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Disclaimer & License<br />

10<br />

20<br />

30<br />

By downloading this document, you explicitly agree to the terms of this disclaimer including<br />

the risk of financial losses, fraud and misrepresentation.<br />

In no event or form is Zatarra, its officers, members, representatives, authors, investigators,<br />

backers, supporters, advisors, clients, suppliers or financial entities associated with them<br />

(henceforth collectively known as ‘Zatarra’) responsible for any direct or indirect trading or<br />

investing losses caused by any information contained within this document.<br />

Furthermore, you agree to undertake and will, undertake your own <strong>research</strong> and due<br />

diligence before making any investment or trading decision with respect to the securities<br />

mentioned herein. If you suffer consequential losses because your advisors have selected<br />

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 />

You should assume irrespective of position, that as of the date of this note Zatarra has<br />

positions (whether they be in stock, contracts for differences, total return swaps, options,<br />

futures or other synthetic instruments or otherwise) that will benefit from a move in the<br />

price of the stock(s) covered or mentioned within this report. We DO NOT undertake nor<br />

accept any responsibility, obligation, or duty to inform, notify, publicly state or otherwise<br />

highlight such changes to any positions Zatarra may hold.<br />

None of the materials in this document should be considered an offer to sell or a solicitation<br />

of an offer to buy any security nor do we intend to make any such an offer.<br />

Zatarra has used sources herein, which, it considers reliable and accurate and from public<br />

sources that are accessible to the wider markets. Where possible we state the source of<br />

each item of information. However, we make no representation either expressed or implied<br />

as to the accuracy, reliability, timeliness or <strong>com</strong>pleteness of the aforementioned sources<br />

nor of our interpretation, analysis, explanation or conclusions of the information. We may<br />

elect to update, respond or reply to any such <strong>com</strong>ments but give no undertaking whether<br />

implied or otherwise to provide additional information.<br />

You should also be aware that we have NOT necessarily included all the information we have<br />

found on the <strong>com</strong>pany or <strong>com</strong>panies covered by this report.<br />

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 />

40


Wirecard AG (WDI GR)<br />

Wirecard’s Underhand Practices & How It Incriminated Itself<br />

50


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 />

60<br />

70<br />

80<br />

90<br />

1<br />

of 12 -<br />

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 />

100<br />

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 />

110<br />

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 />

120<br />

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 />

<br />

<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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of 12 -<br />

1<br />

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.


130<br />

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 />

140<br />

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 />

150<br />

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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of 12 -


160<br />

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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5 of 12 -


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 />

180<br />

6 of 12 -


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 />

190<br />

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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of 12 -


200<br />

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 />

210<br />

220<br />

230<br />

240<br />

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 />

8<br />

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250<br />

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 />

260<br />

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 />

270<br />

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 />

280<br />

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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