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{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"sources","id":"src-068","record":{"id":"src-068","title":"FCA: Wirecard can resume regulated activity","url":"https://www.fca.org.uk/news/news-stories/requirements-imposed-wirecard-authorisation","publisher":"Financial Conduct Authority","date":"2020-06-26","locator":"News story (updated 29 June 2020)","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-21","source_type":"regulatory_record","publisher_type":"regulator"},"reading":"FCA: Wirecard can resume regulated activity, Financial Conduct Authority"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"sources","id":"src-069","record":{"id":"src-069","title":"Federal Ministry of Finance: status report on Wirecard (timeline)","url":"https://www.bundesfinanzministerium.de/Content/DE/Standardartikel/Themen/Internationales_Finanzmarkt/Finanzmarktpolitik/2020-07-17-Sachstandsbericht-Wirecard.pdf?__blob=publicationFile&v=3","publisher":"Federal Ministry of Finance","date":"2020-07-17","locator":"Status report and chronology","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-21","source_type":"regulatory_record","publisher_type":"government"},"reading":"Federal Ministry of Finance: status report on Wirecard (timeline), Federal Ministry of Finance"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"sources","id":"src-070","record":{"id":"src-070","title":"IAASA agrees settlements with Tony Kelly and Alison Gray","url":"https://iaasa.ie/publications/iaasa-agrees-settlements-with-tony-kelly-and-alison-gray/","publisher":"Irish Auditing and Accounting Supervisory Authority","date":"2026-09-22","locator":"Announcement","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-21","source_type":"regulatory_record","publisher_type":"regulator"},"reading":"IAASA agrees settlements with Tony Kelly and Alison Gray, Irish Auditing and Accounting Supervisory Authority"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"sources","id":"src-071","record":{"id":"src-071","title":"Singapore High Court judgment [2026] SGHC 102 (oCap Management Pte Ltd)","url":"https://www.elitigation.sg/gd/s/2026_SGHC_102","publisher":"Supreme Court of Singapore","date":"2026-05-13","locator":"Judgment","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-21","source_type":"court_record","publisher_type":"government"},"reading":"Singapore High Court judgment [2026] SGHC 102 (oCap Management Pte Ltd), Supreme Court of Singapore"}
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{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"sources","id":"src-073","record":{"id":"src-073","title":"Federal Government answer to a parliamentary question on Wirecard Bank loans (printed paper 19/25977)","url":"https://dserver.bundestag.de/btd/19/259/1925977.pdf","publisher":"German Bundestag","date":"2021-01-18","locator":"Answers to questions","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-21","source_type":"regulatory_record","publisher_type":"government"},"reading":"Federal Government answer to a parliamentary question on Wirecard Bank loans (printed paper 19/25977), German Bundestag"}
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{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"sources","id":"src-077","record":{"id":"src-077","title":"MAS: entities that are no longer exempt under the Payment Services Act exemption for a specified period","url":"https://www.mas.gov.sg/regulation/payments/entities-that-are-no-longer-exempt-pursuant-to-the-ps-esp-r","publisher":"Monetary Authority of Singapore","date":"","locator":"List of entities","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-21","source_type":"regulatory_record","publisher_type":"regulator"},"reading":"MAS: entities that are no longer exempt under the Payment Services Act exemption for a specified period, Monetary Authority of Singapore"}
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{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"sources","id":"src-079","record":{"id":"src-079","title":"Bundestag text archive: third committee of inquiry hears Markus Braun and other witnesses","url":"https://www.bundestag.de/webarchiv/textarchiv/2020/kw47-pa-3ua-806332","publisher":"German Bundestag","date":"2020-11-19","locator":"Session report of 19 November 2020","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-21","source_type":"other","publisher_type":"government"},"reading":"Bundestag text archive: third committee of inquiry hears Markus Braun and other witnesses, German Bundestag"}
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{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"sources","id":"src-083","record":{"id":"src-083","title":"Media source · src-083","url":"","publisher":"","date":"","locator":"","basis":"Source classification retained; identifying metadata omitted.","accessed":"","source_type":"media","publisher_type":"media"},"reading":"Media source · src-083"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"sources","id":"src-084","record":{"id":"src-084","title":"Singapore Police Force: four more individuals charged in connection with Wirecard investigation","url":"https://www.police.gov.sg/media-hub/news/2022/20220817_four_more_individuals_charged_in_connection_to_wirecard_investigation","publisher":"Singapore Police Force","date":"2022-08-17","locator":"News release","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-21","source_type":"regulatory_record","publisher_type":"government"},"reading":"Singapore Police Force: four more individuals charged in connection with Wirecard investigation, Singapore Police Force"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"sources","id":"src-085","record":{"id":"src-085","title":"Singapore Police Force: former Wirecard employee extradited to Germany","url":"https://www.police.gov.sg/Media-Hub/News/2026/03/20260331_former_wirecard_employee_extradited_to_germany","publisher":"Singapore Police Force","date":"2026-03-31","locator":"News release","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-21","source_type":"regulatory_record","publisher_type":"government"},"reading":"Singapore Police Force: former Wirecard employee extradited to Germany, Singapore Police Force"}
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{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"sources","id":"src-087","record":{"id":"src-087","title":"ESMA fast-track peer review on the application of the guidelines on the enforcement of financial information by BaFin and FREP in the context of Wirecard","url":"https://www.esma.europa.eu/sites/default/files/library/esma42-111-5349_fast_track_peer_review_report_-_wirecard.pdf","publisher":"European Securities and Markets Authority (ESMA)","date":"2020-11-03","locator":"Report sections and annex chronology","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-21","source_type":"regulatory_record","publisher_type":"intergovernmental"},"reading":"ESMA fast-track peer review on the application of the guidelines on the enforcement of financial information by BaFin and FREP in the context of Wirecard, European Securities and Markets Authority (ESMA)"}
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{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"sources","id":"src-090","record":{"id":"src-090","title":"Bavarian Supreme Regional Court: press release 5/2024 on decisions in the Wirecard model proceeding","url":"https://www.justiz.bayern.de/gerichte-und-behoerden/bayerisches-oberstes-landesgericht/presse/2024/5.php","publisher":"Bavarian Supreme Regional Court (Bavarian State Ministry of Justice portal)","date":"2024-05-15","locator":"Press release 5/2024","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-21","source_type":"court_record","publisher_type":"government"},"reading":"Bavarian Supreme Regional Court: press release 5/2024 on decisions in the Wirecard model proceeding, Bavarian Supreme Regional Court (Bavarian State Ministry of Justice portal)"}
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{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"sources","id":"src-092","record":{"id":"src-092","title":"Companies House: officers of Wirecard Card Solutions Limited (07875693)","url":"https://find-and-update.company-information.service.gov.uk/company/07875693/officers","publisher":"Companies House","date":"","locator":"Officers list","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-21","source_type":"corporate_registry","publisher_type":"registry_operator"},"reading":"Companies House: officers of Wirecard Card Solutions Limited (07875693), Companies House"}
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{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"sources","id":"src-100","record":{"id":"src-100","title":"Companies House: appointments of Thomas Michael Richard Jennings","url":"https://find-and-update.company-information.service.gov.uk/officers/kNfzn30EPej-iH3-InUAGQY95Is/appointments","publisher":"Companies House","date":"","locator":"Appointments list","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-21","source_type":"corporate_registry","publisher_type":"registry_operator"},"reading":"Companies House: appointments of Thomas Michael Richard Jennings, Companies House"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"sources","id":"src-101","record":{"id":"src-101","title":"Companies House: appointments of Andrea Farace","url":"https://find-and-update.company-information.service.gov.uk/officers/htK4fRWYjA_nyCJXJv0Ryrr4mAM/appointments","publisher":"Companies House","date":"","locator":"Appointments list","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-21","source_type":"corporate_registry","publisher_type":"registry_operator"},"reading":"Companies House: appointments of Andrea Farace, Companies House"}
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{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"sources","id":"src-105","record":{"id":"src-105","title":"Corporate registry source · src-105","url":"","publisher":"","date":"","locator":"","basis":"Source classification retained; identifying metadata omitted.","accessed":"","source_type":"corporate_registry","publisher_type":"corporate"},"reading":"Corporate registry source · src-105"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-id-registration","record":{"id":"c-id-registration","kind":"fact","text":"Wirecard AG is a German stock corporation (Aktiengesellschaft) registered with the Munich local court (Amtsgericht München) under HRB 169227 since 6 August 2007. According to its 2019 bond prospectus it was incorporated on 6 May 1999 in Berlin, registered at the Charlottenburg local court under HRB 88060 B, and moved its registered seat after a shareholders' resolution of 14 June 2007.","source_ids":["src-002","src-012","src-006"],"entity_ids":["wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard AG is a German stock corporation (Aktiengesellschaft) registered with the Munich local court (Amtsgericht München) under HRB 169227 since 6 August 2007. According to its 2019 bond prospectus it was incorporated on 6 May 1999 in Berlin, registered at the Charlottenburg local court under HRB 88060 B, and moved its registered seat after a shareholders' resolution of 14 June 2007."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-id-guarantor-leis","record":{"id":"c-id-guarantor-leis","kind":"fact","text":"Wirecard AG's September 2019 bond prospectus gives the Legal Entity Identifiers of the five subsidiary guarantors: Wirecard Technologies GmbH 529900Z54V2EA48D2Y27, Wirecard Sales International Holding GmbH 529900VH0MQZASU8AR79, Wirecard Payment Solutions Holdings Limited (Dublin) 529900BWETZJRMZMRV03, CardSystems Middle East FZ-LLC 529900QITH4S89RB2V17 and Wirecard Processing FZ-LLC 529900NB6TN7EHS4MA55.","source_ids":["src-012"],"entity_ids":["wirecard","wd-tech","wd-sih","wd-psh","cardsystems-me","wd-processing"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard AG's September 2019 bond prospectus gives the Legal Entity Identifiers of the five subsidiary guarantors: Wirecard Technologies GmbH 529900Z54V2EA48D2Y27, Wirecard Sales International Holding GmbH 529900VH0MQZASU8AR79, Wirecard Payment Solutions Holdings Limited (Dublin) 529900BWETZJRMZMRV03, CardSystems Middle East FZ-LLC 529900QITH4S89RB2V17 and Wirecard Processing FZ-LLC 529900NB6TN7EHS4MA55."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-id-identifiers","record":{"id":"c-id-identifiers","kind":"fact","text":"Wirecard AG's Legal Entity Identifier is 529900A8LX4KL0YUTH71, as stated in its September 2019 bond prospectus. A commercial registry aggregator lists the same identifier, the European unique identifier DED2601V.HRB169227 and the earlier register numbers HRB 88060 B (Charlottenburg, Berlin) and HRB 131672 (Munich).","source_ids":["src-012","src-001"],"entity_ids":["wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard AG's Legal Entity Identifier is 529900A8LX4KL0YUTH71, as stated in its September 2019 bond prospectus. A commercial registry aggregator lists the same identifier, the European unique identifier DED2601V.HRB169227 and the earlier register numbers HRB 88060 B (Charlottenburg, Berlin) and HRB 131672 (Munich)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-id-names","record":{"id":"c-id-names","kind":"fact","text":"Wirecard AG's earlier names were InfoGenie Europe AG and Wire Card AG, and its earlier seats were Berlin and Grasbrunn; a subsidiary's register entry confirms that InfoGenie Europe AG (Charlottenburg HRB 88060 B) was renamed Wirecard AG.","source_ids":["src-016","src-001"],"entity_ids":["wirecard","click2pay"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard AG's earlier names were InfoGenie Europe AG and Wire Card AG, and its earlier seats were Berlin and Grasbrunn; a subsidiary's register entry confirms that InfoGenie Europe AG (Charlottenburg HRB 88060 B) was renamed Wirecard AG."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-id-purpose","record":{"id":"c-id-purpose","kind":"fact","text":"Wirecard AG's registered business purpose is the development, operation and marketing of information services, especially through electronic media, and the development and implementation of technical applications, services and projects in payment systems, including the acquisition and granting of licences in the financial services sector.","source_ids":["src-001"],"entity_ids":["wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard AG's registered business purpose is the development, operation and marketing of information services, especially through electronic media, and the development and implementation of technical applications, services and projects in payment systems, including the acquisition and granting of licences in the financial services sector."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-id-addresses-capital","record":{"id":"c-id-addresses-capital","kind":"fact","text":"Register entries show Wirecard AG's address at Bretonischer Ring 4, Grasbrunn from 3 March 2009, at Einsteinring 35, Aschheim from 22 July 2011 and at Humboldtstraße 8, Aschheim from 27 June 2022. The registered share capital rose in steps from EUR 111,983,452 (9 March 2012) to EUR 123,565,586 (26 January 2016).","source_ids":["src-002"],"entity_ids":["wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Register entries show Wirecard AG's address at Bretonischer Ring 4, Grasbrunn from 3 March 2009, at Einsteinring 35, Aschheim from 22 July 2011 and at Humboldtstraße 8, Aschheim from 27 June 2022. The registered share capital rose in steps from EUR 111,983,452 (9 March 2012) to EUR 123,565,586 (26 January 2016)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-id-capital-2011","record":{"id":"c-id-capital-2011","kind":"fact","text":"Wirecard AG's subscribed capital at 31 December 2011 was EUR 101,803,139, divided into the same number of no-par bearer shares; after a capital increase registered on 9 March 2012 it was EUR 111,983,452.","source_ids":["src-010"],"entity_ids":["wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard AG's subscribed capital at 31 December 2011 was EUR 101,803,139, divided into the same number of no-par bearer shares; after a capital increase registered on 9 March 2012 it was EUR 111,983,452."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-id-mergers","record":{"id":"c-id-mergers","kind":"fact","text":"Wirecard AG's register records that InfoGenie Deutschland GmbH and InfoGenie ComService GmbH (both Berlin) were merged into the company, and that under merger agreements of 29 June 2005 net sales GmbH and InfoGenie Global GmbH (both Grasbrunn) were merged into it as well.","source_ids":["src-006"],"entity_ids":["wirecard","infogenie-de","infogenie-comservice","net-sales","infogenie-global"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard AG's register records that InfoGenie Deutschland GmbH and InfoGenie ComService GmbH (both Berlin) were merged into the company, and that under merger agreements of 29 June 2005 net sales GmbH and InfoGenie Global GmbH (both Grasbrunn) were merged into it as well."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-id-dax","record":{"id":"c-id-dax","kind":"fact","text":"The European Securities and Markets Authority (ESMA) describes Wirecard AG as a fintech company included in the DAX 30 index from September 2018 and notes that allegations of accounting inconsistencies and other irregularities were raised several times during its rapid growth and were systematically rejected by the company.","source_ids":["src-087"],"entity_ids":["wirecard","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: The European Securities and Markets Authority (ESMA) describes Wirecard AG as a fintech company included in the DAX 30 index from September 2018 and notes that allegations of accounting inconsistencies and other irregularities were raised several times during its rapid growth and were systematically rejected by the company."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-id-same-address","record":{"id":"c-id-same-address","kind":"fact","text":"A registry aggregator lists six group companies at Wirecard AG's later address, Humboldtstraße 8 in Aschheim: WDB Abwicklungs AG (formerly Wirecard Bank AG, HRB 161178), Wirecard Acquiring & Issuing GmbH, Wirecard Global Sales GmbH, Wirecard Sales International Holding GmbH, Wirecard Service Technologies GmbH and Wirecard Technologies GmbH.","source_ids":["src-002"],"entity_ids":["wirecard","wd-bank","wd-acq-iss","wd-global-sales","wd-sih","wd-service-tech","wd-tech"],"qualification":"","response":"","outcome":""},"reading":"Fact: A registry aggregator lists six group companies at Wirecard AG's later address, Humboldtstraße 8 in Aschheim: WDB Abwicklungs AG (formerly Wirecard Bank AG, HRB 161178), Wirecard Acquiring & Issuing GmbH, Wirecard Global Sales GmbH, Wirecard Sales International Holding GmbH, Wirecard Service Technologies GmbH and Wirecard Technologies GmbH."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-2010-list","record":{"id":"c-str-2010-list","kind":"fact","text":"Wirecard AG's 2010 annual report lists its subsidiaries, each held at 100%: Click2Pay GmbH, InfoGenie Ltd. (Windsor, United Kingdom), Wirecard (Gibraltar) Ltd., Trustpay International GmbH (formerly Trustpay International AG), Wirecard Payment Solutions Holdings Ltd., Wirecard UK and Ireland Ltd. (formerly Wirecard Payment Solutions Ltd.) and Herview Ltd. (Dublin), Wirecard Central Eastern Europe GmbH (formerly Qenta paymentsolutions Beratungs und Informations GmbH, Klagenfurt), Wirecard Technologies AG, Wirecard Communication Services GmbH (Leipzig), Wirecard Retail Services GmbH, cardSystems FZ-LLC (Dubai), Wire Card Beteiligungs GmbH, Wirecard Bank AG, E-Credit Plus Pte. Ltd. (later Wirecard Asia Pte. Ltd., Singapore), E-Credit Plus Corp. (Philippines), Credence Collection SDN BHD (Malaysia) and E-Payments Singapore Pte. Ltd.","source_ids":["src-023"],"entity_ids":["wirecard","click2pay","infogenie-ltd","wd-gibraltar","wd-sih","wd-psh","wd-uki","herview","wd-cee","wd-tech","wd-comm-services","wd-retail-services","cardsystems-fz","wd-acq-iss","wd-bank","wd-asia-pte","ecredit-corp","wd-malaysia","epayments-sg"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard AG's 2010 annual report lists its subsidiaries, each held at 100%: Click2Pay GmbH, InfoGenie Ltd. (Windsor, United Kingdom), Wirecard (Gibraltar) Ltd., Trustpay International GmbH (formerly Trustpay International AG), Wirecard Payment Solutions Holdings Ltd., Wirecard UK and Ireland Ltd. (formerly Wirecard Payment Solutions Ltd.) and Herview Ltd. (Dublin), Wirecard Central Eastern Europe GmbH (formerly Qenta paymentsolutions Beratungs und Informations GmbH, Klagenfurt), Wirecard Technologies AG, Wirecard Communication Services GmbH (Leipzig), Wirecard Retail Services GmbH, cardSystems FZ-LLC (Dubai), Wire Card Beteiligungs GmbH, Wirecard Bank AG, E-Credit Plus Pte. Ltd. (later Wirecard Asia Pte. Ltd., Singapore), E-Credit Plus Corp. (Philippines), Credence Collection SDN BHD (Malaysia) and E-Payments Singapore Pte. Ltd."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-2010-mergers","record":{"id":"c-str-2010-mergers","kind":"fact","text":"To simplify the group, Pro Card Kartensysteme GmbH (Grasbrunn) was merged into Wirecard Retail Services GmbH in 2010, and webcommunication EDV Dienstleistungs und Entwicklungs GmbH (Graz) into Wirecard Central Eastern Europe GmbH; 18 subsidiaries were fully consolidated at 31 December 2010, against 16 a year earlier.","source_ids":["src-023"],"entity_ids":["wirecard","wd-retail-services","procard-kartensysteme","wd-cee"],"qualification":"","response":"","outcome":""},"reading":"Fact: To simplify the group, Pro Card Kartensysteme GmbH (Grasbrunn) was merged into Wirecard Retail Services GmbH in 2010, and webcommunication EDV Dienstleistungs und Entwicklungs GmbH (Graz) into Wirecard Central Eastern Europe GmbH; 18 subsidiaries were fully consolidated at 31 December 2010, against 16 a year earlier."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-2011-list","record":{"id":"c-str-2011-list","kind":"fact","text":"Wirecard AG's 2011 annual report again lists subsidiaries held at 100%, now including Procard Services FZ LLC (Dubai), Systems@Work Pte. Ltd. (Singapore), Systems@Work (M) SDN BHD (Kuala Lumpur) and Safe2Pay Pte. Ltd. (Singapore), alongside Trustpay International GmbH, Wire Card Beteiligungs GmbH, Wirecard Technologies AG, cardSystems FZ-LLC, Wirecard Asia Pte. Ltd., E-Credit Plus Corp., Wirecard Malaysia SDN BHD (formerly Credence Collection SDN BHD) and E-Payments Singapore Pte. Ltd.; 22 subsidiaries were fully consolidated at 31 December 2011, against 18 a year earlier.","source_ids":["src-010"],"entity_ids":["wirecard","procard","wd-singapore","systemsatwork-my","safe2pay","wd-sih","wd-acq-iss","wd-tech","cardsystems-fz","wd-asia-pte","ecredit-corp","wd-malaysia","epayments-sg"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard AG's 2011 annual report again lists subsidiaries held at 100%, now including Procard Services FZ LLC (Dubai), Systems@Work Pte. Ltd. (Singapore), Systems@Work (M) SDN BHD (Kuala Lumpur) and Safe2Pay Pte. Ltd. (Singapore), alongside Trustpay International GmbH, Wire Card Beteiligungs GmbH, Wirecard Technologies AG, cardSystems FZ-LLC, Wirecard Asia Pte. Ltd., E-Credit Plus Corp., Wirecard Malaysia SDN BHD (formerly Credence Collection SDN BHD) and E-Payments Singapore Pte. Ltd.; 22 subsidiaries were fully consolidated at 31 December 2011, against 18 a year earlier."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-2011-holdings","record":{"id":"c-str-2011-holdings","kind":"fact","text":"In 2011 Wire Card Beteiligungs GmbH and Trustpay International GmbH, both based in Aschheim, acted as intermediate holding companies for group subsidiaries without operating business of their own. Together with Wirecard Technologies AG they were exempt from preparing their own consolidated accounts under § 291 of the German Commercial Code because Wirecard AG's group accounts covered them.","source_ids":["src-010"],"entity_ids":["wirecard","wd-acq-iss","wd-sih","wd-tech"],"qualification":"","response":"","outcome":""},"reading":"Fact: In 2011 Wire Card Beteiligungs GmbH and Trustpay International GmbH, both based in Aschheim, acted as intermediate holding companies for group subsidiaries without operating business of their own. Together with Wirecard Technologies AG they were exempt from preparing their own consolidated accounts under § 291 of the German Commercial Code because Wirecard AG's group accounts covered them."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-2011-functions","record":{"id":"c-str-2011-functions","kind":"fact","text":"Wirecard's 2011 report describes the subsidiaries' functions: Wirecard Technologies AG and Wirecard (Gibraltar) Ltd. developed and ran the software platform at the centre of the group's products; Click2Pay GmbH ran the CLICK2PAY internet payment system; Wirecard Payment Solutions Holdings Ltd., Wirecard UK and Ireland Ltd. and Herview Ltd. (Dublin) and Wirecard Central Eastern Europe GmbH (Klagenfurt) provided sales and processing services.","source_ids":["src-010"],"entity_ids":["wirecard","wd-tech","wd-gibraltar","click2pay","wd-psh","wd-uki","herview","wd-cee"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's 2011 report describes the subsidiaries' functions: Wirecard Technologies AG and Wirecard (Gibraltar) Ltd. developed and ran the software platform at the centre of the group's products; Click2Pay GmbH ran the CLICK2PAY internet payment system; Wirecard Payment Solutions Holdings Ltd., Wirecard UK and Ireland Ltd. and Herview Ltd. (Dublin) and Wirecard Central Eastern Europe GmbH (Klagenfurt) provided sales and processing services."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-2014-count","record":{"id":"c-str-2014-count","kind":"fact","text":"ESMA notes that Wirecard's 2014 consolidated accounts covered 33 companies in which it held all the shares.","source_ids":["src-087"],"entity_ids":["wirecard","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: ESMA notes that Wirecard's 2014 consolidated accounts covered 33 companies in which it held all the shares."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-2016-list","record":{"id":"c-str-2016-list","kind":"fact","text":"Wirecard AG's shareholdings list at 31 December 2016 shows 100% subsidiaries that no longer appear under these names in the 2018 list, among them Payment Technologies Ltd. (Wilmington, USA), Provus Service Provider S.A. (Bucharest), Trans Infotech (Vietnam) Ltd and Trans Infotech (Laos) Ltd. (the Romanian and Vietnamese companies were renamed Wirecard Romania S.A. and Wirecard (Vietnam) Ltd., as the 2017 list records); 46 subsidiaries were fully consolidated, against 37 a year earlier.","source_ids":["src-032"],"entity_ids":["wirecard","payment-tech","wd-romania","wd-vietnam","trans-laos"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard AG's shareholdings list at 31 December 2016 shows 100% subsidiaries that no longer appear under these names in the 2018 list, among them Payment Technologies Ltd. (Wilmington, USA), Provus Service Provider S.A. (Bucharest), Trans Infotech (Vietnam) Ltd and Trans Infotech (Laos) Ltd. (the Romanian and Vietnamese companies were renamed Wirecard Romania S.A. and Wirecard (Vietnam) Ltd., as the 2017 list records); 46 subsidiaries were fully consolidated, against 37 a year earlier."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-2017-list","record":{"id":"c-str-2017-list","kind":"fact","text":"The shareholdings list in Wirecard's 2017 annual report records 100% subsidiaries with their earlier names, including Wirecard Singapore Pte. Ltd. (formerly Systems@Work Pte. Ltd.), Wirecard (Vietnam) Ltd. (formerly Trans Infotech (Vietnam) Ltd.), Wirecard Romania S.A. (formerly Provus Service Provider S.A.) and Trans Infotech (Laos) Ltd.","source_ids":["src-020"],"entity_ids":["wirecard","wd-singapore","wd-vietnam","wd-romania","trans-laos"],"qualification":"","response":"","outcome":""},"reading":"Fact: The shareholdings list in Wirecard's 2017 annual report records 100% subsidiaries with their earlier names, including Wirecard Singapore Pte. Ltd. (formerly Systems@Work Pte. Ltd.), Wirecard (Vietnam) Ltd. (formerly Trans Infotech (Vietnam) Ltd.), Wirecard Romania S.A. (formerly Provus Service Provider S.A.) and Trans Infotech (Laos) Ltd."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-2017-founded","record":{"id":"c-str-2017-founded","kind":"fact","text":"In 2017 the group founded Wirecard (Thailand) Co. Ltd. (Bangkok), Wirecard E-Money Philippines Inc. (Manila), and three German companies in Aschheim: Wirecard Issuing Technologies GmbH, Wirecard Service Technologies GmbH and Wirecard Acceptance Technologies GmbH.","source_ids":["src-020"],"entity_ids":["wirecard","wd-thailand","wd-emoney-ph","wd-issuing-tech","wd-service-tech","wd-acceptance-tech"],"qualification":"","response":"","outcome":""},"reading":"Fact: In 2017 the group founded Wirecard (Thailand) Co. Ltd. (Bangkok), Wirecard E-Money Philippines Inc. (Manila), and three German companies in Aschheim: Wirecard Issuing Technologies GmbH, Wirecard Service Technologies GmbH and Wirecard Acceptance Technologies GmbH."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-2018-list-1","record":{"id":"c-str-2018-list-1","kind":"fact","text":"According to the shareholdings list in its 2018 annual report, Wirecard AG held directly or indirectly 100% of these companies: Wirecard Sales International Holding GmbH (Aschheim), Wirecard Payment Solutions Holdings Ltd., Wirecard UK and Ireland Ltd. and Herview Ltd. (Dublin), Wirecard Central Eastern Europe GmbH (Graz), Wirecard Asia Holding Pte. Ltd. and Wirecard Singapore Pte. Ltd., Wirecard (Vietnam) Ltd., Wirecard Payment Solutions Malaysia SDN BHD, PT Prima Vista Solusi and PT Aprisma Indonesia (Jakarta), Wirecard Myanmar Ltd., Wirecard (Thailand) Co. Ltd., Wirecard India Private Ltd., American Payment Holding Inc. (Toronto), Hermes I Tickets Pte Ltd (Chennai), GI Philippines Corp, Wirecard Forex India Pte Ltd (formerly Star Global Currency Exchange), Wirecard Romania S.A., Romcard S.A. and Supercard Solutions & Services S.R.L. (Bucharest), Wirecard Global Sales GmbH, Wirecard Poland Sp. z o.o., Wirecard LLC (Moscow) and Wirecard Mexico S.A. de C.V.","source_ids":["src-005"],"entity_ids":["wirecard","wd-sih","wd-psh","wd-uki","herview","wd-cee","wd-asia-holding","wd-singapore","wd-vietnam","wd-ps-malaysia","prima-vista","wd-indonesia","wd-myanmar","wd-thailand","wd-india","american-payment","hermes","gi-philippines","wd-forex-india","wd-romania","romcard","supercard","wd-global-sales","wd-poland","wd-llc","wd-mexico"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the shareholdings list in its 2018 annual report, Wirecard AG held directly or indirectly 100% of these companies: Wirecard Sales International Holding GmbH (Aschheim), Wirecard Payment Solutions Holdings Ltd., Wirecard UK and Ireland Ltd. and Herview Ltd. (Dublin), Wirecard Central Eastern Europe GmbH (Graz), Wirecard Asia Holding Pte. Ltd. and Wirecard Singapore Pte. Ltd., Wirecard (Vietnam) Ltd., Wirecard Payment Solutions Malaysia SDN BHD, PT Prima Vista Solusi and PT Aprisma Indonesia (Jakarta), Wirecard Myanmar Ltd., Wirecard (Thailand) Co. Ltd., Wirecard India Private Ltd., American Payment Holding Inc. (Toronto), Hermes I Tickets Pte Ltd (Chennai), GI Philippines Corp, Wirecard Forex India Pte Ltd (formerly Star Global Currency Exchange), Wirecard Romania S.A., Romcard S.A. and Supercard Solutions & Services S.R.L. (Bucharest), Wirecard Global Sales GmbH, Wirecard Poland Sp. z o.o., Wirecard LLC (Moscow) and Wirecard Mexico S.A. de C.V."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-2018-list-2","record":{"id":"c-str-2018-list-2","kind":"fact","text":"The continuation of the 2018 list adds further 100% subsidiaries: Wirecard Technologies GmbH, Wirecard Communication Services GmbH (Leipzig), Wirecard Retail Services GmbH, cardSystems Middle East FZ-LLC (Dubai), MyGate Communications Pty Ltd. (Cape Town), Wirecard Acceptance Technologies GmbH, Wirecard Service Technologies GmbH, Wirecard Issuing Technologies GmbH, Wirecard NZ Ltd, Wirecard Australia Pty Ltd, Wirecard Africa Holding Proprietary Ltd., Wirecard South Africa Proprietary Ltd., Wirecard Payment Services (Namibia) (Pty) Ltd, Wirecard Slovakia s.r.o., Click2Pay GmbH, Wirecard (Gibraltar) Ltd., Wirecard Processing FZ LLC (Dubai), Wirecard Acquiring & Issuing GmbH, Wirecard Bank AG, Wirecard Brazil S.A., Wirecard Card Solutions Ltd. (Newcastle), Wirecard E-Money Philippines Inc., Wirecard Luxembourg S.A., Wirecard Ödeme ve Elektronik Para Hizmetleri A.Ş. (Istanbul), Wirecard North America Inc. (Conshohocken), Wirecard Australia A&I Pty Ltd., Wirecard Hong Kong Ltd. and Wirecard Payment Solutions Hong Kong. It holds 60% of GI Technology Pte. Ltd. (Chennai), accounted for by the equity method, and states that 53 subsidiaries were fully consolidated (50 a year earlier).","source_ids":["src-005"],"entity_ids":["wirecard","wd-tech","wd-comm-services","wd-retail-services","cardsystems-me","mygate","wd-acceptance-tech","wd-service-tech","wd-issuing-tech","wd-nz","wd-australia","wd-africa-holding","wd-south-africa","wd-namibia","wd-slovakia","click2pay","wd-gibraltar","wd-processing","wd-acq-iss","wd-bank","wd-brazil","wd-card-solutions","wd-emoney-ph","wd-luxembourg","wd-turkey","wd-north-america","wd-australia-ai","wd-hk","wd-ps-hk","gi-technology"],"qualification":"","response":"","outcome":""},"reading":"Fact: The continuation of the 2018 list adds further 100% subsidiaries: Wirecard Technologies GmbH, Wirecard Communication Services GmbH (Leipzig), Wirecard Retail Services GmbH, cardSystems Middle East FZ-LLC (Dubai), MyGate Communications Pty Ltd. (Cape Town), Wirecard Acceptance Technologies GmbH, Wirecard Service Technologies GmbH, Wirecard Issuing Technologies GmbH, Wirecard NZ Ltd, Wirecard Australia Pty Ltd, Wirecard Africa Holding Proprietary Ltd., Wirecard South Africa Proprietary Ltd., Wirecard Payment Services (Namibia) (Pty) Ltd, Wirecard Slovakia s.r.o., Click2Pay GmbH, Wirecard (Gibraltar) Ltd., Wirecard Processing FZ LLC (Dubai), Wirecard Acquiring & Issuing GmbH, Wirecard Bank AG, Wirecard Brazil S.A., Wirecard Card Solutions Ltd. (Newcastle), Wirecard E-Money Philippines Inc., Wirecard Luxembourg S.A., Wirecard Ödeme ve Elektronik Para Hizmetleri A.Ş. (Istanbul), Wirecard North America Inc. (Conshohocken), Wirecard Australia A&I Pty Ltd., Wirecard Hong Kong Ltd. and Wirecard Payment Solutions Hong Kong. It holds 60% of GI Technology Pte. Ltd. (Chennai), accounted for by the equity method, and states that 53 subsidiaries were fully consolidated (50 a year earlier)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-2018-founded","record":{"id":"c-str-2018-founded","kind":"fact","text":"Wirecard's 2019 bond prospectus records four companies founded in 2018, Wirecard Slovakia s.r.o. (Košice), Wirecard LLC (Moscow), Wirecard Luxembourg S.A. and Wirecard Payment Services (Namibia) (Pty) Ltd (Windhoek), and three founded in 2019: Beijing Wirecard Technology Solutions Co. Ltd., Wirecard U.S. Holdings, Inc. (Wilmington) and WDB US, Inc. (Salt Lake City).","source_ids":["src-012"],"entity_ids":["wirecard","wd-slovakia","wd-llc","wd-luxembourg","wd-namibia","beijing-wd","wd-us-holding","wdb-us"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's 2019 bond prospectus records four companies founded in 2018, Wirecard Slovakia s.r.o. (Košice), Wirecard LLC (Moscow), Wirecard Luxembourg S.A. and Wirecard Payment Services (Namibia) (Pty) Ltd (Windhoek), and three founded in 2019: Beijing Wirecard Technology Solutions Co. Ltd., Wirecard U.S. Holdings, Inc. (Wilmington) and WDB US, Inc. (Salt Lake City)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-2019-list","record":{"id":"c-str-2019-list","kind":"fact","text":"The 2019 bond prospectus states that Wirecard AG held directly or indirectly 100% of its subsidiaries except GI Technology Pte. Ltd. (60%). The list includes PT Wirecard Technologies Indonesia (Jakarta), Wirecard Solutions South Africa (Pty) Ltd (Cape Town), Beijing Wirecard Technology Solutions Co. Ltd., Wirecard U.S. Holding, Inc. and WDB US, Inc., and it still includes Wirecard Bank AG, Wirecard Card Solutions Ltd. and Wirecard North America Inc.","source_ids":["src-012"],"entity_ids":["wirecard","gi-technology","wd-indonesia","wd-sa-solutions","beijing-wd","wd-us-holding","wdb-us","wd-bank","wd-card-solutions","wd-north-america"],"qualification":"","response":"","outcome":""},"reading":"Fact: The 2019 bond prospectus states that Wirecard AG held directly or indirectly 100% of its subsidiaries except GI Technology Pte. Ltd. (60%). The list includes PT Wirecard Technologies Indonesia (Jakarta), Wirecard Solutions South Africa (Pty) Ltd (Cape Town), Beijing Wirecard Technology Solutions Co. Ltd., Wirecard U.S. Holding, Inc. and WDB US, Inc., and it still includes Wirecard Bank AG, Wirecard Card Solutions Ltd. and Wirecard North America Inc."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-2019-halfyear","record":{"id":"c-str-2019-halfyear","kind":"fact","text":"Wirecard's half-year report for the first half of 2019 lists 100% subsidiaries at 30 June 2019 except GI Technology Pte. Ltd. (60%, equity method), with 53 subsidiaries fully consolidated; it names PT Wirecard Technologies Indonesia as the former PT Aprisma Indonesia, records the founding of Beijing Wirecard Technology Solutions Co. Ltd. and Wirecard U.S. Holdings, Inc. in the first half of 2019, and the merger of Wirecard South Africa Proprietary Ltd. and MyGate Communications Pty Ltd. into Wirecard Africa Holding Proprietary Ltd. (Cape Town).","source_ids":["src-066"],"entity_ids":["wirecard","gi-technology","wd-indonesia","beijing-wd","wd-us-holding","wd-south-africa","mygate","wd-africa-holding"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's half-year report for the first half of 2019 lists 100% subsidiaries at 30 June 2019 except GI Technology Pte. Ltd. (60%, equity method), with 53 subsidiaries fully consolidated; it names PT Wirecard Technologies Indonesia as the former PT Aprisma Indonesia, records the founding of Beijing Wirecard Technology Solutions Co. Ltd. and Wirecard U.S. Holdings, Inc. in the first half of 2019, and the merger of Wirecard South Africa Proprietary Ltd. and MyGate Communications Pty Ltd. into Wirecard Africa Holding Proprietary Ltd. (Cape Town)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-registry-profile","record":{"id":"c-str-registry-profile","kind":"fact","text":"A registry aggregator's network view of the German register lists Click2Pay GmbH, Wirecard Sales International Holding GmbH and Wirecard Technologies GmbH as 100% holdings of Wirecard AG; for a stock corporation the register keeps no shareholder list.","source_ids":["src-033"],"entity_ids":["wirecard","click2pay","wd-sih","wd-tech"],"qualification":"","response":"","outcome":""},"reading":"Fact: A registry aggregator's network view of the German register lists Click2Pay GmbH, Wirecard Sales International Holding GmbH and Wirecard Technologies GmbH as 100% holdings of Wirecard AG; for a stock corporation the register keeps no shareholder list."