltd. As<br />
we have shown on page 40 of our <strong>research</strong> note, "Wide Scale Corruption and Corporate<br />
Fraud", Bluemay Enterprises was a front for 7red.<strong>com</strong>, an online poker gambling site.<br />
Bluemay Enterprises was struck off the UK Companies House register at the request of the<br />
UK Secretary of State in 2014. Bluemay Enterprises was found to have €36 Million in credits<br />
to a Wirecard Bank account. See: The UK Insolvency Service - Bluemay Enterprises Limited.<br />
Wirecard incorporated a <strong>com</strong>pany, Wire Card UK Ltd, that had the same owners as Bluetool<br />
Ltd, a <strong>com</strong>pany violating the Wire Act, and Bluemay Enterprises, a front for an online poker<br />
<strong>com</strong>pany, with significant monies credited to a Wirecard Bank account.<br />
Figure 3 United States of America v. Michael Olaf Schuett<br />
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Why this is NEW and Devastating Evidence<br />
The United States Secret Service was unaware of Wirecard's incriminating connections to<br />
these <strong>com</strong>panies at the time of its investigation. The important <strong>com</strong>pany filings that show<br />
these connections were filed after its investigation.<br />
This is significant and new evidence demonstrating Wirecard's central involvement in<br />
transmitting unlawful monies into the United States. Evidence that the United States Secret<br />
Service is now be<strong>com</strong>ing aware of.<br />
Figure 4 Bluemay Enterprises struck off in 2014 at the request of the UK Secretary of State<br />
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Why Did Wirecard Register Wire Card UK Ltd at a Residential<br />
Address?<br />
Wire Card UK Ltd was registered to a residential address in Gateshead, United Kingdom. This<br />
is clearly not a location from which Wirecard conducted any business. It is a violation of UK<br />
Companies House rules to register a business to an address that has no relation to the<br />
registered <strong>com</strong>pany’s activities.<br />
We believe that Wirecard registered Wire Card UK Ltd to this residential address to make it<br />
harder to track Wirecard and its officers’ involvement in money laundering and transmitting<br />
illegal monies into the United States.<br />
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Figure 5 Wire Card UK Ltd registered to someone's house in Gateshead, United Kingdom<br />
We will respond with additional evidence to show the further false statements Wirecard<br />
has made in due course.<br />
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The Email Sent From Wirecard to Sell Side Analysts<br />
Dear all<br />
below you find a statement to a number of the points raised by Zatarra report.<br />
Best regards,<br />
Iris<br />
Wirecard statement: Zatarra report<br />
Despite Zatarra’s distinct lack of credibility, Wirecard has spent significant time and<br />
effort reviewing the Report and the allegations it makes and determined that the<br />
report is totally false. Below you will find answers in detail to a number of the points<br />
raised.<br />
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Wirecard has always supported strengthened regulation of the internet payment industry,<br />
with strict <strong>com</strong>pliance to protect consumers, merchants and the industry from any form of<br />
misconduct. It was the first Payment Service Provider (PSP) to hold a full banking licence,<br />
as early as 2006. Being a regulated entity involves extensive regulatory oversight and<br />
enforces the application of strict <strong>com</strong>pliance procedures to the <strong>com</strong>pany’s operations. Since<br />
Wirecard acquired its full banking licence, the European Union has introduced a regulatory<br />
framework that has required Wirecard’s <strong>com</strong>petitors to apply for licences and to be<strong>com</strong>e<br />
subject to regulatory oversight. Wirecard’s German banking licence and the regulatory<br />
regime which that entails shows that Wirecard operates under one of the most extensive<br />
and strictest regulatory environments in Europe.<br />
1. As one of the world’s leading online payment <strong>com</strong>panies, Wirecard has<br />
excellent relations with all credit card organisations. It is an active licensee/member<br />
of such organisations through its regulated entities in the UK and Germany, and<br />
has been for more than a decade. Further to its role as an acquirer and issuer for<br />
various credit card organisations, Wirecard holds strategic partnerships with these<br />
card organisations and has acquired assets and subsidiaries from them.<br />
2. Wirecard continuously discloses the nature of the transaction volumes<br />
processed by the <strong>com</strong>pany and the revenues related to each client industry<br />
segment in its audited annual reports. Online gambling transactions solely originate<br />
