Report III - Wirecard AG - Project VisMas Wirecard Employee & Terror Financing | Money Laundering | Organized Crime

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This phase of the investigation focused on Wirecard’s acquisition of GFG Group, and possible ties to terrorist financing.
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  REPORT III: WIRECARD AG. Nov 26, 2016. STRICTLY CONFIDENTIAL. PROFESSIONAL LEGAL PRIVILEGE Project VisMas REPORT III: WIRECARD AG November 26, 2016 STRICTLY CONFIDENTIAL PROFESSIONAL LEGAL PRIVILEGE  REPORT III: WIRECARD AG. Nov 26, 2016. STRICTLY CONFIDENTIAL. PROFESSIONAL LEGAL PRIVILEGE Tasking 1.   This company was tasked with carrying out investigative research on Wirecard AG in order to examine allegations of improper conduct and ties to illegal activity. 2.   This phase of the investigation focused on Wirecard’s acquisition of GFG Group, and possible ties to terrorist financing. Background 3.   Wirecard has been alleged to have conducted illegal activity and acquired fraudulent companies. Summary 4.   In December 2014, Wirecard acquired the entire share capital of GFG Group for €30 Million plus earn outs of up to €3.8 Million. 5.   Andreas Kazamias was the CEO of GFG Group at the time of acquisition. Kazamias is the former CEO to FBME, formerly known as Federal Bank of the Middle East. 6.   In July 2014, the United States Department of the Treasury (US DoT) found that: FBME Facilitates Money Laundering, Terrorist Financing, Transnational Organized Crime, Fraud Schemes, Sanctions Evasion, Weapons Proliferation, Corruption by Politically Exposed Persons, and Other Financial Crimes.   7.   FBME’s illegal activity was conducted when Kazamias acted a s CEO. 8.   When CEO of FBME, Kazamias oversaw that GFG became one of FBME’s “very select amount of partners.” 9.   According to the US DoT: Through relationships developed by FBME’s management since at least 2006, as well its large shell company customer base, FBME facilitates the activities of international terrorist financiers, organized crime figures, and money launderers.   10.   One of FBME’s associated companies, was Project -Pay (UK) Limited, a now insolvent mobile payment device provider. Prima facie, Project-Pay does not appear to have been used for illegal activity. However, evidence from FBME, GFG Group, and filings for Project-Pay, details that: a.   FBME was for some time effectively “ frozen out ”  from facilitating cross border payments through the Visa network. b.   FBME signed up GFG Group to assist in: Managing the complete merchant life cycle from account establishment through to settlement.    REPORT III: WIRECARD AG. Nov 26, 2016. STRICTLY CONFIDENTIAL. PROFESSIONAL LEGAL PRIVILEGE c.   This regarded what FBME deemed only: Existing specific high value clients of the bank.   d.   Further that: FBME likes to deal with only a very select amount of partners.   11.   The US DoT findings and sanctions against FBME, were released in July 2014. Prohibited from dealing with US financial institutions, FBME immediately closed down. Less than five months after this, Wirecard announced its acquisition of GFG Group Limited. 12.   FBME’s former CEO, Andreas Kazamias, remains in place as Managing Director and Executive Vice President, Card & Mobile Systems of the now renamed, Wirecard NZ Limited. Conclusions 13.   Prima facie, evidence sugg ests that when FBME was “frozen out” from facilitating cross border payments, that FBME enlisted GFG to facilitate this function. Therefore, GFG may have been party to facilitating the activities of international terrorist financiers, organized crime figures, and money launderers. Further Action/Recommendations 14.   Priority alert to the United States Department of Justice, Department of the Treasury (FinCEN), Department of Homeland Security. 15.   Recommend further in-depth investigation into the following: Andreas Kazamias, Stefan Klestil, Michael Brinkmann (HUMINT underway). Wirecard AG 16.   Wirecard  AG is a global financial services and technology company headquartered in Aschheim, Munich, Germany. Its internet payment service competes with PayPal and Western Union. Wirecard AG is listed on the Frankfurt Securities Exchange. 1   1  https://www.wirecard.com/company/our-story/   REPORT III: WIRECARD AG. Nov 26, 2016. STRICTLY CONFIDENTIAL. PROFESSIONAL LEGAL PRIVILEGE Acquisition of GFG Group 17.   Wirecard acquired the entire share capital of GFG Group Limited , a New Zealand based company on December 11, 2014. Wirecard paid €30 Million plus up to €3.8 Million in earn out components. GFG Group was renamed Wirecard NZ Limited. 2   GFG Group Limited    On 11 December 2014, the Wirecard Group acquired all the shares in GFG Group Limited, Auckland, New Zealand, as well as a subsidiary in Melbourne, Australia. The closing and first-time consolidation was also carried out on 11 December 2014.   The GFG Group, founded in 1990, is a leading provider of innovative electronic  payment solutions and services. Solutions offered by the GFG Group are currently deployed in more than 20 countries at over 100 corporate customers, particularly in the banking and telecommunications sectors, processing more than two million transactions daily from over 25 million card and account holders. The considerations in connection with this transaction, including the assumption of liabilities, amounted to around EUR 30.0 million, plus earnout components that, depending on the operational profit of the acquired group in the years 2015 and 2016, could amount to up to around EUR 3.8 million, of which EUR 3.3 million has been recorded as a liability. In the 2014 fiscal year, the company achieved consolidated sales revenue of kEUR 777 with a result after taxes of kEUR 124. For the full 2014 fiscal year, the company was able to achieve a result after taxes of kEUR 1,169 with sales revenues of EUR 11.7 million. 18.   Andreas   Kazamias  is currently the Managing Director of Wirecard Australia and New Zealand . Kazamias was appointed as CEO to GFG Group in March 2013. 3,4  19.   Kazamias was announced as CEO to GFG Group, in a February 20, 2013 press release. GFG stated: Originally from Australia, Andreas Kazamias is currently Chief Information Officer for online foreign exchange trading group Easy Forex   , based at the company’s headquarters in Cyprus. Easy Forex has clients in over 160 countries, with offices in the UK and Poland, and a separately licensed company in Australia. The CIO role is a global  position . Kazamias takes up the CEO role at GFG Group on 11 March 2013.  Andreas Kazamias has spent nearly thirty years in senior leadership roles in the  financial services industry at companies in Australia, across Europe and in the UK, including First Data, FBME   , ACI, Commonwealth Bank of Australia, Pulse International, St George Bank, National Bank of Greece, Hellenic Bank, JCC Payment Systems, and Cashcard. Kazamias has a long association with GFG Group, beginning when he selected GFG Group’s card system while CEO of FBME in Cyprus . “Andreas took over a basic card centre at FBME and established a successful new card and e-Commerce acquiring company – from concept, to project management of every dimension, through to full 2  https://www.business.govt.nz/companies/app/ui/pages/companies/518165  3  https://www.linkedin.com/in/andreaskazamias  4  http://web.archive.org/web/20130817113242/http:/www.gfg-group.com/news/2013/02/international-payments-expert-takes-up-ceo-role-at-gfg-group/ 
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