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-trustpay-ag","record":{"id":"c-str-trustpay-ag","kind":"fact","text":"Trustpay International AG was a stock corporation registered in Munich under HRB 167639 on 30 April 2007 with capital of EUR 50,000 and deleted on 24 August 2010; it began as the shelf company Blitz 07-210 AG (Munich) and later moved to Grasbrunn.","source_ids":["src-011"],"entity_ids":["wd-sih"],"qualification":"","response":"","outcome":""},"reading":"Fact: Trustpay International AG was a stock corporation registered in Munich under HRB 167639 on 30 April 2007 with capital of EUR 50,000 and deleted on 24 August 2010; it began as the shelf company Blitz 07-210 AG (Munich) and later moved to Grasbrunn."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-wsih-history","record":{"id":"c-str-wsih-history","kind":"fact","text":"Wirecard Sales International Holding GmbH (Munich HRB 187465) came into being on 24 August 2010 as Trustpay International GmbH by conversion of Trustpay International AG (HRB 167639) into a limited liability company; its shareholders renamed it Wirecard Sales International GmbH on 10 May 2012 and Wirecard Sales International Holding GmbH on 18 July 2016.","source_ids":["src-012"],"entity_ids":["wd-sih"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard Sales International Holding GmbH (Munich HRB 187465) came into being on 24 August 2010 as Trustpay International GmbH by conversion of Trustpay International AG (HRB 167639) into a limited liability company; its shareholders renamed it Wirecard Sales International GmbH on 10 May 2012 and Wirecard Sales International Holding GmbH on 18 July 2016."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-wsih-owner","record":{"id":"c-str-wsih-owner","kind":"fact","text":"According to the 2019 bond prospectus, Wirecard AG was the sole shareholder of Wirecard Sales International Holding GmbH, whose share capital of EUR 50,000 consisted of one share; its annual accounts were audited by BakerTilly GmbH & Co. KG Wirtschaftsprüfungsgesellschaft (Hamburg).","source_ids":["src-012"],"entity_ids":["wd-sih","wirecard","bakertilly"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the 2019 bond prospectus, Wirecard AG was the sole shareholder of Wirecard Sales International Holding GmbH, whose share capital of EUR 50,000 consisted of one share; its annual accounts were audited by BakerTilly GmbH & Co. KG Wirtschaftsprüfungsgesellschaft (Hamburg)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-wsih-control","record":{"id":"c-str-wsih-control","kind":"fact","text":"On 10 May 2012 Wirecard Sales International GmbH concluded a control and profit-transfer agreement with Wirecard AG as the controlling company; its shareholders approved it on 26 June 2012 and the register entry dates from 11 July 2012. A register entry of 10 November 2020 records that the agreement ended by termination on 20 August 2020.","source_ids":["src-014","src-001"],"entity_ids":["wd-sih","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 10 May 2012 Wirecard Sales International GmbH concluded a control and profit-transfer agreement with Wirecard AG as the controlling company; its shareholders approved it on 26 June 2012 and the register entry dates from 11 July 2012. A register entry of 10 November 2020 records that the agreement ended by termination on 20 August 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-wpsh","record":{"id":"c-str-wpsh","kind":"fact","text":"Wirecard Payment Solutions Holdings Limited (Dublin, Companies Registration Office number 409925) was first named Gateway E-Commerce Solutions Holdings Limited, then Gateway Payment Solutions Holdings Limited, and has carried its current name since 21 December 2007. The 2019 bond prospectus describes it as an Irish holding company and a wholly owned subsidiary of Wirecard Sales International Holding GmbH, itself wholly owned by Wirecard AG.","source_ids":["src-012"],"entity_ids":["wd-psh","wd-sih","wirecard","wd-uki","herview"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard Payment Solutions Holdings Limited (Dublin, Companies Registration Office number 409925) was first named Gateway E-Commerce Solutions Holdings Limited, then Gateway Payment Solutions Holdings Limited, and has carried its current name since 21 December 2007. The 2019 bond prospectus describes it as an Irish holding company and a wholly owned subsidiary of Wirecard Sales International Holding GmbH, itself wholly owned by Wirecard AG."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-wuki-owner","record":{"id":"c-str-wuki-owner","kind":"fact","text":"Ireland's Corporate Enforcement Authority states that from 2015 the sole shareholder of Wirecard UK & Ireland Limited was Wirecard Payments Solutions Holdings Limited, a wholly owned subsidiary of Wirecard AG, and that Herview Limited belonged to the same group. The company processed credit and prepaid card transactions and became insolvent as a result of the suspected fraud within the Wirecard AG group, which included a sum of EUR 1.9 billion supposedly held in an escrow account that was later found not to exist.","source_ids":["src-044"],"entity_ids":["wd-uki","wd-psh","wirecard","herview","cea-ireland"],"qualification":"","response":"","outcome":""},"reading":"Fact: Ireland's Corporate Enforcement Authority states that from 2015 the sole shareholder of Wirecard UK & Ireland Limited was Wirecard Payments Solutions Holdings Limited, a wholly owned subsidiary of Wirecard AG, and that Herview Limited belonged to the same group. The company processed credit and prepaid card transactions and became insolvent as a result of the suspected fraud within the Wirecard AG group, which included a sum of EUR 1.9 billion supposedly held in an escrow account that was later found not to exist."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-irish-liquidation","record":{"id":"c-str-irish-liquidation","kind":"fact","text":"A commercial database summarising Irish register data shows Wirecard UK and Ireland Limited (number 409923) and Wirecard Payment Solutions Holdings Limited (number 409925), both incorporated on 25 October 2005 with an address in Dublin 2 and one shareholder each, as companies in liquidation; the holding company's filings include liquidator's statements up to August 2026.","source_ids":["src-064","src-093"],"entity_ids":["wd-uki","wd-psh"],"qualification":"","response":"","outcome":""},"reading":"Fact: A commercial database summarising Irish register data shows Wirecard UK and Ireland Limited (number 409923) and Wirecard Payment Solutions Holdings Limited (number 409925), both incorporated on 25 October 2005 with an address in Dublin 2 and one shareholder each, as companies in liquidation; the holding company's filings include liquidator's statements up to August 2026."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-wdtech-history","record":{"id":"c-str-wdtech-history","kind":"fact","text":"Wirecard Technologies GmbH was formed on 13 August 2012 by conversion of Wirecard Technologies AG (HRB 142427). According to the 2019 bond prospectus that company was set up on 24 August 2000 as a shelf company registered in Potsdam (HRB 14098 P), was renamed \"Wirecard AG\" on 21 January 2002, took the name Wirecard Technologies AG on 17 December 2004 and has had its seat in Aschheim since 11 April 2011.","source_ids":["src-012"],"entity_ids":["wd-tech"],"qualification":"The 2002 name \"Wirecard AG\" belonged to this predecessor of Wirecard Technologies GmbH, not to the listed parent company, which was then called InfoGenie Europe AG and later Wire Card AG.","response":"","outcome":""},"reading":"Fact: Wirecard Technologies GmbH was formed on 13 August 2012 by conversion of Wirecard Technologies AG (HRB 142427). According to the 2019 bond prospectus that company was set up on 24 August 2000 as a shelf company registered in Potsdam (HRB 14098 P), was renamed \"Wirecard AG\" on 21 January 2002, took the name Wirecard Technologies AG on 17 December 2004 and has had its seat in Aschheim since 11 April 2011."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-wdtech-holding","record":{"id":"c-str-wdtech-holding","kind":"fact","text":"The 2019 bond prospectus describes Wirecard Technologies GmbH as a subsidiary of Wirecard AG and an intermediate holding company within the group, parent of Wirecard Issuing Technologies GmbH and Wirecard Acceptance Technologies GmbH among others. It names Wirecard AG as its sole shareholder, gives its share capital as EUR 1,101,000 and EY as auditor of its 2017 and 2018 accounts.","source_ids":["src-012"],"entity_ids":["wd-tech","wirecard","wd-issuing-tech","wd-acceptance-tech","ey"],"qualification":"","response":"","outcome":""},"reading":"Fact: The 2019 bond prospectus describes Wirecard Technologies GmbH as a subsidiary of Wirecard AG and an intermediate holding company within the group, parent of Wirecard Issuing Technologies GmbH and Wirecard Acceptance Technologies GmbH among others. It names Wirecard AG as its sole shareholder, gives its share capital as EUR 1,101,000 and EY as auditor of its 2017 and 2018 accounts."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-wdtech-agreements","record":{"id":"c-str-wdtech-agreements","kind":"fact","text":"Wirecard Technologies GmbH's register shows that, as Wirecard Technologies AG, it concluded a profit-transfer agreement on 19 July 2005 with Wire Card AG (Berlin, HRB 88060) and a control agreement on 7 May 2008 with Wirecard AG (Grasbrunn, HRB 169227). Both were terminated at the end of 2018; a new profit-transfer agreement of 11 December 2018 ended by termination on 20 August 2020.","source_ids":["src-015","src-001"],"entity_ids":["wd-tech","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard Technologies GmbH's register shows that, as Wirecard Technologies AG, it concluded a profit-transfer agreement on 19 July 2005 with Wire Card AG (Berlin, HRB 88060) and a control agreement on 7 May 2008 with Wirecard AG (Grasbrunn, HRB 169227). Both were terminated at the end of 2018; a new profit-transfer agreement of 11 December 2018 ended by termination on 20 August 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-cardsystems-owner","record":{"id":"c-str-cardsystems-owner","kind":"fact","text":"According to the 2019 bond prospectus, CardSystems Middle East FZ-LLC (Dubai) was an indirect subsidiary of Wirecard AG wholly owned by Wirecard Technologies GmbH. It operated in the group's Asia-Pacific region and cooperated with banks and financial service providers so that it could offer acquiring and issuing services where Wirecard could not use its own licence.","source_ids":["src-012"],"entity_ids":["cardsystems-me","wirecard","wd-tech"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the 2019 bond prospectus, CardSystems Middle East FZ-LLC (Dubai) was an indirect subsidiary of Wirecard AG wholly owned by Wirecard Technologies GmbH. It operated in the group's Asia-Pacific region and cooperated with banks and financial service providers so that it could offer acquiring and issuing services where Wirecard could not use its own licence."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-processing","record":{"id":"c-str-processing","kind":"fact","text":"Wirecard Processing FZ LLC (Dubai) was a wholly owned direct subsidiary of Wirecard AG; according to the 2019 bond prospectus its directors were Oliver Bellenhaus and Susanne Steidl.","source_ids":["src-012"],"entity_ids":["wd-processing","wirecard","bellenhaus","steidl"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard Processing FZ LLC (Dubai) was a wholly owned direct subsidiary of Wirecard AG; according to the 2019 bond prospectus its directors were Oliver Bellenhaus and Susanne Steidl."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-new-german-subs","record":{"id":"c-str-new-german-subs","kind":"fact","text":"Register entries show Wirecard Issuing Technologies GmbH (HRB 235570, partnership agreement of 24 August 2017, registered 2 September 2017), Wirecard Acceptance Technologies GmbH (HRB 238107, agreement of 6 December 2017, registered 10 January 2018) and Wirecard Service Technologies GmbH (HRB 238150, agreement of 6 December 2017, registered 12 January 2018), each with share capital of EUR 25,000 at Einsteinring 35 in Aschheim, developing payment, risk and cash-management applications.","source_ids":["src-042","src-041","src-043"],"entity_ids":["wd-issuing-tech","wd-acceptance-tech","wd-service-tech"],"qualification":"","response":"","outcome":""},"reading":"Fact: Register entries show Wirecard Issuing Technologies GmbH (HRB 235570, partnership agreement of 24 August 2017, registered 2 September 2017), Wirecard Acceptance Technologies GmbH (HRB 238107, agreement of 6 December 2017, registered 10 January 2018) and Wirecard Service Technologies GmbH (HRB 238150, agreement of 6 December 2017, registered 12 January 2018), each with share capital of EUR 25,000 at Einsteinring 35 in Aschheim, developing payment, risk and cash-management applications."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-acq-iss-history","record":{"id":"c-str-acq-iss-history","kind":"fact","text":"Wirecard Acquiring & Issuing GmbH (Munich HRB 156848, capital EUR 25,000) was registered on 15 April 2005 as the shelf company Blitz 05-059 GmbH. On 2 June 2005 its shareholders renamed it Wire Card Beteiligungs GmbH, moved it to Grasbrunn and gave it the purpose of acquiring and managing holdings; on 10 May 2012 it was renamed Wirecard Acquiring & Issuing GmbH.","source_ids":["src-013"],"entity_ids":["wd-acq-iss"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard Acquiring & Issuing GmbH (Munich HRB 156848, capital EUR 25,000) was registered on 15 April 2005 as the shelf company Blitz 05-059 GmbH. On 2 June 2005 its shareholders renamed it Wire Card Beteiligungs GmbH, moved it to Grasbrunn and gave it the purpose of acquiring and managing holdings; on 10 May 2012 it was renamed Wirecard Acquiring & Issuing GmbH."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-acq-iss-control","record":{"id":"c-str-acq-iss-control","kind":"fact","text":"Wire Card Beteiligungs GmbH, later Wirecard Acquiring & Issuing GmbH, concluded a control and profit-transfer agreement with Wirecard AG as the controlling company on 10 May 2012, approved by its shareholders on 26 June 2012; the agreement ended by termination with effect from 20 August 2020.","source_ids":["src-013","src-001"],"entity_ids":["wd-acq-iss","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wire Card Beteiligungs GmbH, later Wirecard Acquiring & Issuing GmbH, concluded a control and profit-transfer agreement with Wirecard AG as the controlling company on 10 May 2012, approved by its shareholders on 26 June 2012; the agreement ended by termination with effect from 20 August 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-click2pay","record":{"id":"c-str-click2pay","kind":"fact","text":"Click2Pay GmbH (Munich HRB 149001) was registered on 1 September 2003 as Matterhorn 291. V V GmbH and later moved as Click2Pay GmbH to Hallbergmoos, Grasbrunn and Aschheim. Its control and profit-transfer agreement of 28 May 2004 with InfoGenie Europe AG, renamed Wirecard AG, ended by termination on 10 September 2020.","source_ids":["src-016","src-001"],"entity_ids":["click2pay","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Click2Pay GmbH (Munich HRB 149001) was registered on 1 September 2003 as Matterhorn 291. V V GmbH and later moved as Click2Pay GmbH to Hallbergmoos, Grasbrunn and Aschheim. Its control and profit-transfer agreement of 28 May 2004 with InfoGenie Europe AG, renamed Wirecard AG, ended by termination on 10 September 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-global-sales","record":{"id":"c-str-global-sales","kind":"fact","text":"Wirecard Global Sales GmbH (HRB 223366) was founded by a partnership agreement of 15 January 2016 as Wirecard Sales Europe GmbH, a holding company for interests in payment-system companies with share capital of EUR 50,000 at Einsteinring 35, Aschheim; a shareholders' resolution of 18 January 2016, registered on 22 July 2016, renamed it Wirecard Global Sales GmbH.","source_ids":["src-018"],"entity_ids":["wd-global-sales"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard Global Sales GmbH (HRB 223366) was founded by a partnership agreement of 15 January 2016 as Wirecard Sales Europe GmbH, a holding company for interests in payment-system companies with share capital of EUR 50,000 at Einsteinring 35, Aschheim; a shareholders' resolution of 18 January 2016, registered on 22 July 2016, renamed it Wirecard Global Sales GmbH."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-comm-services","record":{"id":"c-str-comm-services","kind":"fact","text":"Wirecard Communication Services GmbH (Leipzig HRB 24925, capital EUR 30,400) provides communication and call-centre services. It was founded on 7 May 2003 as United Data GmbH in Berlin and moved its seat from Berlin (Charlottenburg HRB 107756 B) to Leipzig by a shareholders' resolution of 22 January 2009; a register database shows it in liquidation.","source_ids":["src-049","src-019"],"entity_ids":["wd-comm-services"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard Communication Services GmbH (Leipzig HRB 24925, capital EUR 30,400) provides communication and call-centre services. It was founded on 7 May 2003 as United Data GmbH in Berlin and moved its seat from Berlin (Charlottenburg HRB 107756 B) to Leipzig by a shareholders' resolution of 22 January 2009; a register database shows it in liquidation."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-2007-board","record":{"id":"c-lead-2007-board","kind":"fact","text":"The first entry for Wirecard AG in the Munich register (6 August 2007) names Dr. Markus Braun, Rüdiger Trautmann and Burkhard Ley as members of the management board (Vorstand) and grants joint power of attorney (Gesamtprokura) to Andrea Görres, Thorsten Holten, Salim Chujfi La Roche, Eric Pudewill and Jan Marsalek.","source_ids":["src-006"],"entity_ids":["wirecard","braun","trautmann","ley","goerres","holten","chujfi","pudewill","marsalek"],"qualification":"","response":"","outcome":""},"reading":"Fact: The first entry for Wirecard AG in the Munich register (6 August 2007) names Dr. Markus Braun, Rüdiger Trautmann and Burkhard Ley as members of the management board (Vorstand) and grants joint power of attorney (Gesamtprokura) to Andrea Görres, Thorsten Holten, Salim Chujfi La Roche, Eric Pudewill and Jan Marsalek."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-2010-marsalek","record":{"id":"c-lead-2010-marsalek","kind":"fact","text":"Wirecard's 2010 annual report states that Rüdiger Trautmann stepped down as sales director for personal reasons with effect from 31 January 2010 and that Jan Marsalek was appointed to the management board from 1 February 2010; the register entry of 6 May 2010 records Trautmann's departure, Marsalek's appointment and the end of Marsalek's power of attorney.","source_ids":["src-023","src-007"],"entity_ids":["wirecard","trautmann","marsalek"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's 2010 annual report states that Rüdiger Trautmann stepped down as sales director for personal reasons with effect from 31 January 2010 and that Jan Marsalek was appointed to the management board from 1 February 2010; the register entry of 6 May 2010 records Trautmann's departure, Marsalek's appointment and the end of Marsalek's power of attorney."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-2010-board","record":{"id":"c-lead-2010-board","kind":"fact","text":"The management board named in Wirecard's 2010 annual report consisted of Burkhard Ley (chief financial officer), Dr. Markus Braun (chairman and chief technology officer) and Jan Marsalek (sales, from 1 February 2010).","source_ids":["src-023"],"entity_ids":["wirecard","ley","braun","marsalek"],"qualification":"","response":"","outcome":""},"reading":"Fact: The management board named in Wirecard's 2010 annual report consisted of Burkhard Ley (chief financial officer), Dr. Markus Braun (chairman and chief technology officer) and Jan Marsalek (sales, from 1 February 2010)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-2011-board","record":{"id":"c-lead-2011-board","kind":"fact","text":"Wirecard's 2011 annual report gives the board members' start dates as 1 October 2004 for Dr. Markus Braun (chairman, technology), 1 January 2006 for Burkhard Ley (finance) and 1 February 2010 for Jan Marsalek (sales). On 22 December 2011 the supervisory board reappointed all three from 1 January 2012 for three years, and their contracts were extended to 31 December 2014.","source_ids":["src-010"],"entity_ids":["wirecard","braun","ley","marsalek"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's 2011 annual report gives the board members' start dates as 1 October 2004 for Dr. Markus Braun (chairman, technology), 1 January 2006 for Burkhard Ley (finance) and 1 February 2010 for Jan Marsalek (sales). On 22 December 2011 the supervisory board reappointed all three from 1 January 2012 for three years, and their contracts were extended to 31 December 2014."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-pay-2010-2011","record":{"id":"c-lead-pay-2010-2011","kind":"fact","text":"Wirecard's annual reports disclose management board pay: fixed annual salaries for 2010 of EUR 500,000 for Markus Braun, EUR 450,000 for Burkhard Ley, EUR 275,000 for Jan Marsalek and EUR 282,500 for the departed Rüdiger Trautmann, and total remuneration for 2011 of EUR 1.02 million for Braun, EUR 922,000 for Ley and EUR 703,000 for Marsalek. In the event of a change of control (30% or more of the votes), each board member was entitled to a bonus tied to the company's value: 0.4% for Braun and Ley and 0.25% for Marsalek.","source_ids":["src-023","src-010"],"entity_ids":["wirecard","braun","ley","marsalek","trautmann"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's annual reports disclose management board pay: fixed annual salaries for 2010 of EUR 500,000 for Markus Braun, EUR 450,000 for Burkhard Ley, EUR 275,000 for Jan Marsalek and EUR 282,500 for the departed Rüdiger Trautmann, and total remuneration for 2011 of EUR 1.02 million for Braun, EUR 922,000 for Ley and EUR 703,000 for Marsalek. In the event of a change of control (30% or more of the votes), each board member was entitled to a bonus tied to the company's value: 0.4% for Braun and Ley and 0.25% for Marsalek."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-2016-boards","record":{"id":"c-lead-2016-boards","kind":"fact","text":"At the end of 2016 Wirecard's management board consisted of Dr. Markus Braun (chairman, technology), Burkhard Ley (finance) and Jan Marsalek (sales); the supervisory board consisted of Wulf Matthias (chairman), Alfons W. Henseler (deputy), Tina Kleingarn, Stefan Klestil and Vuyiswa M'Cwabeni. Matthias was re-elected chairman on 16 June 2016, and Kleingarn and M'Cwabeni, elected when the 2016 shareholders' meeting enlarged the board, first attended its meeting of 8 September 2016.","source_ids":["src-032"],"entity_ids":["wirecard","braun","ley","marsalek","matthias","henseler","kleingarn","klestil","mcwabeni"],"qualification":"","response":"","outcome":""},"reading":"Fact: At the end of 2016 Wirecard's management board consisted of Dr. Markus Braun (chairman, technology), Burkhard Ley (finance) and Jan Marsalek (sales); the supervisory board consisted of Wulf Matthias (chairman), Alfons W. Henseler (deputy), Tina Kleingarn, Stefan Klestil and Vuyiswa M'Cwabeni. Matthias was re-elected chairman on 16 June 2016, and Kleingarn and M'Cwabeni, elected when the 2016 shareholders' meeting enlarged the board, first attended its meeting of 8 September 2016."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-2017-boards","record":{"id":"c-lead-2017-boards","kind":"fact","text":"Wirecard's 2017 annual report names Dr. Markus Braun, Burkhard Ley (finance director until 31 December 2017) and Jan Marsalek as the management board, and Wulf Matthias (chairman), Alfons W. Henseler (deputy), Tina Kleingarn, Stefan Klestil and Vuyiswa M'Cwabeni as the supervisory board; the 2018 report's remuneration table shows all five supervisory board members in office throughout 2017.","source_ids":["src-020","src-005"],"entity_ids":["wirecard","braun","ley","marsalek","matthias","henseler","kleingarn","klestil","mcwabeni"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's 2017 annual report names Dr. Markus Braun, Burkhard Ley (finance director until 31 December 2017) and Jan Marsalek as the management board, and Wulf Matthias (chairman), Alfons W. Henseler (deputy), Tina Kleingarn, Stefan Klestil and Vuyiswa M'Cwabeni as the supervisory board; the 2018 report's remuneration table shows all five supervisory board members in office throughout 2017."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-2018-change","record":{"id":"c-lead-2018-change","kind":"fact","text":"The register entry of 1 March 2018 records that Burkhard Ley left Wirecard AG's management board and that Susanne Steidl and Alexander von Knoop were appointed; Wirecard's 2019 half-year report gives 1 January 2018 as the start of their board membership.","source_ids":["src-002","src-066"],"entity_ids":["wirecard","ley","steidl","von-knoop"],"qualification":"","response":"","outcome":""},"reading":"Fact: The register entry of 1 March 2018 records that Burkhard Ley left Wirecard AG's management board and that Susanne Steidl and Alexander von Knoop were appointed; Wirecard's 2019 half-year report gives 1 January 2018 as the start of their board membership."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-2018-boards","record":{"id":"c-lead-2018-boards","kind":"fact","text":"At 31 December 2018 Wirecard's management board consisted of Dr. Markus Braun (chairman and technology), Alexander von Knoop (finance), Jan Marsalek (sales) and Susanne Steidl (products); the supervisory board consisted of Wulf Matthias (chairman), Alfons W. Henseler (deputy), Stefan Klestil, Dr. Anastassia Lauterbach, Vuyiswa M'Cwabeni and Susana Quintana-Plaza. The 2018 report states that the supervisory board extended the appointments of the long-serving chief executive Braun and chief operating officer Marsalek.","source_ids":["src-005"],"entity_ids":["wirecard","braun","von-knoop","marsalek","steidl","matthias","henseler","klestil","lauterbach","mcwabeni","quintana"],"qualification":"","response":"","outcome":""},"reading":"Fact: At 31 December 2018 Wirecard's management board consisted of Dr. Markus Braun (chairman and technology), Alexander von Knoop (finance), Jan Marsalek (sales) and Susanne Steidl (products); the supervisory board consisted of Wulf Matthias (chairman), Alfons W. Henseler (deputy), Stefan Klestil, Dr. Anastassia Lauterbach, Vuyiswa M'Cwabeni and Susana Quintana-Plaza. The 2018 report states that the supervisory board extended the appointments of the long-serving chief executive Braun and chief operating officer Marsalek."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-2019-boards","record":{"id":"c-lead-2019-boards","kind":"fact","text":"Wirecard's half-year report at 30 June 2019 lists Dr. Markus Braun (CEO), Alexander von Knoop (CFO), Jan Marsalek (COO) and Susanne Steidl (CPO) as the management board and Wulf Matthias (chairman), Stefan Klestil (deputy), Thomas Eichelmann, Dr. Anastassia Lauterbach, Vuyiswa M'Cwabeni and Susana Quintana-Plaza as the supervisory board. Alfons W. Henseler left the supervisory board on 18 June 2019, when Eichelmann joined and Klestil became deputy chairman; three supervisory board committees were set up in early 2019. All four management board members signed the report on 6 August 2019.","source_ids":["src-066"],"entity_ids":["wirecard","braun","von-knoop","marsalek","steidl","matthias","klestil","eichelmann","lauterbach","mcwabeni","quintana","henseler"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's half-year report at 30 June 2019 lists Dr. Markus Braun (CEO), Alexander von Knoop (CFO), Jan Marsalek (COO) and Susanne Steidl (CPO) as the management board and Wulf Matthias (chairman), Stefan Klestil (deputy), Thomas Eichelmann, Dr. Anastassia Lauterbach, Vuyiswa M'Cwabeni and Susana Quintana-Plaza as the supervisory board. Alfons W. Henseler left the supervisory board on 18 June 2019, when Eichelmann joined and Klestil became deputy chairman; three supervisory board committees were set up in early 2019. All four management board members signed the report on 6 August 2019."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-2019-sb-mandates","record":{"id":"c-lead-2019-sb-mandates","kind":"fact","text":"Wirecard's September 2019 bond prospectus lists, for the supervisory board chairman Wulf Matthias, membership of the board of administration of Deufol SE and the chair of Wirecard Bank AG's supervisory board, and for the deputy chairman Stefan Klestil a partnership at Speedinvest GmbH (Vienna), the post of managing director of Belview Partners GmbH and membership of Wirecard Bank AG's supervisory board. It lists Thomas Eichelmann, Vuyiswa M'Cwabeni, Dr. Anastassia Lauterbach and Susana Quintana-Plaza as the other members.","source_ids":["src-012"],"entity_ids":["wirecard","matthias","deufol","wd-bank","klestil","speedinvest","belview","eichelmann","mcwabeni","lauterbach","quintana"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's September 2019 bond prospectus lists, for the supervisory board chairman Wulf Matthias, membership of the board of administration of Deufol SE and the chair of Wirecard Bank AG's supervisory board, and for the deputy chairman Stefan Klestil a partnership at Speedinvest GmbH (Vienna), the post of managing director of Belview Partners GmbH and membership of Wirecard Bank AG's supervisory board. It lists Thomas Eichelmann, Vuyiswa M'Cwabeni, Dr. Anastassia Lauterbach and Susana Quintana-Plaza as the other members."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-2011-sb","record":{"id":"c-lead-2011-sb","kind":"fact","text":"Wirecard's 2011 annual report lists Wulf Matthias as supervisory board chairman and managing director of Bank Sarasin AG in Frankfurt, also sitting on the supervisory boards of Wirecard Bank AG, Wirecard Technologies AG and Deufol AG; Alfons W. Henseler as deputy chairman, an independent consultant also on the boards of Wirecard Bank AG, Wirecard Technologies AG and Diamos AG; and Stefan Klestil as managing director and owner of Belview Partners GmbH.","source_ids":["src-010"],"entity_ids":["wirecard","matthias","bank-sarasin","wd-bank","wd-tech","deufol","henseler","diamos","klestil","belview"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's 2011 annual report lists Wulf Matthias as supervisory board chairman and managing director of Bank Sarasin AG in Frankfurt, also sitting on the supervisory boards of Wirecard Bank AG, Wirecard Technologies AG and Deufol AG; Alfons W. Henseler as deputy chairman, an independent consultant also on the boards of Wirecard Bank AG, Wirecard Technologies AG and Diamos AG; and Stefan Klestil as managing director and owner of Belview Partners GmbH."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-2018-bank-sb","record":{"id":"c-lead-2018-bank-sb","kind":"fact","text":"Wirecard's related-party disclosure for 2018 states that supervisory board members Wulf Matthias, Stefan Klestil and Alfons W. Henseler also sat on the supervisory board of the subsidiary Wirecard Bank AG, for which the group recorded an expense of EUR 0.1 million each.","source_ids":["src-005"],"entity_ids":["wirecard","matthias","klestil","henseler","wd-bank"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's related-party disclosure for 2018 states that supervisory board members Wulf Matthias, Stefan Klestil and Alfons W. Henseler also sat on the supervisory board of the subsidiary Wirecard Bank AG, for which the group recorded an expense of EUR 0.1 million each."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-sb-later","record":{"id":"c-lead-sb-later","kind":"fact","text":"Investor-database profiles state that Wulf Matthias chaired the supervisory board of Wirecard Bank AG and had earlier been a supervisory board member of Wirecard Technologies GmbH; that Henseler sat on the supervisory board of WDB Abwicklungs AG (the former Wirecard Bank AG) and earlier on those of Wirecard Technologies GmbH and Wirecard Sales International Holding GmbH; and that Stefan Klestil sat on the boards of Wirecard AG and Wirecard Bank AG and had earlier been a supervisory board member of Trustpay International AG and Wirecard Technologies GmbH.","source_ids":["src-097","src-098","src-096"],"entity_ids":["matthias","wd-bank","wd-tech","wd-sih","henseler","klestil","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Investor-database profiles state that Wulf Matthias chaired the supervisory board of Wirecard Bank AG and had earlier been a supervisory board member of Wirecard Technologies GmbH; that Henseler sat on the supervisory board of WDB Abwicklungs AG (the former Wirecard Bank AG) and earlier on those of Wirecard Technologies GmbH and Wirecard Sales International Holding GmbH; and that Stefan Klestil sat on the boards of Wirecard AG and Wirecard Bank AG and had earlier been a supervisory board member of Trustpay International AG and Wirecard Technologies GmbH."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-kleingarn","record":{"id":"c-lead-kleingarn","kind":"fact","text":"The Bundestag reported that Tina Kleingarn told its third committee of inquiry on 19 November 2020 that she had sat on Wirecard's supervisory board in 2016–2017 and left it in protest against an opaque corporate culture, explaining her departure in a letter to the remaining members. According to her, Markus Braun brought new management board members in without effective involvement of the supervisory board, and the management board resisted effective oversight and withheld information the supervisory board needed.","source_ids":["src-079"],"entity_ids":["kleingarn","wirecard","braun","bundestag"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Bundestag reported that Tina Kleingarn told its third committee of inquiry on 19 November 2020 that she had sat on Wirecard's supervisory board in 2016–2017 and left it in protest against an opaque corporate culture, explaining her departure in a letter to the remaining members. According to her, Markus Braun brought new management board members in without effective involvement of the supervisory board, and the management board resisted effective oversight and withheld information the supervisory board needed."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-quintana","record":{"id":"c-lead-quintana","kind":"fact","text":"An investor database records that Susana Quintana-Plaza's term on Wirecard AG's supervisory board ended on 6 April 2020.","source_ids":["src-099"],"entity_ids":["quintana","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: An investor database records that Susana Quintana-Plaza's term on Wirecard AG's supervisory board ended on 6 April 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-lauterbach","record":{"id":"c-lead-lauterbach","kind":"fact","text":"An investor database lists Dr. Anastassia Lauterbach as a former supervisory board member of Wirecard AG; Wirecard's 2019 prospectus lists her other positions at the time as CEO of Lauterbach Consulting and Venturing GmbH, non-executive director of easyJet plc and of Dun & Bradstreet Corp., and chair of censhare AG.","source_ids":["src-012"],"entity_ids":["lauterbach","wirecard","easyjet","dun-bradstreet","censhare"],"qualification":"","response":"","outcome":""},"reading":"Fact: An investor database lists Dr. Anastassia Lauterbach as a former supervisory board member of Wirecard AG; Wirecard's 2019 prospectus lists her other positions at the time as CEO of Lauterbach Consulting and Venturing GmbH, non-executive director of easyJet plc and of Dun & Bradstreet Corp., and chair of censhare AG."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-2020-suspension","record":{"id":"c-lead-2020-suspension","kind":"fact","text":"On 18 June 2020 Wirecard announced that its supervisory board had suspended Jan Marsalek as a member of the management board with immediate effect, on a revocable basis, until 30 June 2020, and had appointed Dr. James H. Freis, Jr. to the board with immediate effect, earlier than the 1 July 2020 date announced on 8 May 2020, to head a newly created Integrity, Legal and Compliance department.","source_ids":["src-040"],"entity_ids":["wirecard","marsalek","freis"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 18 June 2020 Wirecard announced that its supervisory board had suspended Jan Marsalek as a member of the management board with immediate effect, on a revocable basis, until 30 June 2020, and had appointed Dr. James H. Freis, Jr. to the board with immediate effect, earlier than the 1 July 2020 date announced on 8 May 2020, to head a newly created Integrity, Legal and Compliance department."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-2020-braun-exit","record":{"id":"c-lead-2020-braun-exit","kind":"fact","text":"Wirecard announced on 30 June 2020 that Dr. Markus Braun had resigned from the management board by mutual consent with immediate effect on 19 June 2020 and that the supervisory board had terminated his employment contract with immediate effect.","source_ids":["src-048"],"entity_ids":["wirecard","braun"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard announced on 30 June 2020 that Dr. Markus Braun had resigned from the management board by mutual consent with immediate effect on 19 June 2020 and that the supervisory board had terminated his employment contract with immediate effect."