from regulated online gambling operators and volumes constitute about 7% of<br />
Wirecard’s total transaction volumes. They are aggregated under the ‘digital goods’<br />
segment of Wirecard’s public reporting. Any claim that Wirecard obfuscates<br />
payment jurisdiction and associated merchant risk, to circumvent high risk<br />
categorization and authentication requirements within the credit card organisation<br />
networks, is wrong. Wirecard’s <strong>com</strong>pliance and merchant account setup<br />
procedures are repeatedly audited by regulatory bodies as well as the credit card<br />
organisations themselves. The allocation of country and merchant category codes<br />
to individual merchant accounts is conducted fully in accordance with all regulatory,<br />
tax and credit card organisation rules.<br />
3. Wirecard has never acquired Krores from Mr Knöchelmann, Mr Trautmann or<br />
any other party. Wirecard also does not have any business relationship with Krores.<br />
4. Since the departure of Dietmar Knöchelmann and Rüdiger Trautmann,<br />
Wirecard has no direct or indirect business dealings or relationship with either<br />
individual.<br />
Wirecard has no direct or indirect business dealings with Inatec GmbH.<br />
Mr Knöchelmann is not involved in any legal cases involving Wirecard or any of its<br />
subsidiaries.<br />
5. Wire Card UK Limited (<strong>com</strong>pany number 05888415) was incorporated on 27<br />
July 2006. This was for the purpose of establishing a subsidiary for Wirecard in the<br />
UK but in the end other decisions were made. In its whole lifetime it was a dormant<br />
<strong>com</strong>pany which was never operational. It was dissolved on 17 August 2010.<br />
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6. With recards to the Schütt case, in 2010 the online portal Goldman,<br />
Morgenstern & Partners (“Gomopa”) published a report falsely claiming that Mr<br />
Michael Schütt, in his testimony to US authorities, named Wirecard as an ally in his<br />
money laundering scheme for gambling <strong>com</strong>panies. Several investigations by<br />
journalists have entirely cleared both Wirecard and Mr Trautmann in relation to<br />
Gomopa’s false claims. Gomopa’s claims were entirely fraudulent and made solely<br />
to manipulatively drive down Wirecard’s stock price. For an example of this, please<br />
see the Handelsblatt article available via the link:<br />
http://<strong>www</strong>.handelsblatt.<strong>com</strong>/finanzen/maerkte/boerseinside/marktgeruechtefinanzaufsichtuntersucht-kursachterbahn-beiwirecard/3406252.html<br />
(an English translation can be<br />
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made available upon request) Gomopa’s reputation for questionable business<br />
practices is well known.<br />
7. Mr Usman Fayaz was neither directly nor indirectly a shareholder of any of the<br />
<strong>com</strong>panies at the time of the purchase of the payment business of GI Retail Group.<br />
Neither GI Technologies nor Hermes have ever been involved in any form of lottery<br />
or gaming business. GI Technologies is India’s leading domestic money remittance<br />
operator and regulated by the Reserve Bank of India (RBI). It is regularly audited by<br />
the regulator and applies rigorous KYC and <strong>com</strong>pliance procedures to its<br />
remittance operations. The corporate fraud which is referred to is in respect of the<br />
<strong>com</strong>pany Popular Agro Farms Pvt Ltd, which has nothing at all to do with Wirecard<br />
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or GI Retail.<br />
8. Wirecard has never acquired Asia Pacific E-Serv Corporation (aspaconline).<br />
Wirecard Asia Pacific, Philippines was a newly established <strong>com</strong>pany in 2007 and<br />
was dissolved in 2012.<br />
Mr Magleo's incorrect CV was updated on the website of Paynamics, Philippines.<br />
Mrs Magleo headed the finance department of Wirecard Asia Pacific, Inc. during its<br />
time of operation. She was not involved in any legal cases involving Wirecard or her<br />
past activities as an officer of a subsidiary of Wirecard.<br />
9. Wirecard has never hosted any content websites or any other merchant<br />
business model.<br />
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Iris Stöckl<br />
VP Corporate Communications & Investor Relations<br />
Wirecard AG<br />
Einsteinring 35<br />
D-85609 Aschheim<br />
Ph.: +49 (0) 89 4424-1424<br />
Fax: +49 (0) 89 4424-2424<br />
290 iris.stoeckl@wirecard.<strong>com</strong> <br />
Mobile: +49 (160) 445 11 58<br />
http://<strong>www</strong>.wirecard.de http://<strong>www</strong>.wirecardbank.<strong>com</strong> http://mywirecard.<strong>com</strong><br />
FSE/ TecDAX/Prime ISIN DE0007472060 Ticker symbol WDI<br />
Amtsgericht München HRB<br />
169227<br />
Vorstand: Dr. Markus Braun, Burkhard Ley, Jan<br />
Marsalek<br />
Aufsichtsratsvorsitzender: Wulf Matthias<br />
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