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-2020-register","record":{"id":"c-lead-2020-register","kind":"fact","text":"The register entry of 1 July 2020 records that Dr. Markus Braun and Jan Marsalek left Wirecard AG's management board, that James H. Freis, Jr. (Washington DC) was appointed with sole power of representation, and that Stephan Freiherr von Erffa's power of attorney ended. A registry aggregator shows Wirecard AG as the only German company linked to Freis.","source_ids":["src-002"],"entity_ids":["wirecard","braun","marsalek","freis","von-erffa"],"qualification":"","response":"","outcome":""},"reading":"Fact: The register entry of 1 July 2020 records that Dr. Markus Braun and Jan Marsalek left Wirecard AG's management board, that James H. Freis, Jr. (Washington DC) was appointed with sole power of representation, and that Stephan Freiherr von Erffa's power of attorney ended. A registry aggregator shows Wirecard AG as the only German company linked to Freis."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-prokura-end","record":{"id":"c-lead-prokura-end","kind":"fact","text":"The register entry recording the opening of insolvency proceedings over Wirecard AG states that the powers of attorney of Andrea Görres and Thorsten Holten lapsed as a result, and that the power of attorney of Daniel Steinhoff also ended.","source_ids":["src-002"],"entity_ids":["wirecard","goerres","holten","steinhoff"],"qualification":"","response":"","outcome":""},"reading":"Fact: The register entry recording the opening of insolvency proceedings over Wirecard AG states that the powers of attorney of Andrea Görres and Thorsten Holten lapsed as a result, and that the power of attorney of Daniel Steinhoff also ended."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-other-prokura","record":{"id":"c-lead-other-prokura","kind":"fact","text":"A registry aggregator lists Christian von Hammel-Bonten among the holders of joint power of attorney of Wirecard AG, together with Thorsten Holten, Eric Pudewill, Jan Marsalek, Salim Chujfi La Roche, Andrea Görres, Stephan Freiherr von Erffa and Daniel Steinhoff, without the dates on which the powers ended.","source_ids":["src-033"],"entity_ids":["wirecard","hammel-bonten","holten","pudewill","marsalek","chujfi","goerres","von-erffa","steinhoff"],"qualification":"","response":"","outcome":""},"reading":"Fact: A registry aggregator lists Christian von Hammel-Bonten among the holders of joint power of attorney of Wirecard AG, together with Thorsten Holten, Eric Pudewill, Jan Marsalek, Salim Chujfi La Roche, Andrea Görres, Stephan Freiherr von Erffa and Daniel Steinhoff, without the dates on which the powers ended."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-acqiss-2005","record":{"id":"c-lead-acqiss-2005","kind":"fact","text":"When the shelf company Blitz 05-059 GmbH became Wire Card Beteiligungs GmbH in June 2005, its first managing director Nicole Liebera left and Dr. Markus Braun was appointed sole managing director with power of sole representation.","source_ids":["src-013"],"entity_ids":["wd-acq-iss","liebera","braun"],"qualification":"","response":"","outcome":""},"reading":"Fact: When the shelf company Blitz 05-059 GmbH became Wire Card Beteiligungs GmbH in June 2005, its first managing director Nicole Liebera left and Dr. Markus Braun was appointed sole managing director with power of sole representation."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-acqiss-officers","record":{"id":"c-lead-acqiss-officers","kind":"fact","text":"Register entries for Wirecard Acquiring & Issuing GmbH show that Markus Braun left as managing director on 10 April 2013, when Oliver Bellenhaus, Andrea Görres, Burkhard Ley and Susanne Steidl were appointed; Ley left on 26 January 2018 and Alexander von Knoop was appointed; Bellenhaus and von Knoop left on 20 August 2020, when von Erffa's power of attorney also ended; and on 2 September 2020 Görres and Steidl left and the lawyer Dr. Christoph Schotte became sole managing director, while the powers of attorney of Thorsten Holten and Daniel Steinhoff ended.","source_ids":["src-013"],"entity_ids":["wd-acq-iss","braun","bellenhaus","goerres","ley","steidl","von-knoop","von-erffa","schotte","holten","steinhoff"],"qualification":"","response":"","outcome":""},"reading":"Fact: Register entries for Wirecard Acquiring & Issuing GmbH show that Markus Braun left as managing director on 10 April 2013, when Oliver Bellenhaus, Andrea Görres, Burkhard Ley and Susanne Steidl were appointed; Ley left on 26 January 2018 and Alexander von Knoop was appointed; Bellenhaus and von Knoop left on 20 August 2020, when von Erffa's power of attorney also ended; and on 2 September 2020 Görres and Steidl left and the lawyer Dr. Christoph Schotte became sole managing director, while the powers of attorney of Thorsten Holten and Daniel Steinhoff ended."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-wsih-officers","record":{"id":"c-lead-wsih-officers","kind":"fact","text":"The first register entry for Trustpay International GmbH (25 August 2010), later Wirecard Sales International Holding GmbH, names Jan Marsalek as sole managing director and Stephan Freiherr von Erffa, Andrea Görres and Thorsten Holten as joint authorised signatories. On 25 August 2016 Holten (replacing his power of attorney) and Brigitte Häuser-Axtner were appointed managing directors; on 14 July 2020 Häuser-Axtner and Marsalek left and von Erffa's power of attorney ended. The 2019 bond prospectus lists Marsalek, Holten and Häuser-Axtner as managing directors.","source_ids":["src-014","src-012"],"entity_ids":["wd-sih","marsalek","von-erffa","goerres","holten","haeuser-axtner"],"qualification":"","response":"","outcome":""},"reading":"Fact: The first register entry for Trustpay International GmbH (25 August 2010), later Wirecard Sales International Holding GmbH, names Jan Marsalek as sole managing director and Stephan Freiherr von Erffa, Andrea Görres and Thorsten Holten as joint authorised signatories. On 25 August 2016 Holten (replacing his power of attorney) and Brigitte Häuser-Axtner were appointed managing directors; on 14 July 2020 Häuser-Axtner and Marsalek left and von Erffa's power of attorney ended. The 2019 bond prospectus lists Marsalek, Holten and Häuser-Axtner as managing directors."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-global-sales-officers","record":{"id":"c-lead-global-sales-officers","kind":"fact","text":"The first register entry for Wirecard Sales Europe GmbH, later Wirecard Global Sales GmbH, names Thorsten Holten, Brigitte Häuser-Axtner and Jan Marsalek as managing directors, with joint powers of attorney for Stephan Freiherr von Erffa and Andrea Görres; on 30 June 2020 Häuser-Axtner and Marsalek left and von Erffa's power of attorney ended.","source_ids":["src-018"],"entity_ids":["wd-global-sales","holten","haeuser-axtner","marsalek","von-erffa","goerres"],"qualification":"","response":"","outcome":""},"reading":"Fact: The first register entry for Wirecard Sales Europe GmbH, later Wirecard Global Sales GmbH, names Thorsten Holten, Brigitte Häuser-Axtner and Jan Marsalek as managing directors, with joint powers of attorney for Stephan Freiherr von Erffa and Andrea Görres; on 30 June 2020 Häuser-Axtner and Marsalek left and von Erffa's power of attorney ended."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-wdtech-officers","record":{"id":"c-lead-wdtech-officers","kind":"fact","text":"The first register entry for Wirecard Technologies GmbH (14 August 2012) names Burkhard Ley, Jan Marsalek and Dr. Markus Braun as managing directors and Michael Brinkmann, Stephan Freiherr von Erffa, Andrea Görres and Thorsten Holten as joint authorised signatories. On 5 December 2012 Ley and Marsalek left and Carlos Häuser, Jörg Möller and von Erffa became managing directors; Susanne Steidl followed on 7 November 2017; Häuser left on 27 January 2018, Braun and von Erffa on 30 June 2020 and Möller on 3 October 2020. The 2019 bond prospectus lists Braun, Möller, von Erffa and Steidl as managing directors.","source_ids":["src-015","src-012"],"entity_ids":["wd-tech","ley","marsalek","braun","brinkmann","von-erffa","goerres","holten","c-haeuser","moeller","steidl"],"qualification":"","response":"","outcome":""},"reading":"Fact: The first register entry for Wirecard Technologies GmbH (14 August 2012) names Burkhard Ley, Jan Marsalek and Dr. Markus Braun as managing directors and Michael Brinkmann, Stephan Freiherr von Erffa, Andrea Görres and Thorsten Holten as joint authorised signatories. On 5 December 2012 Ley and Marsalek left and Carlos Häuser, Jörg Möller and von Erffa became managing directors; Susanne Steidl followed on 7 November 2017; Häuser left on 27 January 2018, Braun and von Erffa on 30 June 2020 and Möller on 3 October 2020. The 2019 bond prospectus lists Braun, Möller, von Erffa and Steidl as managing directors."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-click2pay-officers","record":{"id":"c-lead-click2pay-officers","kind":"fact","text":"Click2Pay GmbH was dissolved by a register entry of 30 October 2019 naming Daniel Heuser and Jan Marsalek as liquidators and Andrea Görres and Thorsten Holten as joint authorised signatories; Marsalek ceased to be a liquidator with an entry of 18 July 2020, and on 2 March 2021 TEAM TREUHAND GmbH (Munich HRB 152237) replaced Heuser as liquidator.","source_ids":["src-016"],"entity_ids":["click2pay","heuser","marsalek","goerres","holten","team-treuhand"],"qualification":"","response":"","outcome":""},"reading":"Fact: Click2Pay GmbH was dissolved by a register entry of 30 October 2019 naming Daniel Heuser and Jan Marsalek as liquidators and Andrea Görres and Thorsten Holten as joint authorised signatories; Marsalek ceased to be a liquidator with an entry of 18 July 2020, and on 2 March 2021 TEAM TREUHAND GmbH (Munich HRB 152237) replaced Heuser as liquidator."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-commservices-officers","record":{"id":"c-lead-commservices-officers","kind":"fact","text":"Wirecard Communication Services GmbH's first Leipzig register entry (30 March 2009) names Heiner Bauer, Markus Plänitz and Dr. Markus Braun as managing directors. Braun left on 1 March 2010 and Michael Brinkmann took his place; Plänitz left with entry no. 9 of 15 May 2018, when Amra Blume was appointed; Brinkmann left with an entry of 11 August 2020, leaving Blume as managing director. A register database also lists Bettina Funk as a managing director until 6 July 2020.","source_ids":["src-006","src-104","src-049","src-019","src-105","src-036"],"entity_ids":["wd-comm-services","bauer-heiner","plaenitz","braun","brinkmann","blume","funk"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard Communication Services GmbH's first Leipzig register entry (30 March 2009) names Heiner Bauer, Markus Plänitz and Dr. Markus Braun as managing directors. Braun left on 1 March 2010 and Michael Brinkmann took his place; Plänitz left with entry no. 9 of 15 May 2018, when Amra Blume was appointed; Brinkmann left with an entry of 11 August 2020, leaving Blume as managing director. A register database also lists Bettina Funk as a managing director until 6 July 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-newsubs-officers","record":{"id":"c-lead-newsubs-officers","kind":"fact","text":"The three subsidiaries founded in 2017–2018 had small management teams. Wirecard Acceptance Technologies GmbH started with Stefan Buck, Sreelekha Sankar and Susanne Steidl as managing directors, and Buck left on 25 October 2019; Wirecard Issuing Technologies GmbH started with Sebastian Krahe, Sankar and Steidl, and managing director Arne Matthias left on 25 October 2019; Wirecard Service Technologies GmbH started with Yiannakis Ioannou and Steidl, Tom Schmidt was appointed on 16 May 2019, Ioannou left on 12 September 2019 and Thomas Neeff, also a managing director, left as well. Stephan Freiherr von Erffa, Andrea Görres and Thorsten Holten held joint powers of attorney, and Daniel Steinhoff received one on 25 October 2019.","source_ids":["src-041","src-042","src-043"],"entity_ids":["wd-acceptance-tech","wd-issuing-tech","wd-service-tech","buck","sankar","steidl","krahe","a-matthias","ioannou","neeff","t-schmidt","von-erffa","goerres","holten","steinhoff"],"qualification":"","response":"","outcome":""},"reading":"Fact: The three subsidiaries founded in 2017–2018 had small management teams. Wirecard Acceptance Technologies GmbH started with Stefan Buck, Sreelekha Sankar and Susanne Steidl as managing directors, and Buck left on 25 October 2019; Wirecard Issuing Technologies GmbH started with Sebastian Krahe, Sankar and Steidl, and managing director Arne Matthias left on 25 October 2019; Wirecard Service Technologies GmbH started with Yiannakis Ioannou and Steidl, Tom Schmidt was appointed on 16 May 2019, Ioannou left on 12 September 2019 and Thomas Neeff, also a managing director, left as well. Stephan Freiherr von Erffa, Andrea Görres and Thorsten Holten held joint powers of attorney, and Daniel Steinhoff received one on 25 October 2019."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-wpsh-directors","record":{"id":"c-lead-wpsh-directors","kind":"fact","text":"The 2019 bond prospectus names Jan Marsalek, Alan White (also company secretary), Helen Margaret Meehan and Markus-Konrad Fuchs as directors of Wirecard Payment Solutions Holdings Limited (Dublin).","source_ids":["src-012"],"entity_ids":["wd-psh","marsalek","white","meehan","fuchs"],"qualification":"","response":"","outcome":""},"reading":"Fact: The 2019 bond prospectus names Jan Marsalek, Alan White (also company secretary), Helen Margaret Meehan and Markus-Konrad Fuchs as directors of Wirecard Payment Solutions Holdings Limited (Dublin)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-cardsystems-directors","record":{"id":"c-lead-cardsystems-directors","kind":"fact","text":"The 2019 bond prospectus names Jan Marsalek and Oliver Bellenhaus as directors of CardSystems Middle East FZ-LLC (Dubai Media City) and Bellenhaus as the general manager who ran its business day to day; Wirecard Processing FZ LLC in Dubai had Bellenhaus and Susanne Steidl as directors and Nabila Nouinou as general manager.","source_ids":["src-012"],"entity_ids":["cardsystems-me","marsalek","bellenhaus","wd-processing","steidl","nouinou"],"qualification":"","response":"","outcome":""},"reading":"Fact: The 2019 bond prospectus names Jan Marsalek and Oliver Bellenhaus as directors of CardSystems Middle East FZ-LLC (Dubai Media City) and Bellenhaus as the general manager who ran its business day to day; Wirecard Processing FZ LLC in Dubai had Bellenhaus and Susanne Steidl as directors and Nabila Nouinou as general manager."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-wcs-directors","record":{"id":"c-lead-wcs-directors","kind":"fact","text":"The UK companies register lists Oliver Bellenhaus (13 February 2012 to 30 June 2020), Burkhard Ley (13 February 2012 to 31 December 2017) and Alexander von Knoop (1 January 2018 to 6 July 2020) as former directors of Wirecard Card Solutions Limited (company 07875693), and Thomas Michael Richard Jennings (since 8 December 2011) and Andrea Farace (since 19 August 2020) as its current directors; the company is in liquidation.","source_ids":["src-092","src-101","src-100"],"entity_ids":["wd-card-solutions","bellenhaus","ley","von-knoop","jennings","farace"],"qualification":"A registry aggregator gives slightly different dates for the changes of 2018 and 2020, based on publication dates.","response":"","outcome":""},"reading":"Fact: The UK companies register lists Oliver Bellenhaus (13 February 2012 to 30 June 2020), Burkhard Ley (13 February 2012 to 31 December 2017) and Alexander von Knoop (1 January 2018 to 6 July 2020) as former directors of Wirecard Card Solutions Limited (company 07875693), and Thomas Michael Richard Jennings (since 8 December 2011) and Andrea Farace (since 19 August 2020) as its current directors; the company is in liquidation."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-bank-officers","record":{"id":"c-lead-bank-officers","kind":"fact","text":"Register publications summarised by an aggregator show Alexander von Knoop at Wirecard Bank AG (now WDB Abwicklungs AG) as an authorised signatory from 10 March 2010, a management board member from an entry of 31 January 2014 and leaving the board with an entry of 9 July 2020; Burkhard Ley left the bank's management board with a publication of 3 January 2018, when Daniel Heuser was appointed.","source_ids":["src-065","src-080"],"entity_ids":["wd-bank","von-knoop","ley","heuser"],"qualification":"","response":"","outcome":""},"reading":"Fact: Register publications summarised by an aggregator show Alexander von Knoop at Wirecard Bank AG (now WDB Abwicklungs AG) as an authorised signatory from 10 March 2010, a management board member from an entry of 31 January 2014 and leaving the board with an entry of 9 July 2020; Burkhard Ley left the bank's management board with a publication of 3 January 2018, when Daniel Heuser was appointed."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-lux-board","record":{"id":"c-lead-lux-board","kind":"fact","text":"A registry aggregator shows Alexander von Knoop on the board of directors of Wirecard Luxembourg S.A. (RCS B229425, registered on 14 November 2018), leaving together with Thomas Jennings in a publication of 28 August 2020.","source_ids":["src-065"],"entity_ids":["von-knoop","wd-luxembourg","jennings"],"qualification":"","response":"","outcome":""},"reading":"Fact: A registry aggregator shows Alexander von Knoop on the board of directors of Wirecard Luxembourg S.A. (RCS B229425, registered on 14 November 2018), leaving together with Thomas Jennings in a publication of 28 August 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-own-2010","record":{"id":"c-own-2010","kind":"fact","text":"Wirecard's 2010 annual report records that MB Beteiligungsgesellschaft mbH held 7.60% of Wirecard AG's shares and that its managing director was Dr. Markus Braun, chairman of Wirecard AG's management board.","source_ids":["src-023"],"entity_ids":["mb-beteiligung","wirecard","braun"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's 2010 annual report records that MB Beteiligungsgesellschaft mbH held 7.60% of Wirecard AG's shares and that its managing director was Dr. Markus Braun, chairman of Wirecard AG's management board."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-own-2011","record":{"id":"c-own-2011","kind":"fact","text":"Shareholders with more than 3% of the votes at 31 December 2011 were MB Beteiligungsgesellschaft mbH (7.60%), Jupiter Asset Management Ltd. (6.26%), Alken Fund Sicav (5.00%), Wasatch Holdings (3.10%), Columbia Wanger AM (3.08%) and Ameriprise Financial (3.04%); the free float was 92.4%.","source_ids":["src-010"],"entity_ids":["wirecard","mb-beteiligung","jupiter-am"],"qualification":"","response":"","outcome":""},"reading":"Fact: Shareholders with more than 3% of the votes at 31 December 2011 were MB Beteiligungsgesellschaft mbH (7.60%), Jupiter Asset Management Ltd. (6.26%), Alken Fund Sicav (5.00%), Wasatch Holdings (3.10%), Columbia Wanger AM (3.08%) and Ameriprise Financial (3.04%); the free float was 92.4%."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-own-mb-loan","record":{"id":"c-own-mb-loan","kind":"fact","text":"Wirecard's 2011 annual report discloses that Wirecard AG had lent money to MB Beteiligungsgesellschaft mbH, whose sole shareholder was management board member Dr. Markus Braun: the loan stood at EUR 235,000 at 31 December 2010, peaked at EUR 241,000 during 2011 and was fully repaid in 2011.","source_ids":["src-010"],"entity_ids":["wirecard","mb-beteiligung","braun"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's 2011 annual report discloses that Wirecard AG had lent money to MB Beteiligungsgesellschaft mbH, whose sole shareholder was management board member Dr. Markus Braun: the loan stood at EUR 235,000 at 31 December 2010, peaked at EUR 241,000 during 2011 and was fully repaid in 2011."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-own-2016-2017","record":{"id":"c-own-2016-2017","kind":"fact","text":"Wirecard's annual reports show MB Beteiligungsgesellschaft mbH with 7.0% of the shares at the end of 2016 and 2017. Other holders above 3% at 31 December 2016 included Jupiter Asset Management (6.27%), Alken Luxembourg (5.44%), Citigroup (5.06%) and Artisan Partners (5.01%); at 31 December 2017 they included Jupiter (6.27%), BlackRock (5.12%), Artisan Partners (4.99%), Citigroup (4.93%) and Alken Luxembourg (4.92%).","source_ids":["src-032","src-020"],"entity_ids":["wirecard","mb-beteiligung","jupiter-am","alken","citigroup","artisan","blackrock"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's annual reports show MB Beteiligungsgesellschaft mbH with 7.0% of the shares at the end of 2016 and 2017. Other holders above 3% at 31 December 2016 included Jupiter Asset Management (6.27%), Alken Luxembourg (5.44%), Citigroup (5.06%) and Artisan Partners (5.01%); at 31 December 2017 they included Jupiter (6.27%), BlackRock (5.12%), Artisan Partners (4.99%), Citigroup (4.93%) and Alken Luxembourg (4.92%)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-own-2018","record":{"id":"c-own-2018","kind":"fact","text":"At 31 December 2018 MB Beteiligungsgesellschaft mbH held 7.05% of Wirecard AG and the free float was 92.95%, including BlackRock Inc (6.7%), Jupiter Asset Management Ltd. (5.1%), Citigroup Inc (4.93%) and Artisan Partners Asset Management Inc. (3.0%). The shares were no-par bearer shares (ISIN DE0007472060, WKN 747206), listed since 25 October 2000.","source_ids":["src-005"],"entity_ids":["wirecard","mb-beteiligung","blackrock","jupiter-am","citigroup","artisan"],"qualification":"","response":"","outcome":""},"reading":"Fact: At 31 December 2018 MB Beteiligungsgesellschaft mbH held 7.05% of Wirecard AG and the free float was 92.95%, including BlackRock Inc (6.7%), Jupiter Asset Management Ltd. (5.1%), Citigroup Inc (4.93%) and Artisan Partners Asset Management Inc. (3.0%). The shares were no-par bearer shares (ISIN DE0007472060, WKN 747206), listed since 25 October 2000."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-own-2019","record":{"id":"c-own-2019","kind":"fact","text":"Voting-rights notifications listed in Wirecard's half-year report at 30 June 2019 show MB Beteiligungsgesellschaft mbH with 7.05%, BlackRock 5.77%, Artisan Partners 5.24%, Jupiter Asset Management 5.00%, Citigroup 4.93% and Goldman Sachs 3.53%. The September 2019 bond prospectus gives the position at 31 August 2019 as MB Beteiligungsgesellschaft mbH, attributed to Markus Braun, 8.04%, BlackRock 5.82%, Artisan 5.24%, Jupiter Fund Management plc 5.00%, Citigroup 4.93% and Goldman Sachs 3.53%.","source_ids":["src-066","src-012"],"entity_ids":["wirecard","mb-beteiligung","braun","blackrock","artisan","jupiter-am","jupiter-fm","citigroup","goldman"],"qualification":"","response":"","outcome":""},"reading":"Fact: Voting-rights notifications listed in Wirecard's half-year report at 30 June 2019 show MB Beteiligungsgesellschaft mbH with 7.05%, BlackRock 5.77%, Artisan Partners 5.24%, Jupiter Asset Management 5.00%, Citigroup 4.93% and Goldman Sachs 3.53%. The September 2019 bond prospectus gives the position at 31 August 2019 as MB Beteiligungsgesellschaft mbH, attributed to Markus Braun, 8.04%, BlackRock 5.82%, Artisan 5.24%, Jupiter Fund Management plc 5.00%, Citigroup 4.93% and Goldman Sachs 3.53%."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-own-mb-registry","record":{"id":"c-own-mb-registry","kind":"fact","text":"MB Beteiligungsgesellschaft mbH was registered in Munich under HRB 152399 on 11 May 2004 with capital of EUR 25,000; it was later deleted from the Munich register after moving its seat to Limburg an der Lahn, where an aggregator shows it under HRB 6968 with the Legal Entity Identifier 529900W00T44TXFNWF20. A subsidiary's register page lists it at Einsteinring 35 in Aschheim, Wirecard AG's address until 2022.","source_ids":["src-017","src-016","src-091"],"entity_ids":["mb-beteiligung","wirecard","click2pay"],"qualification":"","response":"","outcome":""},"reading":"Fact: MB Beteiligungsgesellschaft mbH was registered in Munich under HRB 152399 on 11 May 2004 with capital of EUR 25,000; it was later deleted from the Munich register after moving its seat to Limburg an der Lahn, where an aggregator shows it under HRB 6968 with the Legal Entity Identifier 529900W00T44TXFNWF20. A subsidiary's register page lists it at Einsteinring 35 in Aschheim, Wirecard AG's address until 2022."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-2011-loans","record":{"id":"c-fin-2011-loans","kind":"fact","text":"Wirecard's 2011 annual report says the group's interest-bearing bank liabilities rose by EUR 64.0 million to EUR 86.0 million after being moved in the second quarter of 2011 into a long-term framework loan for completed and potential acquisitions; a further EUR 17.1 million was used as guarantee facilities.","source_ids":["src-010"],"entity_ids":["wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's 2011 annual report says the group's interest-bearing bank liabilities rose by EUR 64.0 million to EUR 86.0 million after being moved in the second quarter of 2011 into a long-term framework loan for completed and potential acquisitions; a further EUR 17.1 million was used as guarantee facilities."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-syndicated-2017-2018","record":{"id":"c-fin-syndicated-2017-2018","kind":"fact","text":"Wirecard AG reported a firm credit line with a bank consortium of EUR 1,000 million in its 2017 annual report and of EUR 1,905.6 million in its 2018 report; each consortium member could cancel its share and demand repayment on a change of control. The banks are not named in those passages.","source_ids":["src-020","src-005"],"entity_ids":["wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard AG reported a firm credit line with a bank consortium of EUR 1,000 million in its 2017 annual report and of EUR 1,905.6 million in its 2018 report; each consortium member could cancel its share and demand repayment on a change of control. The banks are not named in those passages."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-rcf-2018","record":{"id":"c-fin-rcf-2018","kind":"fact","text":"According to the 2019 bond prospectus, Wirecard AG was the borrower under a EUR 1,750 million syndicated revolving credit facility dated 15 June 2018, guaranteed by four subsidiaries, with ABN Amro Bank N.V., Commerzbank AG, ING Bank (a branch of ING-DiBa AG) and Landesbank Baden-Württemberg as mandated lead arrangers and Commerzbank as agent.","source_ids":["src-012"],"entity_ids":["wirecard","abn-amro","commerzbank","ing-diba","lbbw"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the 2019 bond prospectus, Wirecard AG was the borrower under a EUR 1,750 million syndicated revolving credit facility dated 15 June 2018, guaranteed by four subsidiaries, with ABN Amro Bank N.V., Commerzbank AG, ING Bank (a branch of ING-DiBa AG) and Landesbank Baden-Württemberg as mandated lead arrangers and Commerzbank as agent."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-2018-bank-loans","record":{"id":"c-fin-2018-bank-loans","kind":"fact","text":"Wirecard's 2018 annual report states that commercial banks had lent the group EUR 1,466.1 million at 31 December 2018 at interest rates between 0.85% and 3.10%, without naming the banks; Wirecard AG's own bank liabilities rose from EUR 1,075.1 million to EUR 1,455.3 million in 2018, which the company linked to acquisitions of companies and customer portfolios.","source_ids":["src-005"],"entity_ids":["wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's 2018 annual report states that commercial banks had lent the group EUR 1,466.1 million at 31 December 2018 at interest rates between 0.85% and 3.10%, without naming the banks; Wirecard AG's own bank liabilities rose from EUR 1,075.1 million to EUR 1,455.3 million in 2018, which the company linked to acquisitions of companies and customer portfolios."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-2019-liabilities","record":{"id":"c-fin-2019-liabilities","kind":"fact","text":"Wirecard's unaudited half-year report for 2019 states that interest-bearing liabilities rose by EUR 251.6 million to EUR 1,717.6 million at 30 June 2019, citing acquisitions, digital lending and licences in Asia and the United States, with bank credit commitments of EUR 1,898.3 million in total; long-term interest-bearing liabilities rose by EUR 245.9 million to EUR 1,594.6 million.","source_ids":["src-066"],"entity_ids":["wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's unaudited half-year report for 2019 states that interest-bearing liabilities rose by EUR 251.6 million to EUR 1,717.6 million at 30 June 2019, citing acquisitions, digital lending and licences in Asia and the United States, with bank credit commitments of EUR 1,898.3 million in total; long-term interest-bearing liabilities rose by EUR 245.9 million to EUR 1,594.6 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-bond-2019","record":{"id":"c-fin-bond-2019","kind":"fact","text":"In September 2019 Wirecard AG issued EUR 500 million of 0.50% notes due 2024 (ISIN DE000A2YNQ58), unconditionally and jointly guaranteed by Wirecard Technologies GmbH, Wirecard Sales International Holding GmbH, Wirecard Payment Solutions Holdings Limited, CardSystems Middle East FZ-LLC and Wirecard Processing FZ-LLC. The bond initially carried a Moody's Baa3 investment-grade rating, withdrawn on 22 June 2020, and was listed on the Luxembourg Stock Exchange's Euro MTF.","source_ids":["src-012","src-025"],"entity_ids":["wirecard","wd-tech","wd-sih","wd-psh","cardsystems-me","wd-processing"],"qualification":"","response":"","outcome":""},"reading":"Fact: In September 2019 Wirecard AG issued EUR 500 million of 0.50% notes due 2024 (ISIN DE000A2YNQ58), unconditionally and jointly guaranteed by Wirecard Technologies GmbH, Wirecard Sales International Holding GmbH, Wirecard Payment Solutions Holdings Limited, CardSystems Middle East FZ-LLC and Wirecard Processing FZ-LLC. The bond initially carried a Moody's Baa3 investment-grade rating, withdrawn on 22 June 2020, and was listed on the Luxembourg Stock Exchange's Euro MTF."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-bond-banks","record":{"id":"c-fin-bond-banks","kind":"fact","text":"The cover of the 2019 bond prospectus names Crédit Agricole CIB, ABN AMRO and Credit Suisse as joint global coordinators and Deutsche Bank, ING, Citigroup and Lloyds Bank Corporate Markets Wertpapierhandelsbank as joint bookrunners.","source_ids":["src-012"],"entity_ids":["wirecard","cacib","abn-amro","credit-suisse","deutsche-bank","ing","citigroup","lloyds-cm"],"qualification":"","response":"","outcome":""},"reading":"Fact: The cover of the 2019 bond prospectus names Crédit Agricole CIB, ABN AMRO and Credit Suisse as joint global coordinators and Deutsche Bank, ING, Citigroup and Lloyds Bank Corporate Markets Wertpapierhandelsbank as joint bookrunners."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-softbank","record":{"id":"c-fin-softbank","kind":"fact","text":"After the 2018 reporting date Wirecard AG signed a binding memorandum of understanding with SoftBank Group Corp. under which a SoftBank group company would invest about EUR 900 million through a convertible bond, together with a strategic partnership in digital payments aimed at Japan and South Korea. The 2019 prospectus records a binding term sheet of 24 April 2019 for five-year convertible bonds 2019/2024 convertible into up to 6,923,076 shares at EUR 130, approved by the shareholders' meeting on 18 June 2019; the bonds are unsecured, unsubordinated and carry 1.90% interest.","source_ids":["src-005","src-012"],"entity_ids":["wirecard","softbank"],"qualification":"","response":"","outcome":""},"reading":"Fact: After the 2018 reporting date Wirecard AG signed a binding memorandum of understanding with SoftBank Group Corp. under which a SoftBank group company would invest about EUR 900 million through a convertible bond, together with a strategic partnership in digital payments aimed at Japan and South Korea. The 2019 prospectus records a binding term sheet of 24 April 2019 for five-year convertible bonds 2019/2024 convertible into up to 6,923,076 shares at EUR 130, approved by the shareholders' meeting on 18 June 2019; the bonds are unsecured, unsubordinated and carry 1.90% interest."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-wd-invest","record":{"id":"c-fin-wd-invest","kind":"fact","text":"The convertible bond of EUR 900 million due 2 October 2024 (ISIN DE000A2R76L7) was issued by WD Invest S.à r.l., formerly Luxembourg Investment Company 326 S.à r.l. (RCS B237265; LEI 52990062BWDZT8AJSS21 according to a registry aggregator), and guaranteed by Wirecard AG; a list of deliverable obligations drawn up by a credit-derivatives determinations committee on 18 July 2020 includes both this bond and Wirecard AG's EUR 500 million 0.5% notes.","source_ids":["src-022","src-021"],"entity_ids":["wd-invest","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: The convertible bond of EUR 900 million due 2 October 2024 (ISIN DE000A2R76L7) was issued by WD Invest S.à r.l., formerly Luxembourg Investment Company 326 S.à r.l. (RCS B237265; LEI 52990062BWDZT8AJSS21 according to a registry aggregator), and guaranteed by Wirecard AG; a list of deliverable obligations drawn up by a credit-derivatives determinations committee on 18 July 2020 includes both this bond and Wirecard AG's EUR 500 million 0.5% notes."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-wd-invest-managers","record":{"id":"c-fin-wd-invest-managers","kind":"fact","text":"Luxembourg register publications summarised by an aggregator show that the shelf company Luxembourg Investment Company 326 S.à r.l. was registered on 23 August 2019 with Intertrust (Luxembourg) S.à r.l. as shareholder and RCS Management (Luxembourg) S.à r.l. as manager, both of which left in September 2019. Thorsten Holten (from 17 September 2019) and Stephan Freiherr von Erffa (17 September 2019 to 1 July 2020) became managers, as did Riccardo Incani and Luigi Maula (30 September 2019 to 3 July 2020).","source_ids":["src-021"],"entity_ids":["wd-invest","intertrust-lux","rcs-mgmt","holten","von-erffa","incani","maula"],"qualification":"","response":"","outcome":""},"reading":"Fact: Luxembourg register publications summarised by an aggregator show that the shelf company Luxembourg Investment Company 326 S.à r.l. was registered on 23 August 2019 with Intertrust (Luxembourg) S.à r.l. as shareholder and RCS Management (Luxembourg) S.à r.l. as manager, both of which left in September 2019. Thorsten Holten (from 17 September 2019) and Stephan Freiherr von Erffa (17 September 2019 to 1 July 2020) became managers, as did Riccardo Incani and Luigi Maula (30 September 2019 to 3 July 2020)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-cash-pool","record":{"id":"c-fin-cash-pool","kind":"fact","text":"The 2019 bond prospectus describes an internal cash-management agreement under which Wirecard AG supplied subsidiaries with funds for their operations and collected their unused surpluses.","source_ids":["src-012"],"entity_ids":["wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: The 2019 bond prospectus describes an internal cash-management agreement under which Wirecard AG supplied subsidiaries with funds for their operations and collected their unused surpluses."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-2010-figures","record":{"id":"c-fin-2010-figures","kind":"fact","text":"Wirecard reported for 2010 group revenue up 19% to EUR 271.6 million and EBITDA up 21% to EUR 73.3 million, with more than 12,000 merchant customers; through the Singapore subsidiary bought in December 2009 it announced partnerships with Alipay and China UnionPay.","source_ids":["src-023"],"entity_ids":["wirecard","unionpay"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard reported for 2010 group revenue up 19% to EUR 271.6 million and EBITDA up 21% to EUR 73.3 million, with more than 12,000 merchant customers; through the Singapore subsidiary bought in December 2009 it announced partnerships with Alipay and China UnionPay."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-2016-figures","record":{"id":"c-fin-2016-figures","kind":"fact","text":"Wirecard reported for 2016 group revenue of EUR 1,028.4 million (2015: EUR 771.3 million), EBITDA of EUR 307.4 million, net profit of EUR 266.7 million, equity of EUR 1,475.0 million and total assets of EUR 3,482.1 million.","source_ids":["src-032"],"entity_ids":["wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard reported for 2016 group revenue of EUR 1,028.4 million (2015: EUR 771.3 million), EBITDA of EUR 307.4 million, net profit of EUR 266.7 million, equity of EUR 1,475.0 million and total assets of EUR 3,482.1 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-2018-cash","record":{"id":"c-fin-2018-cash","kind":"fact","text":"Wirecard reported cash and cash equivalents of EUR 2,719.8 million at 31 December 2018 (2017: EUR 1,901.3 million), including short-term customer deposits of Wirecard Bank AG and Wirecard Card Solutions Ltd., and a company-calculated net cash position of EUR 1,646.6 million (2017: EUR 848.6 million) after deducting EUR 1,263.0 million of banking customer deposits.","source_ids":["src-005"],"entity_ids":["wirecard","wd-bank","wd-card-solutions"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard reported cash and cash equivalents of EUR 2,719.8 million at 31 December 2018 (2017: EUR 1,901.3 million), including short-term customer deposits of Wirecard Bank AG and Wirecard Card Solutions Ltd., and a company-calculated net cash position of EUR 1,646.6 million (2017: EUR 848.6 million) after deducting EUR 1,263.0 million of banking customer deposits."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-2019-halfyear","record":{"id":"c-fin-2019-halfyear","kind":"fact","text":"Wirecard's unaudited half-year report for 2019, approved by the management board on 6 August 2019 and neither audited nor reviewed by an auditor, reported revenue of EUR 1,209.8 million (first half 2018: EUR 885.2 million), EBITDA of EUR 342.1 million, cash and cash equivalents of EUR 3,047.7 million and total assets of EUR 6,697.6 million at 30 June 2019; Asia-Pacific revenue (EUR 609.4 million) exceeded Europe's (EUR 580.3 million) for the first time.","source_ids":["src-066"],"entity_ids":["wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's unaudited half-year report for 2019, approved by the management board on 6 August 2019 and neither audited nor reviewed by an auditor, reported revenue of EUR 1,209.8 million (first half 2018: EUR 885.2 million), EBITDA of EUR 342.1 million, cash and cash equivalents of EUR 3,047.7 million and total assets of EUR 6,697.6 million at 30 June 2019; Asia-Pacific revenue (EUR 609.4 million) exceeded Europe's (EUR 580.3 million) for the first time."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-2019-cash-composition","record":{"id":"c-fin-2019-cash-composition","kind":"fact","text":"The notes to the 2019 half-year report show that the group's cash of EUR 3,047.7 million at 30 June 2019 included EUR 1,559.1 million of banking customer deposits and EUR 346.9 million of Wirecard Bank's acquiring funds; unused bank credit lines amounted to EUR 291.6 million.","source_ids":["src-066"],"entity_ids":["wirecard","wd-bank"],"qualification":"","response":"","outcome":""},"reading":"Fact: The notes to the 2019 half-year report show that the group's cash of EUR 3,047.7 million at 30 June 2019 included EUR 1,559.1 million of banking customer deposits and EUR 346.9 million of Wirecard Bank's acquiring funds; unused bank credit lines amounted to EUR 291.6 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-2019-other","record":{"id":"c-fin-2019-other","kind":"fact","text":"The 2019 half-year report records financing agreements, including with sales partners, of EUR 132.4 million and banking receivables, mainly from fintech customers, of EUR 107.0 million among other financial assets, and shows legal and reporting costs rising from EUR 6.3 million to EUR 20.9 million and consulting costs from EUR 13.4 million to EUR 20.8 million, which the company attributed to the investigations in Asia.","source_ids":["src-066"],"entity_ids":["wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: The 2019 half-year report records financing agreements, including with sales partners, of EUR 132.4 million and banking receivables, mainly from fintech customers, of EUR 107.0 million among other financial assets, and shows legal and reporting costs rising from EUR 6.3 million to EUR 20.9 million and consulting costs from EUR 13.4 million to EUR 20.8 million, which the company attributed to the investigations in Asia."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-dividend-2018","record":{"id":"c-fin-dividend-2018","kind":"fact","text":"The shareholders' meeting of 18 June 2019 resolved a dividend for 2018 of EUR 24.71 million, EUR 0.20 per share, from profit of EUR 167.83 million on 123,565,586 shares; for 2016 the supervisory board had proposed EUR 0.16 per share.","source_ids":["src-066"],"entity_ids":["wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: The shareholders' meeting of 18 June 2019 resolved a dividend for 2018 of EUR 24.71 million, EUR 0.20 per share, from profit of EUR 167.83 million on 123,565,586 shares; for 2016 the supervisory board had proposed EUR 0.16 per share."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-loans-lost","record":{"id":"c-fin-loans-lost","kind":"attributed","text":"According to the investigation summarised by Germany's Federal Criminal Police Office (BKA), banks in Germany and Japan and other investors misled by false financial statements lent Wirecard AG about EUR 3.2 billion in loans and similar funds, which were probably largely lost in the insolvency.","source_ids":["src-003"],"entity_ids":["wirecard","bka"],"qualification":"The figure and its characterisation are the prosecution's account in a wanted notice, not a court finding.","response":"","outcome":""},"reading":"Attributed: According to the investigation summarised by Germany's Federal Criminal Police Office (BKA), banks in Germany and Japan and other investors misled by false financial statements lent Wirecard AG about EUR 3.2 billion in loans and similar funds, which were probably largely lost in the insolvency."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-loans-callable","record":{"id":"c-fin-loans-callable","kind":"fact","text":"Wirecard warned in an ad hoc announcement of 18 June 2020 that loans of about EUR 2 billion could be terminated if audited annual and consolidated accounts for 2019 were not presented by 19 June 2020; on 25 June 2020 it stated that without agreement with lenders loans of EUR 800 million could be terminated on 30 June 2020 and EUR 500 million on 1 July 2020. A European Parliament briefing notes that the consortium reportedly included Commerzbank, LBBW and ING.","source_ids":["src-024","src-025"],"entity_ids":["wirecard","commerzbank","lbbw","ing-diba","europarl"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard warned in an ad hoc announcement of 18 June 2020 that loans of about EUR 2 billion could be terminated if audited annual and consolidated accounts for 2019 were not presented by 19 June 2020; on 25 June 2020 it stated that without agreement with lenders loans of EUR 800 million could be terminated on 30 June 2020 and EUR 500 million on 1 July 2020. A European Parliament briefing notes that the consortium reportedly included Commerzbank, LBBW and ING."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-creditors-committee","record":{"id":"c-fin-creditors-committee","kind":"fact","text":"A news agency report of 6 July 2020 stated that Wirecard's creditors' committee represented the lending banks through ING and LBBW, bondholders through a law firm appointed by Cyrus Capital and other security holders through a firm called Tilp, and that the company owed creditors about EUR 4 billion.","source_ids":["src-094"],"entity_ids":["wirecard","ing","lbbw"],"qualification":"","response":"","outcome":""},"reading":"Fact: A news agency report of 6 July 2020 stated that Wirecard's creditors' committee represented the lending banks through ING and LBBW, bondholders through a law firm appointed by Cyrus Capital and other security holders through a firm called Tilp, and that the company owed creditors about EUR 4 billion."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-company-2017","record":{"id":"c-tpa-company-2017","kind":"fact","text":"Wirecard's 2017 annual report states that Wirecard UK & Ireland Ltd., Wirecard Brasil S.A., cardSystems Middle East FZ-LLC (Dubai) and many East Asian subsidiaries worked with various banks and financial service providers so that they could offer acquiring and issuing services where Wirecard could not use its own licence, and that the network of these acquiring partners was expanded by the 2017 purchases from Citigroup; the partners are not named.","source_ids":["src-020"],"entity_ids":["wirecard","wd-uki","wd-brazil","cardsystems-me","citigroup"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's 2017 annual report states that Wirecard UK & Ireland Ltd., Wirecard Brasil S.A., cardSystems Middle East FZ-LLC (Dubai) and many East Asian subsidiaries worked with various banks and financial service providers so that they could offer acquiring and issuing services where Wirecard could not use its own licence, and that the network of these acquiring partners was expanded by the 2017 purchases from Citigroup; the partners are not named."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-company-2018","record":{"id":"c-tpa-company-2018","kind":"fact","text":"Wirecard's 2018 annual report explains that when another bank, an external acquiring partner, processed transactions, the partner recorded the payment volumes and Wirecard showed as acquiring receivables only its commissions and rolling security reserves. Its risk report states that most receivables arose from acquiring, that Wirecard bore the main opportunities and risks whether transactions ran through the group's licensed acquirers or external acquiring partners, and that Wirecard Bank AG in some cases lent to strategic partners.","source_ids":["src-005"],"entity_ids":["wirecard","wd-bank"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's 2018 annual report explains that when another bank, an external acquiring partner, processed transactions, the partner recorded the payment volumes and Wirecard showed as acquiring receivables only its commissions and rolling security reserves. Its risk report states that most receivables arose from acquiring, that Wirecard bore the main opportunities and risks whether transactions ran through the group's licensed acquirers or external acquiring partners, and that Wirecard Bank AG in some cases lent to strategic partners."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-company-2018-segment","record":{"id":"c-tpa-company-2018-segment","kind":"fact","text":"The 2018 annual report says that volumes in the Payment Processing & Risk Management segment increasingly ran through a \"technical acquiring model\" and third-party banks, and that outside the European licensing area acquiring was offered through BIN-sponsorship models with third-party banks, which it does not name.","source_ids":["src-005"],"entity_ids":["wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: The 2018 annual report says that volumes in the Payment Processing & Risk Management segment increasingly ran through a \"technical acquiring model\" and third-party banks, and that outside the European licensing area acquiring was offered through BIN-sponsorship models with third-party banks, which it does not name."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-scope","record":{"id":"c-tpa-rp-scope","kind":"fact","text":"The special investigators appointed by the Bundestag's third committee of inquiry examined the audits of Wirecard AG's annual and consolidated accounts for 2014 to 2018, with emphasis on 2014–2016, and where necessary the internal IFRS reporting packages of CardSystems Middle East FZ-LLC, Wirecard Technologies GmbH, Wirecard UK & Ireland Ltd. and Wirecard Bank AG, using EY's electronic working papers; their report was delivered on 16 April 2021.","source_ids":["src-027"],"entity_ids":["wirecard","cardsystems-me","wd-tech","wd-uki","wd-bank","ey","bundestag"],"qualification":"","response":"","outcome":""},"reading":"Fact: The special investigators appointed by the Bundestag's third committee of inquiry examined the audits of Wirecard AG's annual and consolidated accounts for 2014 to 2018, with emphasis on 2014–2016, and where necessary the internal IFRS reporting packages of CardSystems Middle East FZ-LLC, Wirecard Technologies GmbH, Wirecard UK & Ireland Ltd. and Wirecard Bank AG, using EY's electronic working papers; their report was delivered on 16 April 2021."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-two-models","record":{"id":"c-tpa-rp-two-models","kind":"fact","text":"The special investigators describe two business models at Wirecard: an own business covering the whole payment chain with the group's own acquiring bank, Wirecard Bank, and third-party acquiring (TPA), in which the payment process and the acquiring bank's services were outsourced to three partners, Al Alam, PayEasy and Senjo, which used other acquiring banks and alone held contracts with the merchants, while Wirecard kept customer acquisition and support.","source_ids":["src-027"],"entity_ids":["wirecard","wd-bank","al-alam","payeasy","senjo"],"qualification":"","response":"","outcome":""},"reading":"Fact: The special investigators describe two business models at Wirecard: an own business covering the whole payment chain with the group's own acquiring bank, Wirecard Bank, and third-party acquiring (TPA), in which the payment process and the acquiring bank's services were outsourced to three partners, Al Alam, PayEasy and Senjo, which used other acquiring banks and alone held contracts with the merchants, while Wirecard kept customer acquisition and support."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-reasons","record":{"id":"c-tpa-rp-reasons","kind":"fact","text":"According to EY's working papers as summarised by the special investigators, certain merchant groups (adult content and dating, gambling and gaming, multi-level marketing, pharmacy, health and beauty) were moved to the third-party acquirers because they were no longer to be processed on Wirecard's platform or because Wirecard Bank AG had no acquiring licence for the merchants' countries; from Wirecard's point of view the third-party acquirer acted as an outsourcing provider.","source_ids":["src-027"],"entity_ids":["wirecard","wd-bank","ey"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to EY's working papers as summarised by the special investigators, certain merchant groups (adult content and dating, gambling and gaming, multi-level marketing, pharmacy, health and beauty) were moved to the third-party acquirers because they were no longer to be processed on Wirecard's platform or because Wirecard Bank AG had no acquiring licence for the merchants' countries; from Wirecard's point of view the third-party acquirer acted as an outsourcing provider."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-reseller","record":{"id":"c-tpa-rp-reseller","kind":"fact","text":"The TPA business rested on reseller agreements which, according to EY's notes, were identical for Al Alam, PayEasy and Senjo: Wirecard earned a commission for referring merchants, payable six to nine months later, and deposited cash collateral with the partners, in Al Alam's case first EUR 10 million and later up to EUR 20 million. Wirecard also indemnified the partners against liability and losses not caused by their own technical errors and had to provide a second security, a rolling 12-month reserve on transaction volumes with long-term risk exposure such as subscriptions.","source_ids":["src-027"],"entity_ids":["wirecard","al-alam","payeasy","senjo","ey"],"qualification":"","response":"","outcome":""},"reading":"Fact: The TPA business rested on reseller agreements which, according to EY's notes, were identical for Al Alam, PayEasy and Senjo: Wirecard earned a commission for referring merchants, payable six to nine months later, and deposited cash collateral with the partners, in Al Alam's case first EUR 10 million and later up to EUR 20 million. Wirecard also indemnified the partners against liability and losses not caused by their own technical errors and had to provide a second security, a rolling 12-month reserve on transaction volumes with long-term risk exposure such as subscriptions."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-practice","record":{"id":"c-tpa-rp-practice","kind":"attributed","text":"The special investigators found that Wirecard's actual settlement practice departed considerably from the reseller agreements: receivables from the partners were not paid after six to nine months but \"reclassified\", by agreement between Wirecard and the partner, into claims arising from security deposits, so that with fast-growing high-risk business the partners paid Wirecard little or nothing and receivables and reserves kept accumulating, while no claims were ever made on these securities. The safekeeping of funds at the partners was monitored through meetings between the management board and the partners' management without formal documentation.","source_ids":["src-027"],"entity_ids":["wirecard"],"qualification":"This is the special investigators' evaluation of EY's audit files for the parliamentary committee, not a court finding.","response":"","outcome":""},"reading":"Attributed: The special investigators found that Wirecard's actual settlement practice departed considerably from the reseller agreements: receivables from the partners were not paid after six to nine months but \"reclassified\", by agreement between Wirecard and the partner, into claims arising from security deposits, so that with fast-growing high-risk business the partners paid Wirecard little or nothing and receivables and reserves kept accumulating, while no claims were ever made on these securities. The safekeeping of funds at the partners was monitored through meetings between the management board and the partners' management without formal documentation."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-business-reason","record":{"id":"c-tpa-rp-business-reason","kind":"attributed","text":"According to the special investigators, EY's concurrence memorandum of 3 March 2016 gave as the essential business reason for the TPA business the legal carving-out of critical transactions (adult entertainment, gambling, food supplements) and circumvention of Visa and Mastercard rules and Wirecard Bank's internal rules. They note that the transfer of merchants to the third-party acquirers was documented close to the entry into force of the EU payment services directive, that Wirecard had contracts neither with the acquiring banks nor with the merchants, and that the extended liability for residual risks served the accounting purpose of showing revenue and costs gross.","source_ids":["src-027"],"entity_ids":["wirecard","ey","wd-bank"],"qualification":"These are the special investigators' reading and evaluation of EY's working papers; the underlying description came from Wirecard's management.","response":"","outcome":""},"reading":"Attributed: According to the special investigators, EY's concurrence memorandum of 3 March 2016 gave as the essential business reason for the TPA business the legal carving-out of critical transactions (adult entertainment, gambling, food supplements) and circumvention of Visa and Mastercard rules and Wirecard Bank's internal rules. They note that the transfer of merchants to the third-party acquirers was documented close to the entry into force of the EU payment services directive, that Wirecard had contracts neither with the acquiring banks nor with the merchants, and that the extended liability for residual risks served the accounting purpose of showing revenue and costs gross."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-gross","record":{"id":"c-tpa-rp-gross","kind":"attributed","text":"The special investigators state that Wirecard recorded the TPA business gross in its income statement but received money only net, so that on 2015 figures about 27% of group revenue and about 51% of the cost of materials were non-cash transactions, a fact not disclosed in the notes to the 2015 consolidated accounts.","source_ids":["src-027"],"entity_ids":["wirecard"],"qualification":"Calculation and evaluation by the special investigators from EY's working papers.","response":"","outcome":""},"reading":"Attributed: The special investigators state that Wirecard recorded the TPA business gross in its income statement but received money only net, so that on 2015 figures about 27% of group revenue and about 51% of the cost of materials were non-cash transactions, a fact not disclosed in the notes to the 2015 consolidated accounts."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-figures","record":{"id":"c-tpa-rp-figures","kind":"fact","text":"A table of key figures compiled by the special investigators from Wirecard's consolidated accounts and EY's working papers shows TPA revenue rising from EUR 308 million (2014) to EUR 376 million (2015), EUR 541 million (2016), EUR 727 million (2017) and EUR 1,034 million (2018), against group revenue of EUR 2,016 million in 2018; escrow balances included in cash rose from EUR 114 million (2015) to EUR 348 million, EUR 662 million and EUR 976 million (2018), against group cash of EUR 2,720 million in 2018, and merchant cash advance loans of EUR 250 million appear for 2018.","source_ids":["src-027"],"entity_ids":["wirecard","ey"],"qualification":"","response":"","outcome":""},"reading":"Fact: A table of key figures compiled by the special investigators from Wirecard's consolidated accounts and EY's working papers shows TPA revenue rising from EUR 308 million (2014) to EUR 376 million (2015), EUR 541 million (2016), EUR 727 million (2017) and EUR 1,034 million (2018), against group revenue of EUR 2,016 million in 2018; escrow balances included in cash rose from EUR 114 million (2015) to EUR 348 million, EUR 662 million and EUR 976 million (2018), against group cash of EUR 2,720 million in 2018, and merchant cash advance loans of EUR 250 million appear for 2018."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-2014-2015-share","record":{"id":"c-tpa-rp-2014-2015-share","kind":"fact","text":"The special investigators calculate that in 2014 the TPA business accounted for half of Wirecard's revenue (EUR 308.5 million of EUR 601.0 million), about two thirds of receivables (EUR 229.5 million) and three quarters of EBITDA (EUR 132.7 million of EUR 172.3 million), and in 2015 for EUR 375.8 million of EUR 771.3 million revenue (48.7%) and EUR 164.0 million or 72.2% of group EBITDA; the sections of the 2015 group management report on the business model never named the TPA business explicitly.","source_ids":["src-027"],"entity_ids":["wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: The special investigators calculate that in 2014 the TPA business accounted for half of Wirecard's revenue (EUR 308.5 million of EUR 601.0 million), about two thirds of receivables (EUR 229.5 million) and three quarters of EBITDA (EUR 132.7 million of EUR 172.3 million), and in 2015 for EUR 375.8 million of EUR 771.3 million revenue (48.7%) and EUR 164.0 million or 72.2% of group EBITDA; the sections of the 2015 group management report on the business model never named the TPA business explicitly."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-2018-total","record":{"id":"c-tpa-rp-2018-total","kind":"attributed","text":"The special investigators report that receivables from PayEasy, Al Alam and Senjo Group (formerly Rising Sun), claims on escrow accounts and merchant cash advance loans grew steadily from 2014 to a total of EUR 1,465.5 million at the end of 2018, that individual TPA transactions could not be traced from origination to payment in Wirecard's accounting, and that EY's 2018 group audit report did not mention bookkeeping deficiencies in the TPA business.","source_ids":["src-027"],"entity_ids":["wirecard","payeasy","al-alam","senjo","ey"],"qualification":"Evaluation by the special investigators of EY's audit files.","response":"","outcome":""},"reading":"Attributed: The special investigators report that receivables from PayEasy, Al Alam and Senjo Group (formerly Rising Sun), claims on escrow accounts and merchant cash advance loans grew steadily from 2014 to a total of EUR 1,465.5 million at the end of 2018, that individual TPA transactions could not be traced from origination to payment in Wirecard's accounting, and that EY's 2018 group audit report did not mention bookkeeping deficiencies in the TPA business."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-collateral","record":{"id":"c-tpa-rp-collateral","kind":"attributed","text":"The special investigators found that Wirecard kept permanent cash collateral of EUR 15–20 million with PayEasy and Al Alam although the acquirer was already protected by four lines of security, that an increase of PayEasy's collateral to EUR 50 million was agreed in 2016, and that Wirecard financed growing collateral, including EUR 14.5 million paid to PayEasy Solutions Inc., from its own and borrowed funds while the partners' payments were small relative to turnover and arrived only net; the report calls this economically very unusual.","source_ids":["src-027"],"entity_ids":["wirecard","payeasy","al-alam"],"qualification":"Evaluation by the special investigators; EY did not perform analytical procedures on these payment flows.","response":"","outcome":""},"reading":"Attributed: The special investigators found that Wirecard kept permanent cash collateral of EUR 15–20 million with PayEasy and Al Alam although the acquirer was already protected by four lines of security, that an increase of PayEasy's collateral to EUR 50 million was agreed in 2016, and that Wirecard financed growing collateral, including EUR 14.5 million paid to PayEasy Solutions Inc., from its own and borrowed funds while the partners' payments were small relative to turnover and arrived only net; the report calls this economically very unusual."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-payers","record":{"id":"c-tpa-rp-payers","kind":"fact","text":"According to the special investigators, the partners' payments did not refer to invoices and some came from unknown third parties: on 30 December 2014 Ressource Management Systems Pte. (Singapore) paid EUR 23.0 million into an account at Wirecard Bank with the reference \"SETTL. INV PEASYGRP 02-14\", which EY noted as a payment by an unknown third party without further work; in 2015 Tuscany Capital Advisors Pte. Ltd. paid EUR 10 million for Rising Sun/Senjo, and a further EUR 4.744 million came from \"PayEasy Solutions LTD. 5 ECOM\". Senjo's management said Tuscany belonged to the Senjo group, but Senjo's 2018 accounts do not list it as a subsidiary.","source_ids":["src-027"],"entity_ids":["wirecard","wd-bank","ressource","payeasy","tuscany","senjo","ey"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the special investigators, the partners' payments did not refer to invoices and some came from unknown third parties: on 30 December 2014 Ressource Management Systems Pte. (Singapore) paid EUR 23.0 million into an account at Wirecard Bank with the reference \"SETTL. INV PEASYGRP 02-14\", which EY noted as a payment by an unknown third party without further work; in 2015 Tuscany Capital Advisors Pte. Ltd. paid EUR 10 million for Rising Sun/Senjo, and a further EUR 4.744 million came from \"PayEasy Solutions LTD. 5 ECOM\". Senjo's management said Tuscany belonged to the Senjo group, but Senjo's 2018 accounts do not list it as a subsidiary."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-alalam-cheques","record":{"id":"c-tpa-rp-alalam-cheques","kind":"fact","text":"The special investigators found that Al Alam paid Wirecard in 2015–2017 mainly by cheques without payment references (EUR 39.9 million), drawn on accounts at Wirecard Bank (account 60757 EUR 36.3 million, account 59049 EUR 4.8 million), that on 29 December 2017 EUR 14,267,271 arrived from account 59049, and that a transaction slip for a cheque of EUR 2,997,988.82 dated 9 July 2015 named Wirecard Bank AG itself, not Al Alam, as the issuing client. Al Alam held several accounts at Wirecard Bank in Germany and used German-language cheque forms, which the report counts among signs of the partners' particular closeness to Wirecard.","source_ids":["src-027"],"entity_ids":["wirecard","al-alam","wd-bank"],"qualification":"","response":"","outcome":""},"reading":"Fact: The special investigators found that Al Alam paid Wirecard in 2015–2017 mainly by cheques without payment references (EUR 39.9 million), drawn on accounts at Wirecard Bank (account 60757 EUR 36.3 million, account 59049 EUR 4.8 million), that on 29 December 2017 EUR 14,267,271 arrived from account 59049, and that a transaction slip for a cheque of EUR 2,997,988.82 dated 9 July 2015 named Wirecard Bank AG itself, not Al Alam, as the issuing client. Al Alam held several accounts at Wirecard Bank in Germany and used German-language cheque forms, which the report counts among signs of the partners' particular closeness to Wirecard."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-2018-payment","record":{"id":"c-tpa-rp-2018-payment","kind":"fact","text":"The special investigators report that in 2018, while the TPA business grew sharply, only one payment arrived from the partners, about EUR 15 million from PayEasy in the first quarter, against receivables from PayEasy including merchant cash advances of about EUR 278 million at 31 December 2018 (EUR 207 million a year earlier); the payment was booked as a lump sum without reference to particular invoices.","source_ids":["src-027"],"entity_ids":["wirecard","payeasy"],"qualification":"","response":"","outcome":""},"reading":"Fact: The special investigators report that in 2018, while the TPA business grew sharply, only one payment arrived from the partners, about EUR 15 million from PayEasy in the first quarter, against receivables from PayEasy including merchant cash advances of about EUR 278 million at 31 December 2018 (EUR 207 million a year earlier); the payment was booked as a lump sum without reference to particular invoices."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-margins","record":{"id":"c-tpa-rp-margins","kind":"attributed","text":"The special investigators note that the gross margin of Wirecard Bank AG's own acquiring business fell to 10% in 2018 while the TPA business showed margins of 43–56%, although Wirecard did less of the work there, and that Wirecard's explanation that the TPA business carried high risks is contradicted by the absence of any liability claims.","source_ids":["src-027"],"entity_ids":["wd-bank","wirecard"],"qualification":"Comparison and evaluation by the special investigators.","response":"","outcome":""},"reading":"Attributed: The special investigators note that the gross margin of Wirecard Bank AG's own acquiring business fell to 10% in 2018 while the TPA business showed margins of 43–56%, although Wirecard did less of the work there, and that Wirecard's explanation that the TPA business carried high risks is contradicted by the absence of any liability claims."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-payeasy-2014","record":{"id":"c-tpa-rp-payeasy-2014","kind":"fact","text":"At 31 December 2014 receivables from PayEasy Solutions Inc. stood at EUR 62.5 million, about 18% of group receivables; revenue with PayEasy in 2014 was EUR 75.8 million (about 13% of group revenue) and EBITDA EUR 31.4 million (about 14%), according to the special investigators.","source_ids":["src-027"],"entity_ids":["payeasy","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: At 31 December 2014 receivables from PayEasy Solutions Inc. stood at EUR 62.5 million, about 18% of group receivables; revenue with PayEasy in 2014 was EUR 75.8 million (about 13% of group revenue) and EBITDA EUR 31.4 million (about 14%), according to the special investigators."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-payeasy-existence","record":{"id":"c-tpa-rp-payeasy-existence","kind":"attributed","text":"EY's forensic team could not confirm the existence and location of PayEasy Solutions Inc. in March 2015: it was not registered with the Philippine Department of Trade and Industry, was no longer a tenant at its address in Makati, its website was down and its latest filing with the Philippine securities regulator was a general information sheet for 2011. A letter from PayEasy's financial controller of 13 March 2015 explaining the registration gaps went to Jan Marsalek, who forwarded it to Burkhard Ley, who passed it to EY; the special investigators found no check of these letters, and EY's forensic review ended without remarks before the audit opinion of 7 April 2015 despite warning signs, including two management board members personally obtaining the evidence.","source_ids":["src-027"],"entity_ids":["payeasy","ey","marsalek","ley","wirecard"],"qualification":"Facts from EY's working papers and evaluation by the special investigators; the final clarification of PayEasy's status is not documented in the working papers.","response":"","outcome":""},"reading":"Attributed: EY's forensic team could not confirm the existence and location of PayEasy Solutions Inc. in March 2015: it was not registered with the Philippine Department of Trade and Industry, was no longer a tenant at its address in Makati, its website was down and its latest filing with the Philippine securities regulator was a general information sheet for 2011. A letter from PayEasy's financial controller of 13 March 2015 explaining the registration gaps went to Jan Marsalek, who forwarded it to Burkhard Ley, who passed it to EY; the special investigators found no check of these letters, and EY's forensic review ended without remarks before the audit opinion of 7 April 2015 despite warning signs, including two management board members personally obtaining the evidence."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-payeasy-figures","record":{"id":"c-tpa-rp-payeasy-figures","kind":"attributed","text":"Instead of financial statements, EY received from PayEasy a letter of 26 March 2015 with a few figures for 2014; the special investigators calculate that PayEasy did about 57% of its 2014 business with Wirecard, or almost all of it if it also reported gross, and that Wirecard's 2014 revenue with PayEasy (EUR 75.8 million) exceeded PayEasy's own total revenue (EUR 72.2 million). PayEasy's reported revenue rose to EUR 666.1 million in 2018 with transaction volume of EUR 5,519.9 million and personnel costs of EUR 267,000, and its audited accounts (local auditor's opinion of 19 March 2019) were available to Wirecard's auditor only for 2018.","source_ids":["src-027"],"entity_ids":["payeasy","ey","wirecard"],"qualification":"Figures as given in documents in EY's files; the comparison and the conclusion that the gap cannot be explained are the special investigators'.","response":"","outcome":""},"reading":"Attributed: Instead of financial statements, EY received from PayEasy a letter of 26 March 2015 with a few figures for 2014; the special investigators calculate that PayEasy did about 57% of its 2014 business with Wirecard, or almost all of it if it also reported gross, and that Wirecard's 2014 revenue with PayEasy (EUR 75.8 million) exceeded PayEasy's own total revenue (EUR 72.2 million). PayEasy's reported revenue rose to EUR 666.1 million in 2018 with transaction volume of EUR 5,519.9 million and personnel costs of EUR 267,000, and its audited accounts (local auditor's opinion of 19 March 2019) were available to Wirecard's auditor only for 2018."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-payeasy-terms","record":{"id":"c-tpa-rp-payeasy-terms","kind":"attributed","text":"Under the agreements PayEasy received rates of 2.15–3% plus transaction and chargeback fees and Al Alam only 2%, yet PayEasy reported much lower profit (gross margin of 0.24% in 2017); the special investigators also found personnel costs of both partners extremely small for their turnover, and that since September 2016 two registrations of PayEasy Solutions Inc. existed with the same name but different numbers and addresses. PayEasy was registered on 8 August 2011 and Al Alam Solution Provider founded in 2011/2012, close to the start of the TPA business.","source_ids":["src-027"],"entity_ids":["payeasy","al-alam","wirecard"],"qualification":"Observations of the special investigators drawn from EY's compliance quick check and working papers.","response":"","outcome":""},"reading":"Attributed: Under the agreements PayEasy received rates of 2.15–3% plus transaction and chargeback fees and Al Alam only 2%, yet PayEasy reported much lower profit (gross margin of 0.24% in 2017); the special investigators also found personnel costs of both partners extremely small for their turnover, and that since September 2016 two registrations of PayEasy Solutions Inc. existed with the same name but different numbers and addresses. PayEasy was registered on 8 August 2011 and Al Alam Solution Provider founded in 2011/2012, close to the start of the TPA business."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-escalion","record":{"id":"c-tpa-rp-escalion","kind":"fact","text":"The special investigators report that PayEasy's main merchant, Escalion, accounted for EUR 1.238 billion in the fourth quarter of 2018, 90% of PayEasy's volume, and that on 20 February 2019 EY reconciled the volume only on totals together with Oliver Bellenhaus, without checking individual transactions. For the PayEasy merchant Helix Gaming International, Wirecard's payment system showed 23,033 transactions worth EUR 742,583.92 for October 2018, while a controlling export showed 286,921 transactions worth 6,304,544.47; such order-of-magnitude differences also appeared in other months and were not investigated by the auditor.","source_ids":["src-027"],"entity_ids":["payeasy","ey","bellenhaus","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: The special investigators report that PayEasy's main merchant, Escalion, accounted for EUR 1.238 billion in the fourth quarter of 2018, 90% of PayEasy's volume, and that on 20 February 2019 EY reconciled the volume only on totals together with Oliver Bellenhaus, without checking individual transactions. For the PayEasy merchant Helix Gaming International, Wirecard's payment system showed 23,033 transactions worth EUR 742,583.92 for October 2018, while a controlling export showed 286,921 transactions worth 6,304,544.47; such order-of-magnitude differences also appeared in other months and were not investigated by the auditor."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-alalam","record":{"id":"c-tpa-rp-alalam","kind":"attributed","text":"A credit report in EY's files showed revenue of about USD 3 million for Al Alam Solutions Provider FZ-LLC for 2016, far below the mid-three-digit million US dollar figures Al Alam reported for 2015–2018, and the registrant e-mail of Al Alam's website used a different domain. The special investigators found that EY had only preliminary estimates or forecasts from Al Alam's management for 2015–2018 and no actual accounts, that Al Alam's volumes for the first and second quarters were identical in 2016 and 2017 (EUR 866,491,337 and EUR 963,579,293), and that its gross margin rose from 20.6% (2015) to 51.0% (2018) while Wirecard Bank's acquiring margin fell; the auditor did not examine this.","source_ids":["src-027"],"entity_ids":["al-alam","ey","wd-bank","wirecard"],"qualification":"Findings of the special investigators in EY's audit files; Al Alam's own position is not in the record.","response":"","outcome":""},"reading":"Attributed: A credit report in EY's files showed revenue of about USD 3 million for Al Alam Solutions Provider FZ-LLC for 2016, far below the mid-three-digit million US dollar figures Al Alam reported for 2015–2018, and the registrant e-mail of Al Alam's website used a different domain. The special investigators found that EY had only preliminary estimates or forecasts from Al Alam's management for 2015–2018 and no actual accounts, that Al Alam's volumes for the first and second quarters were identical in 2016 and 2017 (EUR 866,491,337 and EUR 963,579,293), and that its gross margin rose from 20.6% (2015) to 51.0% (2018) while Wirecard Bank's acquiring margin fell; the auditor did not examine this."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-no-accounts","record":{"id":"c-tpa-rp-no-accounts","kind":"fact","text":"According to the special investigators, EY received no audited or other financial statements from the TPA partners for 2015–2017, only unverified summary figures; statements were obtained only for 2018 and only from PayEasy Solutions Inc. and Senjo Group Ltd.","source_ids":["src-027"],"entity_ids":["ey","payeasy","senjo","al-alam"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the special investigators, EY received no audited or other financial statements from the TPA partners for 2015–2017, only unverified summary figures; statements were obtained only for 2018 and only from PayEasy Solutions Inc. and Senjo Group Ltd."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-cqc","record":{"id":"c-tpa-rp-cqc","kind":"fact","text":"During the 2014 audit EY's internal forensic specialists ran compliance quick checks on Al Alam Solution Provider FZ-LLC, PayEasy Solutions Inc., Rising Sun Co. Ltd., Hamesh Ltd and Bonatal Trading Industries Ltd.","source_ids":["src-027"],"entity_ids":["ey","al-alam","payeasy","senjo","hamesh","bonatal"],"qualification":"","response":"","outcome":""},"reading":"Fact: During the 2014 audit EY's internal forensic specialists ran compliance quick checks on Al Alam Solution Provider FZ-LLC, PayEasy Solutions Inc., Rising Sun Co. Ltd., Hamesh Ltd and Bonatal Trading Industries Ltd."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-senjo","record":{"id":"c-tpa-rp-senjo","kind":"attributed","text":"EY's 2016 compliance check, as summarised by the special investigators, notes that leading managers of the TPA partner Senjo had earlier been business partners of Wirecard: they sold E-Creditplus Pte. Ltd. to Wirecard for EUR 12.8 million and later bought it back for a net EUR 0.1 million, which the short-seller Zatarra called roundtripping; a director of Senjo Payment Asia Pte. Ltd. had worked at Wirecard Asia Pte. Ltd.; and the secretary of Senjo Payments Asia Pte. Ltd., R. Shanmugaratnam, matched by name and document number the signatory of a trustee confirmation of 25 May 2016, which the investigators say could indicate a link between Senjo and the trustee and a conflict of interest.","source_ids":["src-027"],"entity_ids":["senjo","wirecard","wd-asia-pte","rajaratnam","citadelle"],"qualification":"The roundtripping label is the short-seller's; the possible link and conflict of interest are the special investigators' inference, not an established fact.","response":"","outcome":""},"reading":"Attributed: EY's 2016 compliance check, as summarised by the special investigators, notes that leading managers of the TPA partner Senjo had earlier been business partners of Wirecard: they sold E-Creditplus Pte. Ltd. to Wirecard for EUR 12.8 million and later bought it back for a net EUR 0.1 million, which the short-seller Zatarra called roundtripping; a director of Senjo Payment Asia Pte. Ltd. had worked at Wirecard Asia Pte. Ltd.; and the secretary of Senjo Payments Asia Pte. Ltd., R. Shanmugaratnam, matched by name and document number the signatory of a trustee confirmation of 25 May 2016, which the investigators say could indicate a link between Senjo and the trustee and a conflict of interest."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-senjo-email","record":{"id":"c-tpa-rp-senjo-email","kind":"fact","text":"Among the annexes to the insolvency administrator's TPA report for the Bundestag committee, the special investigators list an e-mail of 2 June 2015 from Jan Marsalek asking that Senjo be supported and remarking that this would not create a competitor.","source_ids":["src-027"],"entity_ids":["marsalek","senjo","jaffe","bundestag"],"qualification":"","response":"","outcome":""},"reading":"Fact: Among the annexes to the insolvency administrator's TPA report for the Bundestag committee, the special investigators list an e-mail of 2 June 2015 from Jan Marsalek asking that Senjo be supported and remarking that this would not create a competitor."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-kalixa","record":{"id":"c-tpa-rp-kalixa","kind":"fact","text":"The special investigators report that Senjo Group bought Kalixa Payments Group Pte. Ltd. as of 1 June 2017 for EUR 29.0 million, of which EUR 25.0 million was a loan from Wirecard Bank approved by the bank in May 2017 and by Wirecard's management and supervisory boards; Senjo was the only TPA partner whose creditworthiness was checked. Wirecard Bank's auditors considered Senjo only partly able to service debt and noticed inconsistent financial information in the 2018 audit, but the group auditor did not take this into account and recorded no signs of financial problems in its TPA monitoring.","source_ids":["src-027"],"entity_ids":["senjo","kalixa","wd-bank","wirecard","ey"],"qualification":"","response":"","outcome":""},"reading":"Fact: The special investigators report that Senjo Group bought Kalixa Payments Group Pte. Ltd. as of 1 June 2017 for EUR 29.0 million, of which EUR 25.0 million was a loan from Wirecard Bank approved by the bank in May 2017 and by Wirecard's management and supervisory boards; Senjo was the only TPA partner whose creditworthiness was checked. Wirecard Bank's auditors considered Senjo only partly able to service debt and noticed inconsistent financial information in the 2018 audit, but the group auditor did not take this into account and recorded no signs of financial problems in its TPA monitoring."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-marsalek-notes","record":{"id":"c-tpa-rp-marsalek-notes","kind":"attributed","text":"According to the special investigators, Wirecard gave the auditor no external documents (accounts, credit reports, register extracts, references) on the TPA partners' financial stability; instead the auditor received memos by Jan Marsalek (COO) explaining why the partners were chosen, and Wirecard had no formalised assessment of the partners. For receivables from other debtors that were not confirmed at the end of 2014, the auditor obtained internal memos from Marsalek, while Al Alam (EUR 18.1 million), PayEasy (EUR 62.5 million) and Rising Sun (EUR 47.8 million) confirmed their balances without the slightest deviation.","source_ids":["src-027"],"entity_ids":["wirecard","marsalek","al-alam","payeasy","senjo","ey"],"qualification":"Findings of the special investigators in EY's working papers.","response":"","outcome":""},"reading":"Attributed: According to the special investigators, Wirecard gave the auditor no external documents (accounts, credit reports, register extracts, references) on the TPA partners' financial stability; instead the auditor received memos by Jan Marsalek (COO) explaining why the partners were chosen, and Wirecard had no formalised assessment of the partners. For receivables from other debtors that were not confirmed at the end of 2014, the auditor obtained internal memos from Marsalek, while Al Alam (EUR 18.1 million), PayEasy (EUR 62.5 million) and Rising Sun (EUR 47.8 million) confirmed their balances without the slightest deviation."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-managers","record":{"id":"c-tpa-rp-managers","kind":"fact","text":"The special investigators found that in the 2015 audit documentation and simple reconciliations for the TPA business were provided by senior managers: Oliver Bellenhaus as managing director of CardSystems Middle East FZ-LLC, the head of Wirecard Sales International, Jan Marsalek as chief operating officer and Stephan von Erffa as executive vice president accounting; Marsalek personally joined the auditor's enquiries, and the auditor updated its understanding of the process by interviewing Bellenhaus and the head of Wirecard Sales International.","source_ids":["src-027"],"entity_ids":["bellenhaus","cardsystems-me","wd-sih","marsalek","von-erffa","wirecard","ey"],"qualification":"","response":"","outcome":""},"reading":"Fact: The special investigators found that in the 2015 audit documentation and simple reconciliations for the TPA business were provided by senior managers: Oliver Bellenhaus as managing director of CardSystems Middle East FZ-LLC, the head of Wirecard Sales International, Jan Marsalek as chief operating officer and Stephan von Erffa as executive vice president accounting; Marsalek personally joined the auditor's enquiries, and the auditor updated its understanding of the process by interviewing Bellenhaus and the head of Wirecard Sales International."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-citadelle","record":{"id":"c-tpa-rp-citadelle","kind":"fact","text":"After trust (escrow) accounts were set up in 2015, Citadelle Corporate Services Pte. Ltd. (Singapore) acted as trustee; according to the special investigators the trust agreement gave Wirecard no information rights such as monthly statements, bank balance confirmations or proof that the accounts had been opened, and EY requested balance confirmations from the trustee for 2015–2017.","source_ids":["src-027"],"entity_ids":["citadelle","wirecard","ey"],"qualification":"","response":"","outcome":""},"reading":"Fact: After trust (escrow) accounts were set up in 2015, Citadelle Corporate Services Pte. Ltd. (Singapore) acted as trustee; according to the special investigators the trust agreement gave Wirecard no information rights such as monthly statements, bank balance confirmations or proof that the accounts had been opened, and EY requested balance confirmations from the trustee for 2015–2017."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-confirmations-2016","record":{"id":"c-tpa-rp-confirmations-2016","kind":"attributed","text":"The special investigators list inconsistencies in the trustee confirmations for 2015–2016, which EY did not follow up: a confirmation named Wirecard Technologies GmbH as beneficiary of account 6508 4162 0001 although CardSystems Middle East FZ-LLC had concluded the trust agreement with Al Alam; Citadelle's e-mail addresses and contact names varied (Shan Rajartnam and R. Shanmugaratanam); on 25 May 2016 a balance of EUR 41,500,000 was confirmed on Senjo's account for Al Alam with Wirecard UK & Ireland as beneficiary; and at the end of 2016 Al Alam paid EUR 80,000,000 into an escrow account.","source_ids":["src-027"],"entity_ids":["citadelle","wd-tech","cardsystems-me","al-alam","rajaratnam","senjo","wd-uki","ey"],"qualification":"Findings of the special investigators in EY's working papers; whether the confirmations reflected real balances is addressed in later records.","response":"","outcome":""},"reading":"Attributed: The special investigators list inconsistencies in the trustee confirmations for 2015–2016, which EY did not follow up: a confirmation named Wirecard Technologies GmbH as beneficiary of account 6508 4162 0001 although CardSystems Middle East FZ-LLC had concluded the trust agreement with Al Alam; Citadelle's e-mail addresses and contact names varied (Shan Rajartnam and R. Shanmugaratanam); on 25 May 2016 a balance of EUR 41,500,000 was confirmed on Senjo's account for Al Alam with Wirecard UK & Ireland as beneficiary; and at the end of 2016 Al Alam paid EUR 80,000,000 into an escrow account."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-confirmations-pdf","record":{"id":"c-tpa-rp-confirmations-pdf","kind":"attributed","text":"EY's 2016 audit files contain two Citadelle confirmations dated 2 December 2016, one for EUR 97,533,053.84 at 30 November 2016 on account 6508 4162 0001 addressed to Wirecard UK & Ireland Ltd and one for EUR 84,009,703.83 at 22 November 2016 on account 6010 9797 5201 addressed to Cardsystems Middle East FZ LLC. According to the special investigators, the signature and seal were inserted electronically in both PDFs, and the stamp properties name the author \"Oliver\".","source_ids":["src-027"],"entity_ids":["citadelle","wd-uki","cardsystems-me","ey"],"qualification":"Technical findings of the special investigators on files in EY's working papers; the identity of the author named in the file properties is not established in the report.","response":"","outcome":""},"reading":"Attributed: EY's 2016 audit files contain two Citadelle confirmations dated 2 December 2016, one for EUR 97,533,053.84 at 30 November 2016 on account 6508 4162 0001 addressed to Wirecard UK & Ireland Ltd and one for EUR 84,009,703.83 at 22 November 2016 on account 6010 9797 5201 addressed to Cardsystems Middle East FZ LLC. According to the special investigators, the signature and seal were inserted electronically in both PDFs, and the stamp properties name the author \"Oliver\"."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-account-6010","record":{"id":"c-tpa-rp-account-6010","kind":"fact","text":"There is no trustee confirmation at 31 December 2016 for escrow account 6010 9797 5201, only one at 22 November 2016 showing EUR 84,009,703.83; from the end of 2017 the account was no longer used as a TPA escrow account, and EY's files contain no documents on the transfer of the funds, according to the special investigators.","source_ids":["src-027"],"entity_ids":["wirecard","ey"],"qualification":"","response":"","outcome":""},"reading":"Fact: There is no trustee confirmation at 31 December 2016 for escrow account 6010 9797 5201, only one at 22 November 2016 showing EUR 84,009,703.83; from the end of 2017 the account was no longer used as a TPA escrow account, and EY's files contain no documents on the transfer of the funds, according to the special investigators."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-2018-trustee","record":{"id":"c-tpa-rp-2018-trustee","kind":"attributed","text":"For the 2018 audit, the special investigators report, the trustee was still Citadelle; EY inspected bank statements during the trustee's visit to Aschheim on 26 March 2019 without receiving copies, and Citadelle's confirmation of 12 April 2019, received by e-mail on 11 April, named neither the account numbers nor the bank and carried a different stamp from earlier ones. The auditor did not test the plausibility of trust balances of about EUR 976 million at OCBC Bank in Singapore, sent no confirmation requests to merchants and did not test the transaction chain through the partners, so that confirmation of TPA revenue and cash rested only indirectly on confirmations from the partners and the trustee.","source_ids":["src-027"],"entity_ids":["citadelle","ey","ocbc","wirecard"],"qualification":"Findings and evaluation of the special investigators.","response":"","outcome":""},"reading":"Attributed: For the 2018 audit, the special investigators report, the trustee was still Citadelle; EY inspected bank statements during the trustee's visit to Aschheim on 26 March 2019 without receiving copies, and Citadelle's confirmation of 12 April 2019, received by e-mail on 11 April, named neither the account numbers nor the bank and carried a different stamp from earlier ones. The auditor did not test the plausibility of trust balances of about EUR 976 million at OCBC Bank in Singapore, sent no confirmation requests to merchants and did not test the transaction chain through the partners, so that confirmation of TPA revenue and cash rested only indirectly on confirmations from the partners and the trustee."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-2019-file","record":{"id":"c-tpa-rp-2019-file","kind":"fact","text":"According to the special investigators, EY's 2019 audit file very probably contains a balance confirmation from Banco de Oro (BDO Unibank) of 16 March 2020 and a confirmation and statement from Bank of the Philippine Islands of 17 March 2020 for 31 December 2019, addressed to EY; a management board decision of 20 February 2020 replacing the trustee Citadelle Corporate Services with M. K. Tolentino; EY's letter of 16 June 2020 to supervisory board chairman Thomas Eichelmann about possible irregularities; and EY's refusal of an audit opinion on the 2019 consolidated accounts.","source_ids":["src-027"],"entity_ids":["bdo","bpi","ey","wirecard","citadelle","tolentino","eichelmann"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the special investigators, EY's 2019 audit file very probably contains a balance confirmation from Banco de Oro (BDO Unibank) of 16 March 2020 and a confirmation and statement from Bank of the Philippine Islands of 17 March 2020 for 31 December 2019, addressed to EY; a management board decision of 20 February 2020 replacing the trustee Citadelle Corporate Services with M. K. Tolentino; EY's letter of 16 June 2020 to supervisory board chairman Thomas Eichelmann about possible irregularities; and EY's refusal of an audit opinion on the 2019 consolidated accounts."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-jaffe-report","record":{"id":"c-tpa-rp-jaffe-report","kind":"fact","text":"Insolvency administrator Dr. Michael Jaffé sent the Bundestag committee of inquiry a short statement on the existence and possible size of Wirecard AG's third-party acquiring business; its annexes, as listed by the special investigators, include a 2016 Citadelle confirmation with \"obviously forged signatures\".","source_ids":["src-027"],"entity_ids":["jaffe","wirecard","bundestag","citadelle"],"qualification":"","response":"","outcome":""},"reading":"Fact: Insolvency administrator Dr. Michael Jaffé sent the Bundestag committee of inquiry a short statement on the existence and possible size of Wirecard AG's third-party acquiring business; its annexes, as listed by the special investigators, include a 2016 Citadelle confirmation with \"obviously forged signatures\"."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-2018-contracts","record":{"id":"c-tpa-rp-2018-contracts","kind":"attributed","text":"With the switch to IFRS 15, Wirecard concluded new contracts with all TPA partners as of 1 January 2018: according to the special investigators' second addendum, CardSystems Middle East FZ LLC bought the e-payment platforms of Senjo Payment Asia (contract of 16 April 2018) and of Al Alam (contract of 30 July 2018), each retroactively to 1 January 2018 and each for EUR 6.5 million; the two contracts have identical technical specifications, the Al Alam contract names Senjo instead of Al Alam six times, and there is no sign that the systems were integrated into Wirecard. PayEasy's transactions were moved to Wirecard's \"Elastic Engine\" platform, a \"liability notice\" was introduced, and Wirecard could withdraw money from the trust accounts without the partners' consent.","source_ids":["src-027"],"entity_ids":["wirecard","cardsystems-me","senjo","al-alam","payeasy"],"qualification":"The special investigators conclude that gross accounting and treatment of trust funds as cash looked formally justified from 2018, but that EY's files contain no evidence that Wirecard actually controlled the business.","response":"","outcome":""},"reading":"Attributed: With the switch to IFRS 15, Wirecard concluded new contracts with all TPA partners as of 1 January 2018: according to the special investigators' second addendum, CardSystems Middle East FZ LLC bought the e-payment platforms of Senjo Payment Asia (contract of 16 April 2018) and of Al Alam (contract of 30 July 2018), each retroactively to 1 January 2018 and each for EUR 6.5 million; the two contracts have identical technical specifications, the Al Alam contract names Senjo instead of Al Alam six times, and there is no sign that the systems were integrated into Wirecard. PayEasy's transactions were moved to Wirecard's \"Elastic Engine\" platform, a \"liability notice\" was introduced, and Wirecard could withdraw money from the trust accounts without the partners' consent."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-rp-2018-tests","record":{"id":"c-tpa-rp-2018-tests","kind":"attributed","text":"In the 2018 audit EY could not perform its methodology's prescribed test of ten cash transactions at CardSystems Middle East because Wirecard's accounting could not trace TPA transactions individually. To test whether the TPA business existed it made five test purchases with Wirecard cards at the partners' merchants; on 16 February 2019 Oliver Bellenhaus, managing director of CardSystems, proposed websites for the purchases, and EY's files do not say how the merchants were chosen. The confirmation e-mail for one purchase came from an unrelated hosting address hours before the purchase recorded in the auditor's screenshots, and Bellenhaus supplied screenshots of a bitcoin purchase only on 8 April 2019.","source_ids":["src-027"],"entity_ids":["ey","cardsystems-me","bellenhaus","wirecard"],"qualification":"Findings of the special investigators, who note that the e-mail may have been altered.","response":"","outcome":""},"reading":"Attributed: In the 2018 audit EY could not perform its methodology's prescribed test of ten cash transactions at CardSystems Middle East because Wirecard's accounting could not trace TPA transactions individually. To test whether the TPA business existed it made five test purchases with Wirecard cards at the partners' merchants; on 16 February 2019 Oliver Bellenhaus, managing director of CardSystems, proposed websites for the purchases, and EY's files do not say how the merchants were chosen. The confirmation e-mail for one purchase came from an unrelated hosting address hours before the purchase recorded in the auditor's screenshots, and Bellenhaus supplied screenshots of a bitcoin purchase only on 8 April 2019."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-kpmg-esma","record":{"id":"c-tpa-kpmg-esma","kind":"fact","text":"ESMA, citing KPMG's special investigation report of 27 April 2020, states that KPMG could confirm only payments of EUR 85 million by two TPA partners to accounts of Wirecard Technologies and Cardsystems Middle East at Wirecard Bank, while Wirecard could not produce trustee statements to verify a final balance of about EUR 1 billion; unsecured credit lines of EUR 250 million ran in the opposite direction, and the subsidiaries had undertaken to compensate the TPA partners for losses, secured by withholdings or escrow accounts at the trustee.","source_ids":["src-087"],"entity_ids":["wirecard","kpmg","esma","wd-tech","cardsystems-me","wd-bank"],"qualification":"","response":"","outcome":""},"reading":"Fact: ESMA, citing KPMG's special investigation report of 27 April 2020, states that KPMG could confirm only payments of EUR 85 million by two TPA partners to accounts of Wirecard Technologies and Cardsystems Middle East at Wirecard Bank, while Wirecard could not produce trustee statements to verify a final balance of about EUR 1 billion; unsecured credit lines of EUR 250 million ran in the opposite direction, and the subsidiaries had undertaken to compensate the TPA partners for losses, secured by withholdings or escrow accounts at the trustee."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-kpmg-trustee1","record":{"id":"c-tpa-kpmg-trustee1","kind":"fact","text":"Extracts of the KPMG report quoted by ESMA state that statements and bank confirmations from the bank managing the trust accounts were not provided to KPMG because \"Trustee 1\" had ended its relationships with the Wirecard companies and did not answer enquiries.","source_ids":["src-087"],"entity_ids":["kpmg","esma","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Extracts of the KPMG report quoted by ESMA state that statements and bank confirmations from the bank managing the trust accounts were not provided to KPMG because \"Trustee 1\" had ended its relationships with the Wirecard companies and did not answer enquiries."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-esma-ft-partners","record":{"id":"c-tpa-esma-ft-partners","kind":"attributed","text":"ESMA, drawing on Financial Times reporting, names Al Alam Solution Provider FZ LLC (Dubai), Senjo Payment Asia Pte Ltd (Singapore) and PayEasy Solution Inc. (Philippines) as the three largest TPA partners in 2018, with TPA revenue reaching the group through Cardsystems Middle East FZ LLC, Wirecard UK & Ireland Ltd. and Wirecard Technologies GmbH; Wirecard itself had stated that neither Wirecard Bank AG nor other group companies outside the EU held their own acquiring licence in the third countries concerned.","source_ids":["src-087"],"entity_ids":["al-alam","senjo","payeasy","cardsystems-me","wd-uki","wd-tech","wd-bank","wirecard","esma","ft"],"qualification":"Attribution to the newspaper as summarised in ESMA's report.","response":"","outcome":""},"reading":"Attributed: ESMA, drawing on Financial Times reporting, names Al Alam Solution Provider FZ LLC (Dubai), Senjo Payment Asia Pte Ltd (Singapore) and PayEasy Solution Inc. (Philippines) as the three largest TPA partners in 2018, with TPA revenue reaching the group through Cardsystems Middle East FZ LLC, Wirecard UK & Ireland Ltd. and Wirecard Technologies GmbH; Wirecard itself had stated that neither Wirecard Bank AG nor other group companies outside the EU held their own acquiring licence in the third countries concerned."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-ft-2019","record":{"id":"c-tpa-ft-2019","kind":"attributed","text":"ESMA summarises Financial Times articles of 29 March, 24 April and 20 May 2019 as reporting that half of Wirecard's worldwide revenue and almost all its profit came from three opaque partners, which in 2016 produced 95% of EBITDA and more than half of revenue, that profits were channelled mainly through CardSystems Middle East in Dubai, and that the accounts disclosed none of this. Later reporting from October 2019 said that in 2016–2017 Wirecard had routed billions of euros of payments for 34 clients through Al Alam, eight of which had ceased trading and 15 of which told the newspaper they had never heard of Al Alam, and on 9 December 2019 that EUR 334 million linked to Al Alam and held on trust accounts in 2017 had been wrongly classified as cash.","source_ids":["src-087","src-025"],"entity_ids":["wirecard","cardsystems-me","al-alam","esma","ft"],"qualification":"Newspaper reporting as summarised by ESMA; Wirecard systematically rejected such allegations at the time.","response":"","outcome":"On 22 June 2020 Wirecard stated that there was a prevailing likelihood that the trust account balances of EUR 1.9 billion did not exist.","adverse_subject_ids":["wirecard"]},"reading":"Attributed: ESMA summarises Financial Times articles of 29 March, 24 April and 20 May 2019 as reporting that half of Wirecard's worldwide revenue and almost all its profit came from three opaque partners, which in 2016 produced 95% of EBITDA and more than half of revenue, that profits were channelled mainly through CardSystems Middle East in Dubai, and that the accounts disclosed none of this. Later reporting from October 2019 said that in 2016–2017 Wirecard had routed billions of euros of payments for 34 clients through Al Alam, eight of which had ceased trading and 15 of which told the newspaper they had never heard of Al Alam, and on 9 December 2019 that EUR 334 million linked to Al Alam and held on trust accounts in 2017 had been wrongly classified as cash."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-freq-balances","record":{"id":"c-tpa-freq-balances","kind":"fact","text":"Figures from the financial reporting enforcement panel (FREP) in ESMA's report show trust account balances of EUR 849 million at 30 June 2018 and EUR 1.9 billion at 31 December 2019, which could not be verified and were most likely inaccessible; revenue with questionable TPA partners in the first half of 2018 was about EUR 460 million (51% of EUR 898 million), with gross profit of about EUR 250 million against EBITDA of EUR 245 million.","source_ids":["src-087"],"entity_ids":["wirecard","dpr","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: Figures from the financial reporting enforcement panel (FREP) in ESMA's report show trust account balances of EUR 849 million at 30 June 2018 and EUR 1.9 billion at 31 December 2019, which could not be verified and were most likely inaccessible; revenue with questionable TPA partners in the first half of 2018 was about EUR 460 million (51% of EUR 898 million), with gross profit of about EUR 250 million against EBITDA of EUR 245 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-2014-deposits","record":{"id":"c-tpa-2014-deposits","kind":"fact","text":"ESMA notes that Wirecard's 2014 accounts showed acquiring deposits at Wirecard Bank of EUR 240 million as a separate item, whereas the 2015 accounts no longer showed them separately.","source_ids":["src-087"],"entity_ids":["wirecard","wd-bank","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: ESMA notes that Wirecard's 2014 accounts showed acquiring deposits at Wirecard Bank of EUR 240 million as a separate item, whereas the 2015 accounts no longer showed them separately."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-adhoc-2020-06-18","record":{"id":"c-tpa-adhoc-2020-06-18","kind":"fact","text":"In an ad hoc announcement of 18 June 2020 Wirecard AG stated that its auditor Ernst & Young had informed it that sufficient audit evidence for cash balances on trust accounts of EUR 1.9 billion, about a quarter of the consolidated balance sheet total, could not be obtained, that there were indications that the trustee or the banks keeping the trust accounts had presented false balance confirmations to deceive the auditor, and that publication of the 2019 accounts was postponed.","source_ids":["src-024"],"entity_ids":["wirecard","ey"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["wirecard"]},"reading":"Fact: In an ad hoc announcement of 18 June 2020 Wirecard AG stated that its auditor Ernst & Young had informed it that sufficient audit evidence for cash balances on trust accounts of EUR 1.9 billion, about a quarter of the consolidated balance sheet total, could not be obtained, that there were indications that the trustee or the banks keeping the trust accounts had presented false balance confirmations to deceive the auditor, and that publication of the 2019 accounts was postponed."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-ey-informs","record":{"id":"c-tpa-ey-informs","kind":"fact","text":"According to ESMA's chronology, EY informed Wirecard on 16 June 2020 that the banks said to hold the accounts had stated that Wirecard had presented forged balance confirmations for trust accounts of EUR 1.9 billion in the 2019 audit; the same day EY informed BaFin, which says KPMG's report had until then contained only red flags without a finding of fraud, and BaFin notified the public prosecutor on 18 June 2020.","source_ids":["src-087"],"entity_ids":["ey","wirecard","bafin","esma","kpmg"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to ESMA's chronology, EY informed Wirecard on 16 June 2020 that the banks said to hold the accounts had stated that Wirecard had presented forged balance confirmations for trust accounts of EUR 1.9 billion in the 2019 audit; the same day EY informed BaFin, which says KPMG's report had until then contained only red flags without a finding of fraud, and BaFin notified the public prosecutor on 18 June 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-2020-06-22","record":{"id":"c-tpa-2020-06-22","kind":"fact","text":"On 22 June 2020 Wirecard announced that there was a prevailing likelihood that the bank balances on trust accounts of EUR 1.9 billion did not exist; ESMA records that Wirecard said the EUR 1.9 billion supposedly held on escrow accounts in the Philippines did not exist and that the auditors had not completed their opinion by the Transparency Directive deadline, and that the company filed for insolvency a week later. A European Parliament briefing notes that on 3 May 2020 Wirecard had said the KPMG report had not confirmed any of the allegations.","source_ids":["src-025","src-087"],"entity_ids":["wirecard","esma","europarl","kpmg"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["wirecard"]},"reading":"Fact: On 22 June 2020 Wirecard announced that there was a prevailing likelihood that the bank balances on trust accounts of EUR 1.9 billion did not exist; ESMA records that Wirecard said the EUR 1.9 billion supposedly held on escrow accounts in the Philippines did not exist and that the auditors had not completed their opinion by the Transparency Directive deadline, and that the company filed for insolvency a week later. A European Parliament briefing notes that on 3 May 2020 Wirecard had said the KPMG report had not confirmed any of the allegations."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-philippines","record":{"id":"c-tpa-philippines","kind":"attributed","text":"On 21 June 2020 the governor of the Philippine central bank, Benjamin Diokno, said initial information showed that the missing Wirecard funds (put at US$2.1 billion) had not entered the Philippine financial system and that BDO Unibank and Bank of the Philippine Islands had suffered no losses, their names having been used in an attempt to cover the perpetrators' tracks.","source_ids":["src-031"],"entity_ids":["wirecard","bdo","bpi"],"qualification":"Statements of the central bank governor and the two banks as reported in the press; no court finding.","response":"Both banks stated that Wirecard was not their client and that they had no business relationship with it.","outcome":""},"reading":"Attributed: On 21 June 2020 the governor of the Philippine central bank, Benjamin Diokno, said initial information showed that the missing Wirecard funds (put at US$2.1 billion) had not entered the Philippine financial system and that BDO Unibank and Bank of the Philippine Islands had suffered no losses, their names having been used in an attempt to cover the perpetrators' tracks."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-ocbc","record":{"id":"c-tpa-ocbc","kind":"attributed","text":"A European Parliament briefing states that the key question of KPMG's special audit was whether EUR 1.9 billion supposedly held in an escrow account at OCBC Bank in Singapore existed, and that KPMG's report did not clarify all questions.","source_ids":["src-025","src-067"],"entity_ids":["ocbc","kpmg","europarl","wirecard","jaffe"],"qualification":"The OCBC statement is known from press reporting of the administrator's information, not from a document of the bank.","response":"According to a later press report citing a newspaper, OCBC told Wirecard's insolvency administrator that it had never held significant sums on behalf of the trustee and that some of the accounts had never existed.","outcome":"On 22 June 2020 Wirecard stated that there was a prevailing likelihood that the trust account balances of EUR 1.9 billion did not exist."},"reading":"Attributed: A European Parliament briefing states that the key question of KPMG's special audit was whether EUR 1.9 billion supposedly held in an escrow account at OCBC Bank in Singapore existed, and that KPMG's report did not clarify all questions."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-bka","record":{"id":"c-tpa-bka","kind":"attributed","text":"According to the Munich I public prosecutor's investigation as summarised in the BKA wanted notice, Jan Marsalek and Dr. Markus Braun inflated Wirecard AG's balance sheet total and revenue from no later than 2015, including fictitious revenue from payment transactions with so-called third-party acquirers; in the 2019 audit the auditor found that bank confirmations of trust accounts were forged or not genuine, and assets of EUR 1.9 billion, a quarter of the balance sheet total, did not exist.","source_ids":["src-003"],"entity_ids":["marsalek","braun","wirecard","bka","sta-muenchen"],"qualification":"Suspicion stated in a wanted notice; Braun denies the charges in the pending trial and Marsalek has not been tried.","response":"","outcome":"","adverse_subject_ids":["marsalek"]},"reading":"Attributed: According to the Munich I public prosecutor's investigation as summarised in the BKA wanted notice, Jan Marsalek and Dr. Markus Braun inflated Wirecard AG's balance sheet total and revenue from no later than 2015, including fictitious revenue from payment transactions with so-called third-party acquirers; in the 2019 audit the auditor found that bank confirmations of trust accounts were forged or not genuine, and assets of EUR 1.9 billion, a quarter of the balance sheet total, did not exist."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-cardsystems-unaudited","record":{"id":"c-tpa-cardsystems-unaudited","kind":"fact","text":"The 2019 bond prospectus states that CardSystems Middle East FZ-LLC's annual accounts for 2017 and 2018 were not audited and that the company had not appointed its own auditor.","source_ids":["src-012"],"entity_ids":["cardsystems-me"],"qualification":"","response":"","outcome":""},"reading":"Fact: The 2019 bond prospectus states that CardSystems Middle East FZ-LLC's annual accounts for 2017 and 2018 were not audited and that the company had not appointed its own auditor."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-tpa-alalam-liquidation","record":{"id":"c-tpa-alalam-liquidation","kind":"fact","text":"ESMA's chronology records that Wirecard's Dubai TPA partner Al Alam went into liquidation on 15 May 2020; on 18 May 2020 BaFin told the auditor oversight body about the restructuring of Wirecard's Dubai subsidiary and of Al Alam, and from that date BaFin's market-abuse team investigated whether the liquidation of CardSystems Middle East FZ-LLC and Al Alam Solutions FZ LLC was inside information Wirecard should have disclosed; BaFin received documents on Al Alam from a third-country regulator on 22 September 2020, and the investigation was not finished when ESMA reported.","source_ids":["src-087"],"entity_ids":["al-alam","cardsystems-me","wirecard","bafin","apas","esma"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["al-alam"]},"reading":"Fact: ESMA's chronology records that Wirecard's Dubai TPA partner Al Alam went into liquidation on 15 May 2020; on 18 May 2020 BaFin told the auditor oversight body about the restructuring of Wirecard's Dubai subsidiary and of Al Alam, and from that date BaFin's market-abuse team investigated whether the liquidation of CardSystems Middle East FZ-LLC and Al Alam Solutions FZ LLC was inside information Wirecard should have disclosed; BaFin received documents on Al Alam from a third-country regulator on 22 September 2020, and the investigation was not finished when ESMA reported."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-2010-joint","record":{"id":"c-aud-2010-joint","kind":"fact","text":"RP Richter GmbH Wirtschaftsprüfungsgesellschaft and Ernst & Young GmbH were appointed by the shareholders as joint auditors of Wirecard AG and the group for 2010; they jointly audited the 2010 individual and consolidated accounts and issued an unqualified opinion, and their fees for 2010 were EUR 455,000 (Ernst & Young) and EUR 481,000 (RP Richter).","source_ids":["src-023"],"entity_ids":["wirecard","rp-richter","ey"],"qualification":"","response":"","outcome":""},"reading":"Fact: RP Richter GmbH Wirtschaftsprüfungsgesellschaft and Ernst & Young GmbH were appointed by the shareholders as joint auditors of Wirecard AG and the group for 2010; they jointly audited the 2010 individual and consolidated accounts and issued an unqualified opinion, and their fees for 2010 were EUR 455,000 (Ernst & Young) and EUR 481,000 (RP Richter)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-ey-tenure","record":{"id":"c-aud-ey-tenure","kind":"fact","text":"Wirecard's 2018 annual report states that Ernst & Young GmbH Wirtschaftsprüfungsgesellschaft had audited Wirecard jointly with RP Richter GmbH from the 2009 financial year and alone from 2011, and EY's 2018 opinion states that it had served as group auditor without interruption since 2009; it was elected by the shareholders' meeting of 21 June 2018 and engaged by the supervisory board on 25 June 2018.","source_ids":["src-005"],"entity_ids":["wirecard","ey","rp-richter"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's 2018 annual report states that Ernst & Young GmbH Wirtschaftsprüfungsgesellschaft had audited Wirecard jointly with RP Richter GmbH from the 2009 financial year and alone from 2011, and EY's 2018 opinion states that it had served as group auditor without interruption since 2009; it was elected by the shareholders' meeting of 21 June 2018 and engaged by the supervisory board on 25 June 2018."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-2008-mandate","record":{"id":"c-aud-2008-mandate","kind":"fact","text":"A European Parliament briefing notes that Ernst & Young had itself been tasked with a special investigation into allegations of accounting manipulation at Wirecard, a mandate that enabled it to replace Wirecard's former external auditor in 2010; the briefing tabulates the auditor as RP Richter and Ernst & Young for 2010 and Ernst & Young, with unqualified opinions, for 2011–2018. The briefing also reproduces a company statement that the investor protection association Schutzgemeinschaft der Kapitalanleger e.V. (SdK) had sued in the Munich regional court to challenge the 2008 annual general meeting's discharge of the management and supervisory boards and to have the 2007 annual accounts declared void, citing alleged deficiencies; in autumn 2008 the supervisory board had Ernst & Young prepare an expert opinion, which saw no need for corrections.","source_ids":["src-025"],"entity_ids":["ey","wirecard","europarl","rp-richter","sdk"],"qualification":"The SdK action is described in the company's own words as reproduced in the briefing; its outcome is not in the record.","response":"","outcome":""},"reading":"Fact: A European Parliament briefing notes that Ernst & Young had itself been tasked with a special investigation into allegations of accounting manipulation at Wirecard, a mandate that enabled it to replace Wirecard's former external auditor in 2010; the briefing tabulates the auditor as RP Richter and Ernst & Young for 2010 and Ernst & Young, with unqualified opinions, for 2011–2018. The briefing also reproduces a company statement that the investor protection association Schutzgemeinschaft der Kapitalanleger e.V. (SdK) had sued in the Munich regional court to challenge the 2008 annual general meeting's discharge of the management and supervisory boards and to have the 2007 annual accounts declared void, citing alleged deficiencies; in autumn 2008 the supervisory board had Ernst & Young prepare an expert opinion, which saw no need for corrections."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-opinions-2011-2016","record":{"id":"c-aud-opinions-2011-2016","kind":"fact","text":"Ernst & Young issued unqualified opinions on Wirecard AG's accounts for 2011, signed in Munich on 16 April 2012, and for 2016, which the supervisory board approved on 5 April 2017; for 2012 the supervisory board proposed it to the shareholders' meeting as auditor again.","source_ids":["src-010","src-032","src-050"],"entity_ids":["ey","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: Ernst & Young issued unqualified opinions on Wirecard AG's accounts for 2011, signed in Munich on 16 April 2012, and for 2016, which the supervisory board approved on 5 April 2017; for 2012 the supervisory board proposed it to the shareholders' meeting as auditor again."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-unqualified-2009-2018","record":{"id":"c-aud-unqualified-2009-2018","kind":"fact","text":"The German Finance Ministry's report to the Bundestag finance committee of July 2020 states that Wirecard AG and the group presented accounts for each financial year from 2009 to 2018 with EY's unqualified audit opinion and that none of the audits led to objections; the 2018 opinion contained a discussion of the Singapore whistleblower allegations.","source_ids":["src-069"],"entity_ids":["wirecard","ey","bmf"],"qualification":"","response":"","outcome":""},"reading":"Fact: The German Finance Ministry's report to the Bundestag finance committee of July 2020 states that Wirecard AG and the group presented accounts for each financial year from 2009 to 2018 with EY's unqualified audit opinion and that none of the audits led to objections; the 2018 opinion contained a discussion of the Singapore whistleblower allegations."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-2018-signatories","record":{"id":"c-aud-2018-signatories","kind":"fact","text":"EY's opinion on the 2018 consolidated accounts was signed by Martin Dahmen, who had first signed for 2016 and was the responsible auditor from 2018, and by Andreas Budde; EY's fees were EUR 2.3 million for 2018 (EUR 2.1 million for the audit) and EUR 2.2 million for 2017.","source_ids":["src-005"],"entity_ids":["ey","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: EY's opinion on the 2018 consolidated accounts was signed by Martin Dahmen, who had first signed for 2016 and was the responsible auditor from 2018, and by Andreas Budde; EY's fees were EUR 2.3 million for 2018 (EUR 2.1 million for the audit) and EUR 2.2 million for 2017."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-2018-kam","record":{"id":"c-aud-2018-kam","kind":"fact","text":"EY named the valuation of receivables and the recognition of revenue from acquiring partners as a key audit matter for 2018, explaining that the receivables arose from fees and commissions on transactions processed through the partners and from prefinancing of merchant payouts, and that Wirecard was treated as principal under IFRS 15 for most of them, so that revenue was shown gross. EY states that it obtained confirmation letters from the acquiring partners on the receivables and on chargebacks and fines, traced payments received from them and reconciled their settlements with transaction data, and had no objections.","source_ids":["src-005"],"entity_ids":["ey","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: EY named the valuation of receivables and the recognition of revenue from acquiring partners as a key audit matter for 2018, explaining that the receivables arose from fees and commissions on transactions processed through the partners and from prefinancing of merchant payouts, and that Wirecard was treated as principal under IFRS 15 for most of them, so that revenue was shown gross. EY states that it obtained confirmation letters from the acquiring partners on the receivables and on chargebacks and fines, traced payments received from them and reconciled their settlements with transaction data, and had no objections."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-2018-emphasis","record":{"id":"c-aud-2018-emphasis","kind":"fact","text":"EY's 2018 opinion contains an emphasis-of-matter paragraph on the accounting treatment of allegations by a whistleblower in Singapore and of claims for damages against Wirecard AG over allegedly incorrect or late disclosures; EY states that it compared the findings with work by independent third parties and the internal compliance department, interviewed managers, suppliers, customers and lawyers with its own forensic specialists, and had no objections.","source_ids":["src-005"],"entity_ids":["ey","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: EY's 2018 opinion contains an emphasis-of-matter paragraph on the accounting treatment of allegations by a whistleblower in Singapore and of claims for damages against Wirecard AG over allegedly incorrect or late disclosures; EY states that it compared the findings with work by independent third parties and the internal compliance department, interviewed managers, suppliers, customers and lawyers with its own forensic specialists, and had no objections."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-materiality","record":{"id":"c-aud-materiality","kind":"fact","text":"According to FREP information in ESMA's report, Wirecard's auditor set its audit materiality limit at EUR 20 million for 2018 and EUR 28.7 million for 2019.","source_ids":["src-087"],"entity_ids":["ey","wirecard","dpr","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to FREP information in ESMA's report, Wirecard's auditor set its audit materiality limit at EUR 20 million for 2018 and EUR 28.7 million for 2019."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-2019-refusal","record":{"id":"c-aud-2019-refusal","kind":"fact","text":"The Federal Court of Justice records that Wirecard's auditor since 2009, which also audited Wirecard Technologies GmbH from 2014 to 2019, issued unqualified opinions on both companies' accounts for 2014–2018 and refused an opinion for 2019; Wirecard Technologies GmbH filed for insolvency on 1 July 2020.","source_ids":["src-057"],"entity_ids":["ey","wirecard","wd-tech","bgh"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Federal Court of Justice records that Wirecard's auditor since 2009, which also audited Wirecard Technologies GmbH from 2014 to 2019, issued unqualified opinions on both companies' accounts for 2014–2018 and refused an opinion for 2019; Wirecard Technologies GmbH filed for insolvency on 1 July 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-rp-concurrence","record":{"id":"c-aud-rp-concurrence","kind":"fact","text":"The special investigators found that EY had Burkhard Ley (chief financial officer) and Stephan von Erffa (executive vice president accounting) confirm by signature its understanding of Wirecard's role in the TPA business in a \"concurrence memorandum\" of 3 March 2016. The memorandum was prepared by an EY senior manager and approved the same day by an EY partner, and the working papers contain no contracts between the partners and the merchants or banks that would support the arrangement management described.","source_ids":["src-027"],"entity_ids":["ey","ley","von-erffa","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: The special investigators found that EY had Burkhard Ley (chief financial officer) and Stephan von Erffa (executive vice president accounting) confirm by signature its understanding of Wirecard's role in the TPA business in a \"concurrence memorandum\" of 3 March 2016. The memorandum was prepared by an EY senior manager and approved the same day by an EY partner, and the working papers contain no contracts between the partners and the merchants or banks that would support the arrangement management described."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-rp-concurrence-signers","record":{"id":"c-aud-rp-concurrence-signers","kind":"attributed","text":"According to the special investigators, the concurrence memorandum was signed by ten EY auditors including the quality-control partner, and EY's memorandum recorded that no receivable from the third-party acquirers Al Alam, PayEasy and Rising Sun had gone unpaid in 2011–2013 and that management saw no liability risks in 2014; the auditor did not consider whether the extensive collateral that Wirecard, as intermediary, gave the partners was usual in the market.","source_ids":["src-027"],"entity_ids":["ey","al-alam","payeasy","senjo","wirecard"],"qualification":"Findings of the special investigators in EY's working papers.","response":"","outcome":""},"reading":"Attributed: According to the special investigators, the concurrence memorandum was signed by ten EY auditors including the quality-control partner, and EY's memorandum recorded that no receivable from the third-party acquirers Al Alam, PayEasy and Rising Sun had gone unpaid in 2011–2013 and that management saw no liability risks in 2014; the auditor did not consider whether the extensive collateral that Wirecard, as intermediary, gave the partners was usual in the market."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-rp-escrow-cash","record":{"id":"c-aud-rp-escrow-cash","kind":"attributed","text":"EY's 2015 working papers first classified the escrow accounts as other financial assets (restricted cash) and then, in a memorandum, reclassified them as cash on the argument that Wirecard could replace them with a bank guarantee obtainable within three months with the partners' agreement; the special investigators found no evidence in the papers that such a guarantee existed or could be obtained.","source_ids":["src-027"],"entity_ids":["ey","wirecard"],"qualification":"Finding of the special investigators.","response":"","outcome":""},"reading":"Attributed: EY's 2015 working papers first classified the escrow accounts as other financial assets (restricted cash) and then, in a memorandum, reclassified them as cash on the argument that Wirecard could replace them with a bank guarantee obtainable within three months with the partners' agreement; the special investigators found no evidence in the papers that such a guarantee existed or could be obtained."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-rp-fraud-risk","record":{"id":"c-aud-rp-fraud-risk","kind":"attributed","text":"In the 2015–2016 audits EY listed external fraud risk factors such as capital-market pressure, share-price-linked management pay, EBIT covenants and money laundering at Wirecard Bank, but according to the special investigators did not include the standard risk of management override and documented no analysis of fraud indicators under German auditing standard IDW PS 210; nor did it assess in 2014–2016 whether the TPA partners were service providers for outsourced parts of Wirecard's accounting whose internal controls needed testing, although it obtained such controls reports for Wirecard Bank's provider SIX Payment Services.","source_ids":["src-027"],"entity_ids":["ey","wd-bank","six","wirecard"],"qualification":"Evaluation by the special investigators.","response":"","outcome":""},"reading":"Attributed: In the 2015–2016 audits EY listed external fraud risk factors such as capital-market pressure, share-price-linked management pay, EBIT covenants and money laundering at Wirecard Bank, but according to the special investigators did not include the standard risk of management override and documented no analysis of fraud indicators under German auditing standard IDW PS 210; nor did it assess in 2014–2016 whether the TPA partners were service providers for outsourced parts of Wirecard's accounting whose internal controls needed testing, although it obtained such controls reports for Wirecard Bank's provider SIX Payment Services."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-rp-receivables","record":{"id":"c-aud-rp-receivables","kind":"attributed","text":"Overdue trade receivables of the group stood at EUR 55.3 million at the end of 2016 (EUR 61.4 million a year earlier) before allowances, against total trade receivables of about EUR 190 million after allowances; the special investigators note that the ageing analysis required by IFRS 7.37a was not disclosed in the 2016 notes and EY considered the omission immaterial.","source_ids":["src-027"],"entity_ids":["wirecard","ey"],"qualification":"The disclosure point is the special investigators' evaluation.","response":"","outcome":""},"reading":"Attributed: Overdue trade receivables of the group stood at EUR 55.3 million at the end of 2016 (EUR 61.4 million a year earlier) before allowances, against total trade receivables of about EUR 190 million after allowances; the special investigators note that the ageing analysis required by IFRS 7.37a was not disclosed in the 2016 notes and EY considered the omission immaterial."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-rp-2015-report","record":{"id":"c-aud-rp-2015-report","kind":"attributed","text":"The special investigators consider that the TPA business bore the features of a measure designed to shape the balance sheet in the sense of § 321(2) of the German Commercial Code, but that EY's long-form audit report on the 2015 consolidated accounts contains no explicit section on it, only partial descriptions in the valuation section, a remark on the high volume of unsecured receivables from third-party acquirers and Wirecard's intention to monitor them more closely.","source_ids":["src-027"],"entity_ids":["ey","wirecard"],"qualification":"Evaluation by the special investigators; EY's position on it is not in the record.","response":"","outcome":""},"reading":"Attributed: The special investigators consider that the TPA business bore the features of a measure designed to shape the balance sheet in the sense of § 321(2) of the German Commercial Code, but that EY's long-form audit report on the 2015 consolidated accounts contains no explicit section on it, only partial descriptions in the valuation section, a remark on the high volume of unsecured receivables from third-party acquirers and Wirecard's intention to monitor them more closely."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-rp-2018-audit","record":{"id":"c-aud-rp-2018-audit","kind":"fact","text":"According to the special investigators, Wirecard had known since March–April 2018 of the whistleblower information that the Financial Times published on 30 January 2019 and engaged Rajah & Tann Singapore LLP, then Fieldfisher LLP, which brought in Control Risks Group Ltd. From February 2019 EY's forensic department joined the 2018 audit; it identified more than 20 issues from the allegations and kept a file \"Wirecard AG Project Tiger 2018\" of more than 1,100 documents, which the investigators did not analyse in depth for lack of time.","source_ids":["src-027"],"entity_ids":["wirecard","rajah-tann","fieldfisher","control-risks","ey","ft"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the special investigators, Wirecard had known since March–April 2018 of the whistleblower information that the Financial Times published on 30 January 2019 and engaged Rajah & Tann Singapore LLP, then Fieldfisher LLP, which brought in Control Risks Group Ltd. From February 2019 EY's forensic department joined the 2018 audit; it identified more than 20 issues from the allegations and kept a file \"Wirecard AG Project Tiger 2018\" of more than 1,100 documents, which the investigators did not analyse in depth for lack of time."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-rp-2018-meeting","record":{"id":"c-aud-rp-2018-meeting","kind":"fact","text":"The significance of the emphasis of matter in the 2018 opinion was not discussed with the supervisory board and management board, according to the special investigators; the board meeting to approve the accounts on 24 April 2019 was interrupted at 6 p.m. because of a new Financial Times article, which the auditor discussed with the supervisory board's lawyers, the supervisory board and CEO Dr. Markus Braun before concluding that it contained no new information changing the opinion.","source_ids":["src-027"],"entity_ids":["ey","wirecard","braun","ft"],"qualification":"","response":"","outcome":""},"reading":"Fact: The significance of the emphasis of matter in the 2018 opinion was not discussed with the supervisory board and management board, according to the special investigators; the board meeting to approve the accounts on 24 April 2019 was interrupted at 6 p.m. because of a new Financial Times article, which the auditor discussed with the supervisory board's lawyers, the supervisory board and CEO Dr. Markus Braun before concluding that it contained no new information changing the opinion."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-rp-conclusion","record":{"id":"c-aud-rp-conclusion","kind":"attributed","text":"The special investigators concluded on 16 April 2021 that there were indications that EY had not fully applied the IDW standards in planning and performing the audit, that a systematic analysis of fraud indicators could have led to greater professional scepticism and further procedures on the TPA business, and that the audit evidence often consisted not of third-party confirmations but of internal documents and oral statements by the management board; their report gives no overall assessment of whether the audit was properly performed.","source_ids":["src-027","src-025","src-030","src-057"],"entity_ids":["ey","wirecard","bundestag"],"qualification":"This is the conclusion of investigators acting for a parliamentary committee, not a disciplinary or court finding; the auditor oversight body's later decision is described separately.","response":"EY said in June 2020, as quoted from a news agency in a European Parliament briefing, that there were clear indications of an elaborate and sophisticated fraud involving multiple parties around the world in different institutions with a deliberate aim of deception.","outcome":"Germany's auditor oversight body found on 31 March 2023 that professional duties had been breached in the 2016-2018 audits of Wirecard AG and Wirecard Bank AG and imposed sanctions; on 11 December 2025 the Federal Court of Justice largely upheld the insolvency administrator's claims for information about and access to the audit firm's working files."},"reading":"Attributed: The special investigators concluded on 16 April 2021 that there were indications that EY had not fully applied the IDW standards in planning and performing the audit, that a systematic analysis of fraud indicators could have led to greater professional scepticism and further procedures on the TPA business, and that the audit evidence often consisted not of third-party confirmations but of internal documents and oral statements by the management board; their report gives no overall assessment of whether the audit was properly performed."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-kpmg-timeline","record":{"id":"c-aud-kpmg-timeline","kind":"fact","text":"A European Parliament briefing records that KPMG began an independent special investigation of Wirecard on 31 October 2019 and reported its results on 27 April 2020, and that Wirecard AG applied for insolvency proceedings on 25 June 2020.","source_ids":["src-025"],"entity_ids":["kpmg","wirecard","europarl"],"qualification":"","response":"","outcome":""},"reading":"Fact: A European Parliament briefing records that KPMG began an independent special investigation of Wirecard on 31 October 2019 and reported its results on 27 April 2020, and that Wirecard AG applied for insolvency proceedings on 25 June 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-kpmg-adhoc","record":{"id":"c-aud-kpmg-adhoc","kind":"fact","text":"In an ad hoc announcement of 28 April 2020 Wirecard AG stated that KPMG's special investigation had found no incriminating evidence for the public allegations of balance sheet manipulation and, for the four areas examined (TPA, merchant cash advance/digital lending, India and Singapore), no findings requiring adjustment of the 2016–2018 accounts. It also said that not all data needed to prove TPA revenue for those years could be obtained because it was held by third parties, that KPMG had identified documentation and organisational weaknesses, and that publication of the annual accounts on 30 April 2020 was cancelled pending coordination with EY.","source_ids":["src-059"],"entity_ids":["wirecard","kpmg","ey"],"qualification":"","response":"","outcome":""},"reading":"Fact: In an ad hoc announcement of 28 April 2020 Wirecard AG stated that KPMG's special investigation had found no incriminating evidence for the public allegations of balance sheet manipulation and, for the four areas examined (TPA, merchant cash advance/digital lending, India and Singapore), no findings requiring adjustment of the 2016–2018 accounts. It also said that not all data needed to prove TPA revenue for those years could be obtained because it was held by third parties, that KPMG had identified documentation and organisational weaknesses, and that publication of the annual accounts on 30 April 2020 was cancelled pending coordination with EY."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-kpmg-esma","record":{"id":"c-aud-kpmg-esma","kind":"fact","text":"ESMA's chronology states that the KPMG report published on Wirecard's website on 28 April 2020 found the evidence insufficient to conclude either that the TPA revenue existed and was accurate or that it did not, while Wirecard said in an ad hoc announcement the same day that KPMG had found no evidence of balance-sheet manipulation.","source_ids":["src-087"],"entity_ids":["kpmg","wirecard","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: ESMA's chronology states that the KPMG report published on Wirecard's website on 28 April 2020 found the evidence insufficient to conclude either that the TPA revenue existed and was accurate or that it did not, while Wirecard said in an ad hoc announcement the same day that KPMG had found no evidence of balance-sheet manipulation."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-apas","record":{"id":"c-aud-apas","kind":"fact","text":"Germany's auditor oversight body APAS announced on 3 April 2023 that its professional-supervision decision chamber had found on 31 March 2023 that professional duties were breached in the audits of Wirecard AG and Wirecard Bank AG for 2016 to 2018 and imposed sanctions on the audit firm and five auditors; proceedings against seven further auditors ended because they gave up their auditor status. The fines were EUR 23,000 to EUR 300,000 for individuals and EUR 500,000 for the firm, which was also barred for two years from accepting new statutory audits of public-interest entities; the investigation covered 12 auditors and one firm for the 2016–2019 audits and found no breaches for 2019.","source_ids":["src-030"],"entity_ids":["apas","wirecard","wd-bank","ey"],"qualification":"The announcement does not name the audit firm; Wirecard's auditor for these years was EY.","response":"","outcome":"","adverse_subject_ids":["ey"]},"reading":"Fact: Germany's auditor oversight body APAS announced on 3 April 2023 that its professional-supervision decision chamber had found on 31 March 2023 that professional duties were breached in the audits of Wirecard AG and Wirecard Bank AG for 2016 to 2018 and imposed sanctions on the audit firm and five auditors; proceedings against seven further auditors ended because they gave up their auditor status. The fines were EUR 23,000 to EUR 300,000 for individuals and EUR 500,000 for the firm, which was also barred for two years from accepting new statutory audits of public-interest entities; the investigation covered 12 auditors and one firm for the 2016–2019 audits and found no breaches for 2019."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-frep-aob","record":{"id":"c-aud-frep-aob","kind":"fact","text":"ESMA reports that when FREP concluded on 20 July 2020 that Wirecard's 2018 accounts were erroneous, it notified the auditor oversight body of a possible breach of professional requirements by the group auditor EY, and on 22 July 2020 sent it KPMG's full report.","source_ids":["src-087"],"entity_ids":["dpr","apas","ey","kpmg","esma","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: ESMA reports that when FREP concluded on 20 July 2020 that Wirecard's 2018 accounts were erroneous, it notified the auditor oversight body of a possible breach of professional requirements by the group auditor EY, and on 22 July 2020 sent it KPMG's full report."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-bgh-files","record":{"id":"c-aud-bgh-files","kind":"fact","text":"On 11 December 2025 the Federal Court of Justice (III ZR 438/23) upheld claims of the insolvency administrator of Wirecard AG and Wirecard Technologies GmbH against their audit firm for information about and access to its working files for the audits of 2016 to 2019, for answers on the 2016 consolidated audit and on the \"Projekt Ring\" special investigation; claims concerning the files for 2014 and 2015 were time-barred.","source_ids":["src-057"],"entity_ids":["bgh","jaffe","wirecard","wd-tech","ey"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 11 December 2025 the Federal Court of Justice (III ZR 438/23) upheld claims of the insolvency administrator of Wirecard AG and Wirecard Technologies GmbH against their audit firm for information about and access to its working files for the audits of 2016 to 2019, for answers on the 2016 consolidated audit and on the \"Projekt Ring\" special investigation; claims concerning the files for 2014 and 2015 were time-barred."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-iaasa","record":{"id":"c-aud-iaasa","kind":"fact","text":"Ireland's audit supervisor IAASA concluded settlements with the auditors of Wirecard UK and Ireland Limited's financial statements: a severe reprimand and a fine of EUR 19,500 for Tony Kelly and a severe reprimand and a fine of EUR 10,500 for Alison Gray.","source_ids":["src-070"],"entity_ids":["iaasa","wd-uki","kelly","gray"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["kelly","gray"]},"reading":"Fact: Ireland's audit supervisor IAASA concluded settlements with the auditors of Wirecard UK and Ireland Limited's financial statements: a severe reprimand and a fine of EUR 19,500 for Tony Kelly and a severe reprimand and a fine of EUR 10,500 for Alison Gray."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-scope","record":{"id":"c-sup-scope","kind":"fact","text":"According to the German Finance Ministry's report of 16 July 2020 to the Bundestag finance committee, Wirecard AG itself provided no banking or payment services and was not supervised by BaFin as a credit, payment or e-money institution, nor classified as a financial holding company; BaFin supervised only Wirecard Bank AG, and the British subsidiary Wirecard Card Solutions Limited was supervised by the UK Financial Conduct Authority.","source_ids":["src-069"],"entity_ids":["wirecard","bafin","wd-bank","wd-card-solutions","fca","bmf"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the German Finance Ministry's report of 16 July 2020 to the Bundestag finance committee, Wirecard AG itself provided no banking or payment services and was not supervised by BaFin as a credit, payment or e-money institution, nor classified as a financial holding company; BaFin supervised only Wirecard Bank AG, and the British subsidiary Wirecard Card Solutions Limited was supervised by the UK Financial Conduct Authority."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-holding","record":{"id":"c-sup-holding","kind":"fact","text":"ESMA's chronology records that on 1 February 2017 BaFin's banking supervision and the Deutsche Bundesbank concluded that Wirecard was not a financial holding company under EU law, so that supervisors had no powers over the group as a whole; the ECB later agreed.","source_ids":["src-087"],"entity_ids":["bafin","wirecard","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: ESMA's chronology records that on 1 February 2017 BaFin's banking supervision and the Deutsche Bundesbank concluded that Wirecard was not a financial holding company under EU law, so that supervisors had no powers over the group as a whole; the ECB later agreed."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-aml-gap","record":{"id":"c-sup-aml-gap","kind":"fact","text":"The Finance Ministry's report states that anti-money-laundering supervision of Wirecard AG was unresolved: the Lower Bavaria district government contacted BaFin on 25 February 2020 and again on 27 May 2020 as the competent authority, Wirecard AG regarded itself as a \"financial undertaking\" supervised by Bavaria, the Bavarian interior ministry said the classification was still open and its working level favoured denying that status, and in July 2020 the Bavarian interior minister Herrmann said he did not regard the district government as the competent supervisor.","source_ids":["src-069"],"entity_ids":["wirecard","bafin","bmf"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Finance Ministry's report states that anti-money-laundering supervision of Wirecard AG was unresolved: the Lower Bavaria district government contacted BaFin on 25 February 2020 and again on 27 May 2020 as the competent authority, Wirecard AG regarded itself as a \"financial undertaking\" supervised by Bavaria, the Bavarian interior ministry said the classification was still open and its working level favoured denying that status, and in July 2020 the Bavarian interior minister Herrmann said he did not regard the district government as the competent supervisor."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-short-ban","record":{"id":"c-sup-short-ban","kind":"fact","text":"BaFin imposed a temporary ban on short selling of Wirecard shares in February 2019, with a positive opinion from ESMA; Wirecard's 2019 bond prospectus presented it as a response to several short-selling attacks.","source_ids":["src-012","src-025"],"entity_ids":["bafin","wirecard","esma","europarl"],"qualification":"","response":"","outcome":""},"reading":"Fact: BaFin imposed a temporary ban on short selling of Wirecard shares in February 2019, with a positive opinion from ESMA; Wirecard's 2019 bond prospectus presented it as a response to several short-selling attacks."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-fine-2019","record":{"id":"c-sup-fine-2019","kind":"fact","text":"On 15 April 2019 BaFin fined Wirecard AG EUR 1.52 million for breaches of financial reporting obligations under § 115 of the Securities Trading Act, partly for late publication of the 2018 half-year report and of the related notice; Wirecard accepted the fine but contested its publication, which followed a decision of the Hessian administrative court in September 2019.","source_ids":["src-069"],"entity_ids":["bafin","wirecard","bmf"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["wirecard"]},"reading":"Fact: On 15 April 2019 BaFin fined Wirecard AG EUR 1.52 million for breaches of financial reporting obligations under § 115 of the Securities Trading Act, partly for late publication of the 2018 half-year report and of the related notice; Wirecard accepted the fine but contested its publication, which followed a decision of the Hessian administrative court in September 2019."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-market-manipulation-probes","record":{"id":"c-sup-market-manipulation-probes","kind":"fact","text":"BaFin investigated market participants betting on falls in Wirecard's share price: after the Zatarra report (from 21 March 2016, with a criminal complaint to the Munich prosecutor on 12 May 2016), after a report by the short-seller SIRF (18 February to 24 May 2018) and after Financial Times publications (from 1 February 2019, with a complaint to the prosecutor on 10 April 2019). ESMA records that in February 2019 BaFin filed a complaint against market participants and two journalists on suspicion of market manipulation.","source_ids":["src-069","src-087"],"entity_ids":["bafin","wirecard","sta-muenchen","ft","esma","bmf"],"qualification":"","response":"","outcome":""},"reading":"Fact: BaFin investigated market participants betting on falls in Wirecard's share price: after the Zatarra report (from 21 March 2016, with a criminal complaint to the Munich prosecutor on 12 May 2016), after a report by the short-seller SIRF (18 February to 24 May 2018) and after Financial Times publications (from 1 February 2019, with a complaint to the prosecutor on 10 April 2019). ESMA records that in February 2019 BaFin filed a complaint against market participants and two journalists on suspicion of market manipulation."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-ft-suit-2019","record":{"id":"c-sup-ft-suit-2019","kind":"fact","text":"In March 2019 Wirecard AG brought a declaratory action in the Munich regional court against the Financial Times and its journalist over the use and misrepresentation of trade secrets; the company's prospectus states that BaFin had filed a complaint over suspected links between the newspaper's reports and short positions and that the Munich prosecutor was investigating Dan McCrum for market manipulation.","source_ids":["src-012"],"entity_ids":["wirecard","ft","mccrum","bafin","sta-muenchen"],"qualification":"","response":"The Munich regional court records that the action was interrupted by Wirecard's insolvency in September 2020 and withdrawn on 28 October 2020.","outcome":""},"reading":"Fact: In March 2019 Wirecard AG brought a declaratory action in the Munich regional court against the Financial Times and its journalist over the use and misrepresentation of trade secrets; the company's prospectus states that BaFin had filed a complaint over suspected links between the newspaper's reports and short positions and that the Munich prosecutor was investigating Dan McCrum for market manipulation."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-kukies","record":{"id":"c-sup-kukies","kind":"fact","text":"The Finance Ministry reported that State Secretary Dr. Jörg Kukies met Dr. Markus Braun on 5 November 2019 without minutes being taken; the topics included the suspicion of market manipulation and the KPMG special audit that had begun.","source_ids":["src-069"],"entity_ids":["braun","bmf","kpmg"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Finance Ministry reported that State Secretary Dr. Jörg Kukies met Dr. Markus Braun on 5 November 2019 without minutes being taken; the topics included the suspicion of market manipulation and the KPMG special audit that had begun."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-mof-reports","record":{"id":"c-sup-mof-reports","kind":"fact","text":"ESMA found that BaFin sent the Finance Ministry at least 17 reports on Wirecard between 2016 and 2020 (three in 2016 and 14 in 2019–2020) on its market-abuse examinations and on proceedings concerning the issuer's transparency obligations.","source_ids":["src-087"],"entity_ids":["bafin","bmf","esma","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: ESMA found that BaFin sent the Finance Ministry at least 17 reports on Wirecard between 2016 and 2020 (three in 2016 and 14 in 2019–2020) on its market-abuse examinations and on proceedings concerning the issuer's transparency obligations."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-2020-complaints","record":{"id":"c-sup-2020-complaints","kind":"fact","text":"BaFin filed a criminal complaint against Wirecard with the Munich prosecutor on 2 June 2020 for market manipulation through misleading ad hoc announcements on the interim results of KPMG's special investigation, on the basis of which the prosecutor searched Wirecard's premises on 5 June 2020. On 18 June 2020 BaFin filed a further complaint on suspicion of misrepresentation under § 331 of the Commercial Code and market manipulation through false information in the 2016–2018 annual accounts, and on 20 June 2020 it opened a market-abuse analysis of recent ad hoc announcements.","source_ids":["src-069","src-087"],"entity_ids":["bafin","wirecard","sta-muenchen","kpmg","esma"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["wirecard"]},"reading":"Fact: BaFin filed a criminal complaint against Wirecard with the Munich prosecutor on 2 June 2020 for market manipulation through misleading ad hoc announcements on the interim results of KPMG's special investigation, on the basis of which the prosecutor searched Wirecard's premises on 5 June 2020. On 18 June 2020 BaFin filed a further complaint on suspicion of misrepresentation under § 331 of the Commercial Code and market manipulation through false information in the 2016–2018 annual accounts, and on 20 June 2020 it opened a market-abuse analysis of recent ad hoc announcements."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-braun-shares","record":{"id":"c-sup-braun-shares","kind":"fact","text":"On 3 June 2020 BaFin opened a market-abuse analysis of purchases of Wirecard shares by the then management board chairman Dr. Markus Braun through MB Beteiligungsgesellschaft mbH; on 29 May 2020 it had reported to the Finance Ministry on his share transactions. ESMA records that on 29 April 2020 BaFin opened a market-manipulation examination of Wirecard's statements to investors that KPMG had found nothing material.","source_ids":["src-069","src-087"],"entity_ids":["bafin","braun","mb-beteiligung","wirecard","kpmg","bmf"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 3 June 2020 BaFin opened a market-abuse analysis of purchases of Wirecard shares by the then management board chairman Dr. Markus Braun through MB Beteiligungsgesellschaft mbH; on 29 May 2020 it had reported to the Finance Ministry on his share transactions. ESMA records that on 29 April 2020 BaFin opened a market-manipulation examination of Wirecard's statements to investors that KPMG had found nothing material."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-bank-measures-2020","record":{"id":"c-sup-bank-measures-2020","kind":"fact","text":"On 22 June 2020 BaFin required Wirecard Bank AG to report its liquidity daily, appointed a special representative to oversee all significant payments with group companies, placed the bank under special observation and asked foreign supervisors for assistance.","source_ids":["src-087"],"entity_ids":["bafin","wd-bank","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 22 June 2020 BaFin required Wirecard Bank AG to report its liquidity daily, appointed a special representative to oversee all significant payments with group companies, placed the bank under special observation and asked foreign supervisors for assistance."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-frep-history","record":{"id":"c-sup-frep-history","kind":"fact","text":"ESMA records that in 15 years FREP fully examined Wirecard's accounts four times (2005, 2011 and 2014 by sample, 2018 on risk grounds), found an error in the 2005 accounts and in 2008 began an examination of the 2007 accounts on indications of irregularities after public allegations by the head of a German shareholders' association; it was suspended because of an action to annul the 2007 accounts, which the Munich regional court rejected, and ended in June 2012 for lack of public interest, while the examination of the 2011 accounts found no errors in December 2012.","source_ids":["src-087"],"entity_ids":["dpr","wirecard","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: ESMA records that in 15 years FREP fully examined Wirecard's accounts four times (2005, 2011 and 2014 by sample, 2018 on risk grounds), found an error in the 2005 accounts and in 2008 began an examination of the 2007 accounts on indications of irregularities after public allegations by the head of a German shareholders' association; it was suspended because of an action to annul the 2007 accounts, which the Munich regional court rejected, and ended in June 2012 for lack of public interest, while the examination of the 2011 accounts found no errors in December 2012."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-frep-2014","record":{"id":"c-sup-frep-2014","kind":"fact","text":"FREP selected Wirecard's 2014 annual report by random sampling on 15 December 2014, opened the examination by letter of 15 April 2015 and concluded it on 1 December 2016 without error findings; Wirecard's 2015 accounts were not examined, and from 2015 to 2018 Wirecard was not selected on concrete risk grounds. ESMA rated the 2014 examination only partially compliant with supervisory expectations, citing serious shortcomings, material risks left unaddressed, insufficient professional scepticism and a duration of 19.5 months against an average of eight.","source_ids":["src-087"],"entity_ids":["dpr","wirecard","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: FREP selected Wirecard's 2014 annual report by random sampling on 15 December 2014, opened the examination by letter of 15 April 2015 and concluded it on 1 December 2016 without error findings; Wirecard's 2015 accounts were not examined, and from 2015 to 2018 Wirecard was not selected on concrete risk grounds. ESMA rated the 2014 examination only partially compliant with supervisory expectations, citing serious shortcomings, material risks left unaddressed, insufficient professional scepticism and a duration of 19.5 months against an average of eight."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-frep-whistleblower","record":{"id":"c-sup-frep-whistleblower","kind":"fact","text":"BaFin learned of the Zatarra report in February 2016 and on 27 April 2016 asked FREP to include Wirecard in its risk group; on 29 September 2016 a whistleblower told FREP that the acquiring receivables and payables in the 2015 balance sheet were doubtful, which FREP's committee considered evidently unfounded on 6 October 2016. On 1 December 2016 Wirecard gave FREP a one-page interim report by an external party it had engaged, without addressee or signature, attached to a letter from its chief accountant, and FREP closed its examination the same day without error findings.","source_ids":["src-087"],"entity_ids":["bafin","dpr","wirecard","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: BaFin learned of the Zatarra report in February 2016 and on 27 April 2016 asked FREP to include Wirecard in its risk group; on 29 September 2016 a whistleblower told FREP that the acquiring receivables and payables in the 2015 balance sheet were doubtful, which FREP's committee considered evidently unfounded on 6 October 2016. On 1 December 2016 Wirecard gave FREP a one-page interim report by an external party it had engaged, without addressee or signature, attached to a letter from its chief accountant, and FREP closed its examination the same day without error findings."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-frep-ey-2016","record":{"id":"c-sup-frep-ey-2016","kind":"fact","text":"At a working meeting on 11 October 2016 EY confirmed to FREP that it had looked into the fraud allegations in the Zatarra report and addressed the related allegations in the Financial Times; FREP considered the matter resolved because the 2015 accounts carried a clean opinion, which ESMA criticised as reliance solely on the auditor's work.","source_ids":["src-087"],"entity_ids":["ey","dpr","wirecard","esma","ft"],"qualification":"","response":"","outcome":""},"reading":"Fact: At a working meeting on 11 October 2016 EY confirmed to FREP that it had looked into the fraud allegations in the Zatarra report and addressed the related allegations in the Financial Times; FREP considered the matter resolved because the 2015 accounts carried a clean opinion, which ESMA criticised as reliance solely on the auditor's work."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-frep-250m","record":{"id":"c-sup-frep-250m","kind":"fact","text":"On 28 February 2017 FREP's committee decided that a business magazine article about a \"EUR 250 million puzzle\" did not give sufficiently concrete indications of accounting breaches, although the amount and nature of rolling security reserve receivables of EUR 250 million remained unexplained; in an internal note of 15 March 2017 BaFin concluded that the 2015 annual accounts showed no concrete indications of accounting breaches and that a lack of clarity was not a breach, a view ESMA strongly disagreed with, citing IAS 1.","source_ids":["src-087"],"entity_ids":["dpr","bafin","wirecard","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 28 February 2017 FREP's committee decided that a business magazine article about a \"EUR 250 million puzzle\" did not give sufficiently concrete indications of accounting breaches, although the amount and nature of rolling security reserve receivables of EUR 250 million remained unexplained; in an internal note of 15 March 2017 BaFin concluded that the 2015 annual accounts showed no concrete indications of accounting breaches and that a lack of clarity was not a breach, a view ESMA strongly disagreed with, citing IAS 1."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-frep-2019","record":{"id":"c-sup-frep-2019","kind":"fact","text":"In 2019 FREP placed Wirecard in an abstract risk pool because of unusual transactions such as mergers, above-average growth, sector risks and weak corporate governance; ESMA notes that these signs, including annual revenue growth of 30% and acquisitions in Asia such as Citi's operations in 11 Asian countries in 2017, had been visible earlier. On 30 October 2019, in agreement with BaFin, FREP extended its examination to the amount and existence of TPA revenue, the classification of escrow accounts as cash and a possible \"Indian round-tripping\", and decided to await KPMG's results.","source_ids":["src-087"],"entity_ids":["dpr","bafin","wirecard","esma","kpmg"],"qualification":"","response":"","outcome":""},"reading":"Fact: In 2019 FREP placed Wirecard in an abstract risk pool because of unusual transactions such as mergers, above-average growth, sector risks and weak corporate governance; ESMA notes that these signs, including annual revenue growth of 30% and acquisitions in Asia such as Citi's operations in 11 Asian countries in 2017, had been visible earlier. On 30 October 2019, in agreement with BaFin, FREP extended its examination to the amount and existence of TPA revenue, the classification of escrow accounts as cash and a possible \"Indian round-tripping\", and decided to await KPMG's results."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-bafin-requests","record":{"id":"c-sup-bafin-requests","kind":"fact","text":"BaFin required FREP (the DPR) to examine Wirecard's condensed half-year accounts at 30 June 2018 on 15 February 2019, the consolidated accounts at 31 December 2018 on 30 April 2020, the condensed accounts at 30 June 2019 on 24 June 2020 and the consolidated accounts at 31 December 2017 on 25 June 2020. On 30 April 2020 BaFin expressly cited KPMG's report as concrete indications of material accounting breaches concerning TPA revenue, the presentation of the TPA escrow accounts and the reporting of TPA risks in the management report.","source_ids":["src-069","src-087"],"entity_ids":["bafin","dpr","wirecard","kpmg","esma","bmf"],"qualification":"","response":"","outcome":""},"reading":"Fact: BaFin required FREP (the DPR) to examine Wirecard's condensed half-year accounts at 30 June 2018 on 15 February 2019, the consolidated accounts at 31 December 2018 on 30 April 2020, the condensed accounts at 30 June 2019 on 24 June 2020 and the consolidated accounts at 31 December 2017 on 25 June 2020. On 30 April 2020 BaFin expressly cited KPMG's report as concrete indications of material accounting breaches concerning TPA revenue, the presentation of the TPA escrow accounts and the reporting of TPA risks in the management report."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-frep-ft-unaware","record":{"id":"c-sup-frep-ft-unaware","kind":"fact","text":"ESMA records that in early 2019 BaFin received the preliminary Rajah & Tann report on Wirecard from an anonymous whistleblower but, citing professional secrecy, did not pass it to FREP, which obtained it from Wirecard in mid-2019; BaFin also stated that its market-abuse and financial-reporting teams were unaware of the Financial Times articles of the first half of 2019 on Wirecard's TPA partners, although they had access to the newspaper, and FREP noted that BaFin had not shared information on its market-abuse, anti-money-laundering or Wirecard Bank supervision.","source_ids":["src-087"],"entity_ids":["bafin","dpr","rajah-tann","wirecard","esma","ft"],"qualification":"","response":"","outcome":""},"reading":"Fact: ESMA records that in early 2019 BaFin received the preliminary Rajah & Tann report on Wirecard from an anonymous whistleblower but, citing professional secrecy, did not pass it to FREP, which obtained it from Wirecard in mid-2019; BaFin also stated that its market-abuse and financial-reporting teams were unaware of the Financial Times articles of the first half of 2019 on Wirecard's TPA partners, although they had access to the newspaper, and FREP noted that BaFin had not shared information on its market-abuse, anti-money-laundering or Wirecard Bank supervision."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-frep-no-access","record":{"id":"c-sup-frep-no-access","kind":"fact","text":"During the 2019–2020 examination Wirecard did not formally release its auditor from confidentiality, so FREP had no contact with EY throughout, and it also refused to release KPMG; a contract with KPMG requested in mid-December 2019 was supplied by Wirecard at the end of January 2020.","source_ids":["src-087"],"entity_ids":["wirecard","dpr","ey","kpmg","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: During the 2019–2020 examination Wirecard did not formally release its auditor from confidentiality, so FREP had no contact with EY throughout, and it also refused to release KPMG; a contract with KPMG requested in mid-December 2019 was supplied by Wirecard at the end of January 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-frep-2020","record":{"id":"c-sup-frep-2020","kind":"fact","text":"On 17 June 2020 FREP received from BaFin the auditor's report under Article 12 of EU Regulation 537/2014 on possibly incorrect balance confirmations for part of the TPA trust accounts. On 29 June 2020 Wirecard's management board told FREP that the reliability of information supplied earlier, especially on \"third-party transactions\", was in doubt and that it could not say which remained reliable.","source_ids":["src-087"],"entity_ids":["dpr","bafin","wirecard","ey","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 17 June 2020 FREP received from BaFin the auditor's report under Article 12 of EU Regulation 537/2014 on possibly incorrect balance confirmations for part of the TPA trust accounts. On 29 June 2020 Wirecard's management board told FREP that the reliability of information supplied earlier, especially on \"third-party transactions\", was in doubt and that it could not say which remained reliable."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-frep-error","record":{"id":"c-sup-frep-error","kind":"fact","text":"FREP found Wirecard's 2018 half-year report erroneous on 9 July 2020 and finalised on 6 July 2020 its findings that the 2018 half-year and annual reports were erroneous, concluding that significant assets, revenue and expenses had not been properly accounted for (breach of § 238(1) of the Commercial Code) and that the half-year report did not give a true picture (IAS 1.15). Wirecard disagreed and refused to take part in the examinations of the 2017 accounts and the first half of 2019; on 20 July 2020 FREP ended its examinations and passed them to BaFin, which took them over at the second level on 24 July 2020.","source_ids":["src-087"],"entity_ids":["dpr","wirecard","bafin","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: FREP found Wirecard's 2018 half-year report erroneous on 9 July 2020 and finalised on 6 July 2020 its findings that the 2018 half-year and annual reports were erroneous, concluding that significant assets, revenue and expenses had not been properly accounted for (breach of § 238(1) of the Commercial Code) and that the half-year report did not give a true picture (IAS 1.15). Wirecard disagreed and refused to take part in the examinations of the 2017 accounts and the first half of 2019; on 20 July 2020 FREP ended its examinations and passed them to BaFin, which took them over at the second level on 24 July 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-bundesanzeiger","record":{"id":"c-sup-bundesanzeiger","kind":"fact","text":"On 4 August 2020 BaFin for the first time published in the Federal Gazette a notice on examinations of an issuer's financial reporting, covering Wirecard's half-year and annual reports for 2018, the half-year report for 2019 and the annual report for 2017.","source_ids":["src-087"],"entity_ids":["bafin","wirecard","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 4 August 2020 BaFin for the first time published in the Federal Gazette a notice on examinations of an issuer's financial reporting, covering Wirecard's half-year and annual reports for 2018, the half-year report for 2019 and the annual report for 2017."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-esma-mandate","record":{"id":"c-sup-esma-mandate","kind":"fact","text":"On 25 June 2020 the European Commission asked ESMA to analyse the events leading to Wirecard's collapse and the German supervisors' response; ESMA launched a fast-track peer review of BaFin and FREP, set up its committee on 6 August 2020 and approved the mandate on 25 August 2020.","source_ids":["src-087"],"entity_ids":["esma","bafin","dpr","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 25 June 2020 the European Commission asked ESMA to analyse the events leading to Wirecard's collapse and the German supervisors' response; ESMA launched a fast-track peer review of BaFin and FREP, set up its committee on 6 August 2020 and approved the mandate on 25 August 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-esma-findings","record":{"id":"c-sup-esma-findings","kind":"fact","text":"ESMA's fast-track peer review of BaFin's and FREP's supervision of Wirecard's financial reporting (period 1 January 2015 to 25 August 2020, published on 3 November 2020) found a heightened risk of Finance Ministry influence on BaFin because of the frequency and detail of its reporting, that BaFin had no information on staff shareholdings and that some staff in its market-abuse team had traded Wirecard shares, and that FREP did not select Wirecard's 2015–2017 accounts for examination nor did BaFin request it.","source_ids":["src-087"],"entity_ids":["esma","bafin","dpr","bmf","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: ESMA's fast-track peer review of BaFin's and FREP's supervision of Wirecard's financial reporting (period 1 January 2015 to 25 August 2020, published on 3 November 2020) found a heightened risk of Finance Ministry influence on BaFin because of the frequency and detail of its reporting, that BaFin had no information on staff shareholdings and that some staff in its market-abuse team had traded Wirecard shares, and that FREP did not select Wirecard's 2015–2017 accounts for examination nor did BaFin request it."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-esma-allegations","record":{"id":"c-sup-esma-allegations","kind":"attributed","text":"ESMA's report summarises the public allegations against Wirecard: FT Alphaville blog posts (\"House of Wirecard\", 2015) raised the first doubts about the accounting for TPA partners, and a whistleblower raised concerns with FREP in 2016 about acquiring receivables at subsidiaries in jurisdictions without a licence (Dubai, Ireland); in early 2016 Zatarra Research and Investigations accused Wirecard of money laundering (mainly on information from 2006–2010), facilitating circumvention of US online-gambling restrictions, deceiving Visa and Mastercard on customer checks and overpaying for acquisitions; and on 7 June 2019 the Financial Times reported that a long-standing Wirecard customer had settled US allegations of defrauding customers of more than USD 110 million.","source_ids":["src-087"],"entity_ids":["esma","wirecard","ft","dpr"],"qualification":"These are allegations by journalists, short-sellers and a whistleblower as summarised by ESMA; Wirecard systematically rejected them at the time.","response":"","outcome":""},"reading":"Attributed: ESMA's report summarises the public allegations against Wirecard: FT Alphaville blog posts (\"House of Wirecard\", 2015) raised the first doubts about the accounting for TPA partners, and a whistleblower raised concerns with FREP in 2016 about acquiring receivables at subsidiaries in jurisdictions without a licence (Dubai, Ireland); in early 2016 Zatarra Research and Investigations accused Wirecard of money laundering (mainly on information from 2006–2010), facilitating circumvention of US online-gambling restrictions, deceiving Visa and Mastercard on customer checks and overpaying for acquisitions; and on 7 June 2019 the Financial Times reported that a long-standing Wirecard customer had settled US allegations of defrauding customers of more than USD 110 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-fca","record":{"id":"c-sup-fca","kind":"fact","text":"On 26 June 2020 the UK Financial Conduct Authority imposed requirements on Wirecard's British e-money firm: it was not to dispose of assets or funds, not to carry on regulated activities, and to state on its website that it could no longer do so; the FCA cited events in Germany around the parent Wirecard AG, which it did not supervise. After it allowed e-money activity to resume on 29 June 2020, restrictions on where customer funds could be held and on transfers of the firm's own assets remained.","source_ids":["src-068","src-025"],"entity_ids":["fca","wd-card-solutions","wirecard"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["wd-card-solutions"]},"reading":"Fact: On 26 June 2020 the UK Financial Conduct Authority imposed requirements on Wirecard's British e-money firm: it was not to dispose of assets or funds, not to carry on regulated activities, and to state on its website that it could no longer do so; the FCA cited events in Germany around the parent Wirecard AG, which it did not supervise. After it allowed e-money activity to resume on 29 June 2020, restrictions on where customer funds could be held and on transfers of the firm's own assets remained."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-fca-cards","record":{"id":"c-sup-fca-cards","kind":"fact","text":"Wirecard reported at the end of June 2020 that the FCA had suspended the activities of Wirecard Card Solutions Limited (Newcastle) after Wirecard AG's insolvency filing and lifted the restrictions early on 30 June 2020, reopening several hundred thousand accounts for payments; the Estonian e-Residency programme reported that the firm issued Holvi Business Mastercard and Payoneer prepaid Mastercard cards, which were frozen and later partly restored.","source_ids":["src-048","src-088"],"entity_ids":["wirecard","fca","wd-card-solutions","holvi","payoneer"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["wd-card-solutions"]},"reading":"Fact: Wirecard reported at the end of June 2020 that the FCA had suspended the activities of Wirecard Card Solutions Limited (Newcastle) after Wirecard AG's insolvency filing and lifted the restrictions early on 30 June 2020, reopening several hundred thousand accounts for payments; the Estonian e-Residency programme reported that the firm issued Holvi Business Mastercard and Payoneer prepaid Mastercard cards, which were frozen and later partly restored."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-mas","record":{"id":"c-sup-mas","kind":"fact","text":"The Monetary Authority of Singapore lists Wirecard Asia Holding Pte. Ltd. (domestic and inbound cross-border money transfers and merchant acquisition) and Wirecard Singapore Pte. Ltd. (account issuance, money transfers and e-money issuance) among entities that previously held a temporary exemption from licensing under the Payment Services Act but no longer do and may not provide these services.","source_ids":["src-077"],"entity_ids":["mas","wd-asia-holding","wd-singapore"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Monetary Authority of Singapore lists Wirecard Asia Holding Pte. Ltd. (domestic and inbound cross-border money transfers and merchant acquisition) and Wirecard Singapore Pte. Ltd. (account issuance, money transfers and e-money issuance) among entities that previously held a temporary exemption from licensing under the Payment Services Act but no longer do and may not provide these services."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-gi-retail","record":{"id":"c-asia-gi-retail","kind":"fact","text":"On 27 October 2015 Wirecard AG signed agreements to acquire the payment business of the Great Indian (GI) Retail Group: 100% of Hermes I Tickets Pte. Ltd., GI Philippines Corp. and Star Global Currency Exchange Pte. Ltd. and 60% of GI Technology Private Limited, for EUR 230 million in cash plus up to EUR 110 million depending on 2015–2017 results. Wirecard consolidated the three wholly owned companies from 30 December 2015 because a trust arrangement (Treuhandvereinbarung) already gave it control and economic ownership, with closing in early 2016; GI Technology was acquired at 60% from 1 March 2016.","source_ids":["src-032"],"entity_ids":["wirecard","gi-retail","hermes","gi-philippines","wd-forex-india","gi-technology"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 27 October 2015 Wirecard AG signed agreements to acquire the payment business of the Great Indian (GI) Retail Group: 100% of Hermes I Tickets Pte. Ltd., GI Philippines Corp. and Star Global Currency Exchange Pte. Ltd. and 60% of GI Technology Private Limited, for EUR 230 million in cash plus up to EUR 110 million depending on 2015–2017 results. Wirecard consolidated the three wholly owned companies from 30 December 2015 because a trust arrangement (Treuhandvereinbarung) already gave it control and economic ownership, with closing in early 2016; GI Technology was acquired at 60% from 1 March 2016."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-gi-price","record":{"id":"c-asia-gi-price","kind":"attributed","text":"ESMA, summarising press reports, states that Wirecard agreed to pay EUR 330 million for a group of Indian payment businesses whose key company was Hermes, although a year earlier the key assets had been valued at EUR 46 million, and that a fund, EMIF1A, had paid USD 37 million for Hermes only six weeks before bundling it into the transaction with Wirecard. According to a business magazine cited by ESMA, the price of up to EUR 340 million was 49 times pre-tax earnings; FREP told ESMA the price included an earn-out of EUR 110 million.","source_ids":["src-087"],"entity_ids":["wirecard","hermes","emerging-fund","esma","ft","dpr"],"qualification":"Press reporting and ESMA's summary of it; Wirecard disputed critical reporting at the time and no court has ruled on the price.","response":"","outcome":""},"reading":"Attributed: ESMA, summarising press reports, states that Wirecard agreed to pay EUR 330 million for a group of Indian payment businesses whose key company was Hermes, although a year earlier the key assets had been valued at EUR 46 million, and that a fund, EMIF1A, had paid USD 37 million for Hermes only six weeks before bundling it into the transaction with Wirecard. According to a business magazine cited by ESMA, the price of up to EUR 340 million was 49 times pre-tax earnings; FREP told ESMA the price included an earn-out of EUR 110 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-hermes-litigation","record":{"id":"c-asia-hermes-litigation","kind":"fact","text":"Wirecard's 2018 annual report records that former minority shareholders of the Indian subsidiary Hermes, acquired in 2015, were suing their former co-shareholders and Wirecard AG in the United Kingdom, claiming they had received too little for their shares, and that in March 2019 an Indian company also sued, among others, Wirecard AG; a class action by holders of unsponsored American depositary receipts was pending in California over price falls after the investigations in Asia.","source_ids":["src-005"],"entity_ids":["wirecard","hermes"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's 2018 annual report records that former minority shareholders of the Indian subsidiary Hermes, acquired in 2015, were suing their former co-shareholders and Wirecard AG in the United Kingdom, claiming they had received too little for their shares, and that in March 2019 an Indian company also sued, among others, Wirecard AG; a class action by holders of unsponsored American depositary receipts was pending in California over price falls after the investigations in Asia."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-ring-whistleblower","record":{"id":"c-asia-ring-whistleblower","kind":"attributed","text":"In early summer 2016 EY learned of a conversation between an EY India audit partner and Hermes' chief financial officer, summarised in a whistleblower memo: according to it, the seller of the Hermes group, Emerging Fund1A, had itself bought the group a few months before the deal, Wirecard \"senior management\" was directly or indirectly involved in the fund and would receive the EUR 110 million earn-out, revenue would have to be fabricated to meet the targets, and these mechanisms were said to be directed by Stephan von Erffa.","source_ids":["src-027"],"entity_ids":["ey","hermes","emerging-fund","wirecard","von-erffa"],"qualification":"These are the whistleblower's allegations as recorded by EY and summarised by the special investigators; the management board denied any involvement in the fund, and the allegations about von Erffa's role were left unexamined.","response":"The management board stated that it had no interest in Fund1A, and EY accepted these statements.","outcome":""},"reading":"Attributed: In early summer 2016 EY learned of a conversation between an EY India audit partner and Hermes' chief financial officer, summarised in a whistleblower memo: according to it, the seller of the Hermes group, Emerging Fund1A, had itself bought the group a few months before the deal, Wirecard \"senior management\" was directly or indirectly involved in the fund and would receive the EUR 110 million earn-out, revenue would have to be fabricated to meet the targets, and these mechanisms were said to be directed by Stephan von Erffa."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-ring-mandate","record":{"id":"c-asia-ring-mandate","kind":"fact","text":"At a meeting with the supervisory and management boards on 8 September 2016, Burkhard Ley (CFO) agreed to disclose his personal financial circumstances, but on 12 September 2016 he told the auditor he was not prepared to do so or to be interviewed, which EY treated as an indicator of possible management involvement. The same day the management board instructed EY's forensic service to carry out \"Projekt Ring\": a sample-based check of revenue, a review of at least one employee's e-mails and an optional review of personal finances for conflicts of interest; the working papers show no notable investigative work until February 2017.","source_ids":["src-027"],"entity_ids":["ley","wirecard","ey"],"qualification":"","response":"","outcome":""},"reading":"Fact: At a meeting with the supervisory and management boards on 8 September 2016, Burkhard Ley (CFO) agreed to disclose his personal financial circumstances, but on 12 September 2016 he told the auditor he was not prepared to do so or to be interviewed, which EY treated as an indicator of possible management involvement. The same day the management board instructed EY's forensic service to carry out \"Projekt Ring\": a sample-based check of revenue, a review of at least one employee's e-mails and an optional review of personal finances for conflicts of interest; the working papers show no notable investigative work until February 2017."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-ring-2017","record":{"id":"c-asia-ring-2017","kind":"fact","text":"On 2 February 2017 EY proposed a simplified alternative procedure for Projekt Ring because Wirecard had failed since September 2016 to provide a reliable transaction database, and Jan Marsalek and Burkhard Ley agreed. In an e-mail to Ley of 16 March 2017 EY recorded that revenue booked in 2015 and 2016 (Projekt Ring, Indian Hermes) was not adequately evidenced as to amount, substance and timing, that the amounts significantly affected the 2015 and 2016 earn-outs, and for the first time raised a possible qualification of the opinion.","source_ids":["src-027"],"entity_ids":["ey","wirecard","marsalek","ley","hermes"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 2 February 2017 EY proposed a simplified alternative procedure for Projekt Ring because Wirecard had failed since September 2016 to provide a reliable transaction database, and Jan Marsalek and Burkhard Ley agreed. In an e-mail to Ley of 16 March 2017 EY recorded that revenue booked in 2015 and 2016 (Projekt Ring, Indian Hermes) was not adequately evidenced as to amount, substance and timing, that the amounts significantly affected the 2015 and 2016 earn-outs, and for the first time raised a possible qualification of the opinion."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-ring-warning","record":{"id":"c-asia-ring-warning","kind":"fact","text":"On 29 March 2017 EY informed the management board (Dr. Markus Braun, Burkhard Ley and Jan Marsalek) and supervisory board chairman Wulf Matthias orally and in writing that it would qualify its opinions on the 2016 accounts unless it received evidence on more than 20 open questions, mainly concerning the whistleblower's fraud allegations; at a meeting on 30 March 2017 headed \"Ring Meeting\", Ley told EY that additional questions were not feasible at present. Around 30 March 2017 the memos and e-mails by which the auditor confirmed the recoverability of disputed receivables (debtors including Bytemax, Clear.IO and Pyro) were prepared or supplied mainly by Marsalek and Ley, some of them carried forward since 2014.","source_ids":["src-027"],"entity_ids":["ey","wirecard","braun","ley","marsalek","matthias"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 29 March 2017 EY informed the management board (Dr. Markus Braun, Burkhard Ley and Jan Marsalek) and supervisory board chairman Wulf Matthias orally and in writing that it would qualify its opinions on the 2016 accounts unless it received evidence on more than 20 open questions, mainly concerning the whistleblower's fraud allegations; at a meeting on 30 March 2017 headed \"Ring Meeting\", Ley told EY that additional questions were not feasible at present. Around 30 March 2017 the memos and e-mails by which the auditor confirmed the recoverability of disputed receivables (debtors including Bytemax, Clear.IO and Pyro) were prepared or supplied mainly by Marsalek and Ley, some of them carried forward since 2014."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-ring-braun","record":{"id":"c-asia-ring-braun","kind":"attributed","text":"At a meeting with EY on 3 April 2017, two days before the opinion date, Dr. Markus Braun said that interested parties were putting Wirecard under pressure with targeted false reports, that investment controlling had been strengthened and the CFO in India replaced, that the whistleblower's allegations about India reflected personal animosity, and that additional transactions could affect the earn-out as long as this was in Wirecard's interest; according to the special investigators he did not address the other allegations in substance.","source_ids":["src-027"],"entity_ids":["braun","ey","wirecard"],"qualification":"Braun's statements as recorded in EY's minutes and summarised by the special investigators.","response":"","outcome":""},"reading":"Attributed: At a meeting with EY on 3 April 2017, two days before the opinion date, Dr. Markus Braun said that interested parties were putting Wirecard under pressure with targeted false reports, that investment controlling had been strengthened and the CFO in India replaced, that the whistleblower's allegations about India reflected personal animosity, and that additional transactions could affect the earn-out as long as this was in Wirecard's interest; according to the special investigators he did not address the other allegations in substance."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-ring-findings","record":{"id":"c-asia-ring-findings","kind":"attributed","text":"On 4 April 2017 EY's forensic service recorded indicators of a targeted increase of EBITDA (fictitious revenue) at the Indian Hermes, while three allegations, instructions by Stephan von Erffa to Hermes' accounting, senior management's involvement in the seller of Hermes and an attempt to bribe the auditor, remained unexamined without interviews or e-mail review. EY estimated the effect of including interest and tax accounts in Hermes' EBITDA on the earn-out at about EUR 13.6 million, the amount by which goodwill would have to be reduced, but accepted the treatment, citing among other things that the due-diligence provider Baker Tilly Roelfs had not objected.","source_ids":["src-027","src-057"],"entity_ids":["ey","hermes","von-erffa","wirecard","bgh"],"qualification":"EY's internal findings as summarised by the special investigators; the open allegations were never investigated to a conclusion.","response":"","outcome":"EY nevertheless issued unqualified opinions on the 2016 consolidated accounts on 5 April 2017, and according to the Federal Court of Justice the Projekt Ring investigation was broken off in 2018 at the management board's insistence."},"reading":"Attributed: On 4 April 2017 EY's forensic service recorded indicators of a targeted increase of EBITDA (fictitious revenue) at the Indian Hermes, while three allegations, instructions by Stephan von Erffa to Hermes' accounting, senior management's involvement in the seller of Hermes and an attempt to bribe the auditor, remained unexamined without interviews or e-mail review. EY estimated the effect of including interest and tax accounts in Hermes' EBITDA on the earn-out at about EUR 13.6 million, the amount by which goodwill would have to be reduced, but accepted the treatment, citing among other things that the due-diligence provider Baker Tilly Roelfs had not objected."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-ring-opinion","record":{"id":"c-asia-ring-opinion","kind":"fact","text":"Despite the warning of 29 March 2017, EY issued unqualified opinions on Wirecard AG's 2016 consolidated accounts on 5 April 2017 and on the individual accounts on 25 April 2017; the evidence obtained consisted mainly of oral and written statements by the management board. According to the Federal Court of Justice, the Projekt Ring special investigation concerned the acquisition of three Indian companies at allegedly or actually inflated prices and was broken off in 2018 at the management board's insistence.","source_ids":["src-027","src-057"],"entity_ids":["ey","wirecard","bgh"],"qualification":"","response":"","outcome":""},"reading":"Fact: Despite the warning of 29 March 2017, EY issued unqualified opinions on Wirecard AG's 2016 consolidated accounts on 5 April 2017 and on the individual accounts on 25 April 2017; the evidence obtained consisted mainly of oral and written statements by the management board. According to the Federal Court of Justice, the Projekt Ring special investigation concerned the acquisition of three Indian companies at allegedly or actually inflated prices and was broken off in 2018 at the management board's insistence."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-ring-marsalek","record":{"id":"c-asia-ring-marsalek","kind":"fact","text":"An EY working paper of March 2018 in the 2017 audit files records that EY's forensic team had repeatedly tried in vain, or obtained only with delay, the documents it needed, and a timeline in it states that Jan Marsalek (COO) had wanted to end Projekt Ring as early as autumn 2017.","source_ids":["src-027"],"entity_ids":["ey","marsalek","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: An EY working paper of March 2018 in the 2017 audit files records that EY's forensic team had repeatedly tried in vain, or obtained only with delay, the documents it needed, and a timeline in it states that Jan Marsalek (COO) had wanted to end Projekt Ring as early as autumn 2017."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-sg-whistleblower","record":{"id":"c-asia-sg-whistleblower","kind":"fact","text":"Wirecard's 2018 annual report states that in spring 2018 a whistleblower reported irregularities in the local accounting department in Singapore and that Wirecard instructed the law firm Rajah & Tann (Singapore), whose preliminary report is dated 4 May 2018. According to the company, allegations of round-tripping, corruption, money laundering and deceiving regulators in licensing were not confirmed, but Singapore authorities were continuing their investigations and criminal liability of individual employees could not be ruled out.","source_ids":["src-005"],"entity_ids":["wirecard","rajah-tann"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's 2018 annual report states that in spring 2018 a whistleblower reported irregularities in the local accounting department in Singapore and that Wirecard instructed the law firm Rajah & Tann (Singapore), whose preliminary report is dated 4 May 2018. According to the company, allegations of round-tripping, corruption, money laundering and deceiving regulators in licensing were not confirmed, but Singapore authorities were continuing their investigations and criminal liability of individual employees could not be ruled out."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-sg-prospectus","record":{"id":"c-asia-sg-prospectus","kind":"fact","text":"The 2019 bond prospectus states that Rajah & Tann LLP, assisted by a forensic team from Control Risks, investigated the whistleblower allegations of round-tripping, corruption, money laundering and deceiving regulators in licensing, and, in the company's summary of its \"Summary of Updated Findings\" of 26 March 2019, that for 2017 revenue of EUR 2.5 million had been wrongly recognised under a sham contract and EUR 2.3 million entered in a subsidiary's ledger of old receivables.","source_ids":["src-012"],"entity_ids":["wirecard","rajah-tann","control-risks"],"qualification":"","response":"","outcome":""},"reading":"Fact: The 2019 bond prospectus states that Rajah & Tann LLP, assisted by a forensic team from Control Risks, investigated the whistleblower allegations of round-tripping, corruption, money laundering and deceiving regulators in licensing, and, in the company's summary of its \"Summary of Updated Findings\" of 26 March 2019, that for 2017 revenue of EUR 2.5 million had been wrongly recognised under a sham contract and EUR 2.3 million entered in a subsidiary's ledger of old receivables."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-sg-ft","record":{"id":"c-asia-sg-ft","kind":"attributed","text":"ESMA summarises Financial Times articles of 30 January, 1 February and 7 February 2019 reporting that a senior executive of Wirecard's Singapore subsidiary was suspected of using forged and backdated contracts, that a preliminary report by Rajah & Tann pointed to serious offences of forgery, and that USD 37 million appeared to have moved in and out of Wirecard subsidiaries and external businesses in seven sets of complex transactions.","source_ids":["src-012","src-087","src-084","src-095"],"entity_ids":["wirecard","rajah-tann","esma","ft","spf","wd-asia-holding"],"qualification":"Newspaper reporting as summarised by ESMA; Wirecard rejected the reports at the time and later restated limited amounts.","response":"Wirecard's 2019 bond prospectus summarised the law firm's updated findings of 26 March 2019 as limited to EUR 2.5 million of wrongly recognised 2017 revenue under a sham contract and EUR 2.3 million entered in a subsidiary's ledger of old receivables.","outcome":"Singapore police charged three former employees of Wirecard Asia Holding and a director of another company on 17 August 2022; two of the former employees were convicted of criminal breach of trust on 20 June 2023.","adverse_subject_ids":["wirecard"]},"reading":"Attributed: ESMA summarises Financial Times articles of 30 January, 1 February and 7 February 2019 reporting that a senior executive of Wirecard's Singapore subsidiary was suspected of using forged and backdated contracts, that a preliminary report by Rajah & Tann pointed to serious offences of forgery, and that USD 37 million appeared to have moved in and out of Wirecard subsidiaries and external businesses in seven sets of complex transactions."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-restatement-2018","record":{"id":"c-asia-restatement-2018","kind":"fact","text":"In note 2.7 of its 2018 accounts Wirecard corrected retrospectively, in connection with the investigations in Asia, errors in 2017 revenue recognition: software purchase and sale transactions of about EUR 10.0 million had been recorded in the wrong group units with an intermediary as counterparty; 2017 revenue was reduced overall and the net effect on profit after tax was a reduction of EUR 3.6 million. ESMA notes that the adjustments reduced net assets by EUR 8.5 million at 1 January 2017 and EUR 4.8 million at 31 December 2017 and that, according to the press, the Singapore transactions concerned totalled EUR 37 million in 2015–2018.","source_ids":["src-005","src-087"],"entity_ids":["wirecard","esma"],"qualification":"","response":"","outcome":""},"reading":"Fact: In note 2.7 of its 2018 accounts Wirecard corrected retrospectively, in connection with the investigations in Asia, errors in 2017 revenue recognition: software purchase and sale transactions of about EUR 10.0 million had been recorded in the wrong group units with an intermediary as counterparty; 2017 revenue was reduced overall and the net effect on profit after tax was a reduction of EUR 3.6 million. ESMA notes that the adjustments reduced net assets by EUR 8.5 million at 1 January 2017 and EUR 4.8 million at 31 December 2017 and that, according to the press, the Singapore transactions concerned totalled EUR 37 million in 2015–2018."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-restatement-2019","record":{"id":"c-asia-restatement-2019","kind":"fact","text":"Wirecard's 2019 half-year report corrected first-half 2018 revenue under IAS 8 in connection with the Asian investigations and an extended review of transactions: a software transaction of EUR 2.5 million was moved from 2017 into 2018, and revenue and costs of Citi portfolios in Asia-Pacific that had not yet been transferred were overstated and reduced by EUR 21.0 million.","source_ids":["src-066"],"entity_ids":["wirecard","citigroup"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard's 2019 half-year report corrected first-half 2018 revenue under IAS 8 in connection with the Asian investigations and an extended review of transactions: a software transaction of EUR 2.5 million was moved from 2017 into 2018, and revenue and costs of Citi portfolios in Asia-Pacific that had not yet been transferred were overstated and reduced by EUR 21.0 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-sg-charges-2022","record":{"id":"c-asia-sg-charges-2022","kind":"fact","text":"The Singapore Police Force announced on 17 August 2022 that, after the Commercial Affairs Department investigated the activities of Wirecard AG's Singapore subsidiaries Wirecard Asia Holding Pte Ltd (WAH) and Wirecard Singapore Pte Ltd, three former WAH employees and a director of another Singapore company were charged with criminal breach of trust for allegedly conspiring between May and December 2018 with Edo Kurniawan, then WAH's vice president of controlling and finance, to misappropriate amounts of $41,200 to $100,000 from WAH, and with related offences including the falsification of four invoices totalling $184,870; Kurniawan had left Singapore before the investigation began and a warrant had been issued for his arrest.","source_ids":["src-084","src-078"],"entity_ids":["spf","cad","wirecard","wd-asia-holding","wd-singapore","kurniawan"],"qualification":"Charges, not findings; the police release gives the amounts with a dollar sign without naming the currency.","response":"","outcome":""},"reading":"Fact: The Singapore Police Force announced on 17 August 2022 that, after the Commercial Affairs Department investigated the activities of Wirecard AG's Singapore subsidiaries Wirecard Asia Holding Pte Ltd (WAH) and Wirecard Singapore Pte Ltd, three former WAH employees and a director of another Singapore company were charged with criminal breach of trust for allegedly conspiring between May and December 2018 with Edo Kurniawan, then WAH's vice president of controlling and finance, to misappropriate amounts of $41,200 to $100,000 from WAH, and with related offences including the falsification of four invoices totalling $184,870; Kurniawan had left Singapore before the investigation began and a warrant had been issued for his arrest."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-sg-convictions-2023","record":{"id":"c-asia-sg-convictions-2023","kind":"fact","text":"On 20 June 2023 two former Wirecard Asia Holding employees, the international finance process manager James Aga Wardhana and the head of finance Chai Ai Lim, were convicted of criminal breach of trust and other offences and sentenced to 21 and 10 months' imprisonment; the police release describes amounts taken from Wirecard Asia's account in conspiracy with Edo Kurniawan.","source_ids":["src-095"],"entity_ids":["spf","wd-asia-holding","kurniawan"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 20 June 2023 two former Wirecard Asia Holding employees, the international finance process manager James Aga Wardhana and the head of finance Chai Ai Lim, were convicted of criminal breach of trust and other offences and sentenced to 21 and 10 months' imprisonment; the police release describes amounts taken from Wirecard Asia's account in conspiracy with Edo Kurniawan."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-kurniawan-wanted","record":{"id":"c-asia-kurniawan-wanted","kind":"fact","text":"The Singapore Police Force stated on 20 June 2023 that Edo Kurniawan, Wirecard Asia's former vice president of controlling and international finance and a signatory of its bank account, was at large, and that a warrant of arrest and an INTERPOL red notice had been issued against him.","source_ids":["src-095"],"entity_ids":["spf","kurniawan","wd-asia-holding"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["kurniawan"]},"reading":"Fact: The Singapore Police Force stated on 20 June 2023 that Edo Kurniawan, Wirecard Asia's former vice president of controlling and international finance and a signatory of its bank account, was at large, and that a warrant of arrest and an INTERPOL red notice had been issued against him."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-asia-wah-registry","record":{"id":"c-asia-wah-registry","kind":"fact","text":"A business directory summarising Singapore register data records Wirecard Asia Holding Pte. Ltd. (UEN 201429281D), incorporated on 1 October 2014 at 1 Raffles Quay #27-10, as dissolved by members' voluntary winding-up, with RSM SG Assurance LLP as auditor, and Wirecard Singapore Pte. Ltd. (UEN 199906900E), registered on 5 November 1999 at the same address, as dissolved by members' voluntary winding-up.","source_ids":["src-078","src-089"],"entity_ids":["wd-asia-holding","wd-singapore","rsm"],"qualification":"","response":"","outcome":""},"reading":"Fact: A business directory summarising Singapore register data records Wirecard Asia Holding Pte. Ltd. (UEN 201429281D), incorporated on 1 October 2014 at 1 Raffles Quay #27-10, as dissolved by members' voluntary winding-up, with RSM SG Assurance LLP as auditor, and Wirecard Singapore Pte. Ltd. (UEN 199906900E), registered on 5 November 1999 at the same address, as dissolved by members' voluntary winding-up."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mca-ocap-selection","record":{"id":"c-mca-ocap-selection","kind":"attributed","text":"According to the Munich I prosecutor's indictment of 31 July 2024, OCAP Management Pte Ltd. was chosen as a supposedly neutral third party for the merchant cash advance (MCA) business although until the end of 2017 it had financed oil transports, had nothing to do with card payments and belonged to the corporate network of another accused; it was renamed OCAP only at the end of 2017 after several formal ownership changes through shell companies and then applied to Wirecard Bank for MCA financing. The prosecution says Dr. Braun personally pressed a Wirecard Bank board member who had refused, Wirecard AG gave a guarantee, and a loan of EUR 10 million was paid out but not passed on to merchants; in April 2019 the loan and guarantee were extended with retroactive effect.","source_ids":["src-052","src-103"],"entity_ids":["ocap","wd-bank","braun","wirecard","sta-muenchen"],"qualification":"Prosecution allegations in an indictment; the court decided in February 2025 not to pursue the guarantee counts further (see the trial).","response":"","outcome":"In a civil case over the OCAP loan and a related bond subscription, the Munich I regional court ordered three former management board members on 5 September 2024 to pay EUR 140 million to the insolvency administrator; the judgment was not final."},"reading":"Attributed: According to the Munich I prosecutor's indictment of 31 July 2024, OCAP Management Pte Ltd. was chosen as a supposedly neutral third party for the merchant cash advance (MCA) business although until the end of 2017 it had financed oil transports, had nothing to do with card payments and belonged to the corporate network of another accused; it was renamed OCAP only at the end of 2017 after several formal ownership changes through shell companies and then applied to Wirecard Bank for MCA financing. The prosecution says Dr. Braun personally pressed a Wirecard Bank board member who had refused, Wirecard AG gave a guarantee, and a loan of EUR 10 million was paid out but not passed on to merchants; in April 2019 the loan and guarantee were extended with retroactive effect."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mca-ocap-2018-loans","record":{"id":"c-mca-ocap-2018-loans","kind":"attributed","text":"The prosecution states that a Wirecard subsidiary lent OCAP EUR 115 million in September and November 2018; by autumn 2019 substantial interest arrears had built up and repayment was not in sight. On 25 March 2020, while KPMG's special audit was under way, the management board resolved without the supervisory board to lend OCAP a further EUR 100 million, when OCAP had already received about EUR 137 million and was servicing debts in the manner of a \"Ponzi scheme\".","source_ids":["src-052","src-038"],"entity_ids":["ocap","wirecard","sta-muenchen","kpmg"],"qualification":"Prosecution allegations in the indictments of March 2022 and July 2024.","response":"","outcome":""},"reading":"Attributed: The prosecution states that a Wirecard subsidiary lent OCAP EUR 115 million in September and November 2018; by autumn 2019 substantial interest arrears had built up and repayment was not in sight. On 25 March 2020, while KPMG's special audit was under way, the management board resolved without the supervisory board to lend OCAP a further EUR 100 million, when OCAP had already received about EUR 137 million and was servicing debts in the manner of a \"Ponzi scheme\"."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mca-ocap-flow","record":{"id":"c-mca-ocap-flow","kind":"attributed","text":"According to the prosecution, the EUR 100 million reached OCAP's account at Wirecard Bank AG on 27 March 2020 and was transferred the same day in full to an account of Ruprecht Services Pte. Ltd. in Lithuania, from which EUR 35 million went to \"M.\", who passed it on as repayment of a 2017 loan to the account of Dr. Braun's asset-management company; this repaid a Wirecard Bank loan of EUR 35 million, cancelled as of 1 April 2020, with which Dr. Braun had refinanced a EUR 150 million bank loan to his company. The prosecution puts the damage at several hundred million euros.","source_ids":["src-038","src-052"],"entity_ids":["ocap","wd-bank","ruprecht","braun","sta-muenchen"],"qualification":"Prosecution allegations; \"M.\" is the prosecution's abbreviation for a separately prosecuted person, and the account holders are named as in the releases.","response":"","outcome":""},"reading":"Attributed: According to the prosecution, the EUR 100 million reached OCAP's account at Wirecard Bank AG on 27 March 2020 and was transferred the same day in full to an account of Ruprecht Services Pte. Ltd. in Lithuania, from which EUR 35 million went to \"M.\", who passed it on as repayment of a 2017 loan to the account of Dr. Braun's asset-management company; this repaid a Wirecard Bank loan of EUR 35 million, cancelled as of 1 April 2020, with which Dr. Braun had refinanced a EUR 150 million bank loan to his company. The prosecution puts the damage at several hundred million euros."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mca-security-deposit","record":{"id":"c-mca-security-deposit","kind":"attributed","text":"The prosecution states that in December 2019, during KPMG's special investigation, Wirecard AG's management board granted the Singapore company Ruprecht Services Pte. Ltd., a penniless and later insolvent shell from the circle of another accused, a \"security deposit\" of EUR 40 million in total through subsidiaries, without any security, supposedly to replace the TPA partner Al Alam Solution Provider FZ-LLC in Dubai. The increase from EUR 10 million to EUR 40 million on 23 December 2019 was approved within half an hour on Jan Marsalek's e-mail proposal without a formal resolution and without involving the supervisory board; the earlier indictment says the former chief executive \"Dr. B.\" agreed immediately and pressed the other board members, and that repayment is not expected.","source_ids":["src-052","src-038"],"entity_ids":["ruprecht","wirecard","al-alam","marsalek","braun","sta-muenchen","kpmg"],"qualification":"Prosecution allegations; Braun's trial was continuing at the evidence cutoff.","response":"","outcome":""},"reading":"Attributed: The prosecution states that in December 2019, during KPMG's special investigation, Wirecard AG's management board granted the Singapore company Ruprecht Services Pte. Ltd., a penniless and later insolvent shell from the circle of another accused, a \"security deposit\" of EUR 40 million in total through subsidiaries, without any security, supposedly to replace the TPA partner Al Alam Solution Provider FZ-LLC in Dubai. The increase from EUR 10 million to EUR 40 million on 23 December 2019 was approved within half an hour on Jan Marsalek's e-mail proposal without a formal resolution and without involving the supervisory board; the earlier indictment says the former chief executive \"Dr. B.\" agreed immediately and pressed the other board members, and that repayment is not expected."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mca-ruprecht-registry","record":{"id":"c-mca-ruprecht-registry","kind":"fact","text":"Ruprecht Services Pte. Ltd. was incorporated in Singapore on 17 August 2016 with its registered office in the Ocean Financial Centre and IT consultancy as its stated activity; it is in compulsory liquidation for insolvency, with a winding-up application published on 28 January 2022, a winding-up order on 25 February 2022, a creditors' meeting on 17 May 2022 and a final meeting on 25 April 2025. The Monetary Authority of Singapore lists it among entities that previously held a temporary exemption under the Payment Services Act, for account issuance, domestic transfers, merchant acquisition and e-money issuance, but no longer do.","source_ids":["src-072","src-077"],"entity_ids":["ruprecht","mas"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["ruprecht"]},"reading":"Fact: Ruprecht Services Pte. Ltd. was incorporated in Singapore on 17 August 2016 with its registered office in the Ocean Financial Centre and IT consultancy as its stated activity; it is in compulsory liquidation for insolvency, with a winding-up application published on 28 January 2022, a winding-up order on 25 February 2022, a creditors' meeting on 17 May 2022 and a final meeting on 25 April 2025. The Monetary Authority of Singapore lists it among entities that previously held a temporary exemption under the Payment Services Act, for account issuance, domestic transfers, merchant acquisition and e-money issuance, but no longer do."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mca-wd-bank-loans","record":{"id":"c-mca-wd-bank-loans","kind":"attributed","text":"In the preamble to a parliamentary question answered on 18 January 2021, FDP deputies, citing a news magazine, stated that OCAP was under the influence of the TPA partner Senjo Group and of a Senjo figure, received a EUR 115 million loan in 2018 guaranteed by Wirecard AG, had Carlos Häuser as managing director, and that the loan was approved by a Wirecard employee identified as \"H.\". They also stated that on 18 November 2018 the management board released EUR 500 million of loans and credit lines to push the MCA business, that the Indian travel provider Gomoo received EUR 11 million from Wirecard Bank AG guaranteed by Wirecard AG, and that PayEasy received loans of EUR 270 million in 2018.","source_ids":["src-073"],"entity_ids":["ocap","senjo","wirecard","c-haeuser","wd-bank","goomo","payeasy","bundestag"],"qualification":"Statements of opposition deputies citing a magazine, not of the government; the government replied that it had no information on whether \"H.\" had authority to approve loans since 2015.","response":"","outcome":""},"reading":"Attributed: In the preamble to a parliamentary question answered on 18 January 2021, FDP deputies, citing a news magazine, stated that OCAP was under the influence of the TPA partner Senjo Group and of a Senjo figure, received a EUR 115 million loan in 2018 guaranteed by Wirecard AG, had Carlos Häuser as managing director, and that the loan was approved by a Wirecard employee identified as \"H.\". They also stated that on 18 November 2018 the management board released EUR 500 million of loans and credit lines to push the MCA business, that the Indian travel provider Gomoo received EUR 11 million from Wirecard Bank AG guaranteed by Wirecard AG, and that PayEasy received loans of EUR 270 million in 2018."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mca-ocap-senjo","record":{"id":"c-mca-ocap-senjo","kind":"fact","text":"The Federal Government's answer of 18 January 2021 (Bundestag printed paper 19/25977) states that OCAP Management Pte. Ltd. was formerly called Senjo Trading Pte. Ltd. and that loans by Wirecard Bank AG to it and to Senjo Group Pte. Ltd. as TPA partners were in the sample of the 2017 MaRisk special audit by BaFin and the Deutsche Bundesbank (portfolio \"strategic loans\").","source_ids":["src-073"],"entity_ids":["ocap","senjo","wd-bank","bafin","bundestag"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Federal Government's answer of 18 January 2021 (Bundestag printed paper 19/25977) states that OCAP Management Pte. Ltd. was formerly called Senjo Trading Pte. Ltd. and that loans by Wirecard Bank AG to it and to Senjo Group Pte. Ltd. as TPA partners were in the sample of the 2017 MaRisk special audit by BaFin and the Deutsche Bundesbank (portfolio \"strategic loans\")."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mca-ocap-singapore-2020","record":{"id":"c-mca-ocap-singapore-2020","kind":"fact","text":"In November 2020 Singapore's High Court rejected an application by oCap Management to release seized funds, a lump sum of USD 1.85 million and USD 1 million a month, to repay \"loans\" from Wirecard and expenses; the Commercial Affairs Department had seized USD 8.63 million of oCap Management and SGD 290,000 of its Singapore subsidiary oCap Asia Pacific Holdings on 20 August 2020 as suspected proceeds of serious crime.","source_ids":["src-083"],"entity_ids":["ocap","ocap-asia","cad","wirecard"],"qualification":"Reported by a Singapore newspaper; the seizure is an investigative measure, not a finding of guilt.","response":"","outcome":"","adverse_subject_ids":["ocap"]},"reading":"Fact: In November 2020 Singapore's High Court rejected an application by oCap Management to release seized funds, a lump sum of USD 1.85 million and USD 1 million a month, to repay \"loans\" from Wirecard and expenses; the Commercial Affairs Department had seized USD 8.63 million of oCap Management and SGD 290,000 of its Singapore subsidiary oCap Asia Pacific Holdings on 20 August 2020 as suspected proceeds of serious crime."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mca-ocap-singapore-2026","record":{"id":"c-mca-ocap-singapore-2026","kind":"fact","text":"In a judgment of 13 May 2026 ([2026] SGHC 102) Singapore's High Court, on an application by oCap Management's liquidators, released from a restraint order fees already incurred of SGD 178,560.25 but refused to release about SGD 2,997,500 for future claims against third parties. The company has been in creditors' voluntary liquidation since 10 December 2020 and in court-ordered liquidation since 15 March 2021.","source_ids":["src-071"],"entity_ids":["ocap","wirecard"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["ocap"]},"reading":"Fact: In a judgment of 13 May 2026 ([2026] SGHC 102) Singapore's High Court, on an application by oCap Management's liquidators, released from a restraint order fees already incurred of SGD 178,560.25 but refused to release about SGD 2,997,500 for future claims against third parties. The company has been in creditors' voluntary liquidation since 10 December 2020 and in court-ordered liquidation since 15 March 2021."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mca-ocap-restraint","record":{"id":"c-mca-ocap-restraint","kind":"fact","text":"The Singapore judgment records that German authorities charged Dr Markus Braun on 10 March 2022 with embezzlement involving loans of EUR 210 million from Wirecard group companies to oCap Management, allegedly used to disguise the group's true financial position and divert money out of it; at their request the Attorney-General applied on 18 April 2023 and the court ordered on 3 November 2023 the restraint of the company's funds in two Citibank N.A. accounts, as German authorities seek confiscation of EUR 210 million.","source_ids":["src-071"],"entity_ids":["ocap","braun","wirecard","ag-singapore","citibank-na"],"qualification":"The charges are allegations; the court decided only on the restraint and release of funds.","response":"","outcome":"","adverse_subject_ids":["ocap"]},"reading":"Fact: The Singapore judgment records that German authorities charged Dr Markus Braun on 10 March 2022 with embezzlement involving loans of EUR 210 million from Wirecard group companies to oCap Management, allegedly used to disguise the group's true financial position and divert money out of it; at their request the Attorney-General applied on 18 April 2023 and the court ordered on 3 November 2023 the restraint of the company's funds in two Citibank N.A. accounts, as German authorities seek confiscation of EUR 210 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mca-ocap-creditors","record":{"id":"c-mca-ocap-creditors","kind":"fact","text":"According to the Singapore judgment, Wirecard group companies are oCap Management's majority creditors with over 97% of its debt; they funded the liquidators' investigation of the company's affairs but declined to fund claims against third parties, and recoveries for the group are pursued under the control of Wirecard AG's insolvency administrator Dr Michael Jaffé. The liquidators intended to pursue former and possible shadow or de facto directors over a questionable dividend (about SGD 10.14 million) and a company over a breach of an agreement to assign sale proceeds (about SGD 1.95 million).","source_ids":["src-071"],"entity_ids":["ocap","wirecard","jaffe"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the Singapore judgment, Wirecard group companies are oCap Management's majority creditors with over 97% of its debt; they funded the liquidators' investigation of the company's affairs but declined to fund claims against third parties, and recoveries for the group are pursued under the control of Wirecard AG's insolvency administrator Dr Michael Jaffé. The liquidators intended to pursue former and possible shadow or de facto directors over a questionable dividend (about SGD 10.14 million) and a company over a breach of an agreement to assign sale proceeds (about SGD 1.95 million)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mca-civil-judgment","record":{"id":"c-mca-civil-judgment","kind":"fact","text":"On 5 September 2024 the 5th commercial chamber of the Munich I regional court (presiding judge Dr. Helmut Krenek, case 5 HK O 17452/21) ordered three former Wirecard AG management board members, jointly and severally, to pay EUR 140 million plus interest to the insolvency administrator, and dismissed the claim against a former supervisory board member. The case concerned an unsecured loan of EUR 100 million by a subsidiary, from Wirecard AG funds, to OCAP Management Pte Ltd. and the subscription, on Wirecard AG's instructions, of a EUR 100 million bond by a subsidiary.","source_ids":["src-103","src-062"],"entity_ids":["wirecard","jaffe","ocap","braun","lg-muenchen"],"qualification":"The judgment was not final. The press release does not name the three board members; press reporting identifies them as chairman Markus Braun and the finance and product board members.","response":"The former board members argued that they had not breached their duties, or not culpably, and that the decisions were justified in the company's interest.","outcome":"","adverse_subject_ids":["braun"]},"reading":"Fact: On 5 September 2024 the 5th commercial chamber of the Munich I regional court (presiding judge Dr. Helmut Krenek, case 5 HK O 17452/21) ordered three former Wirecard AG management board members, jointly and severally, to pay EUR 140 million plus interest to the insolvency administrator, and dismissed the claim against a former supervisory board member. The case concerned an unsecured loan of EUR 100 million by a subsidiary, from Wirecard AG funds, to OCAP Management Pte Ltd. and the subscription, on Wirecard AG's instructions, of a EUR 100 million bond by a subsidiary."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mca-civil-damage","record":{"id":"c-mca-civil-damage","kind":"fact","text":"The Munich I regional court put the damage from the OCAP loan at EUR 40 million, because EUR 60 million had been repaid from the bond subscription and the borrower was insolvent; it found the loan negligent mainly because of arrears of EUR 2.375 million on another loan and because, after KPMG's special audit, it was uncertain whether the third-party acquiring business closely linked to the loan existed. The bond subscription of EUR 100 million was made without financial due diligence and against a lawyer's advice, and the full amount was lost because the issuer was insolvent; loans of EUR 115 million had been granted in 2018.","source_ids":["src-103","src-062"],"entity_ids":["wirecard","ocap","kpmg","lg-muenchen"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Munich I regional court put the damage from the OCAP loan at EUR 40 million, because EUR 60 million had been repaid from the bond subscription and the borrower was insolvent; it found the loan negligent mainly because of arrears of EUR 2.375 million on another loan and because, after KPMG's special audit, it was uncertain whether the third-party acquiring business closely linked to the loan existed. The bond subscription of EUR 100 million was made without financial due diligence and against a lawyer's advice, and the full amount was lost because the issuer was insolvent; loans of EUR 115 million had been granted in 2018."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mca-civil-klestil","record":{"id":"c-mca-civil-klestil","kind":"fact","text":"The court dismissed the administrator's claim against former deputy supervisory board chairman Stefan Klestil: although he had neglected his duty of supervision, it doubted that proper supervision would have changed the management board's conduct, since the board had already disregarded the supervisory board's instructions in the past; no criminal offence is alleged against Klestil.","source_ids":["src-062"],"entity_ids":["klestil","jaffe","wirecard","lg-muenchen"],"qualification":"","response":"","outcome":""},"reading":"Fact: The court dismissed the administrator's claim against former deputy supervisory board chairman Stefan Klestil: although he had neglected his duty of supervision, it doubted that proper supervision would have changed the management board's conduct, since the board had already disregarded the supervisory board's instructions in the past; no criminal offence is alleged against Klestil."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mca-wah-loans","record":{"id":"c-mca-wah-loans","kind":"fact","text":"The Munich higher regional court's press release of 28 February 2025 lists among the counts in the criminal case one of breach of trust through consent to loans by Wirecard Asia Holding Pte. Ltd. to OCAP Management Pte. Ltd. in September 2018, or aiding it; prosecution of this count was discontinued on 27 February 2025.","source_ids":["src-055"],"entity_ids":["wd-asia-holding","ocap","olg-muenchen"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Munich higher regional court's press release of 28 February 2025 lists among the counts in the criminal case one of breach of trust through consent to loans by Wirecard Asia Holding Pte. Ltd. to OCAP Management Pte. Ltd. in September 2018, or aiding it; prosecution of this count was discontinued on 27 February 2025."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-petition","record":{"id":"c-ins-petition","kind":"fact","text":"Wirecard AG applied on 25 June 2020 to open insolvency proceedings over its own assets, citing impending insolvency and over-indebtedness. On 29 June 2020 the Munich local court (insolvency court, case 1542 IN 1308/20) appointed the lawyer Dr. Michael Jaffé (Munich) as preliminary insolvency administrator, ordered that the debtor's dispositions required his consent and prohibited enforcement against the debtor, confirming an order of 25 June 2020.","source_ids":["src-009","src-002","src-025"],"entity_ids":["wirecard","jaffe","ag-muenchen"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard AG applied on 25 June 2020 to open insolvency proceedings over its own assets, citing impending insolvency and over-indebtedness. On 29 June 2020 the Munich local court (insolvency court, case 1542 IN 1308/20) appointed the lawyer Dr. Michael Jaffé (Munich) as preliminary insolvency administrator, ordered that the debtor's dispositions required his consent and prohibited enforcement against the debtor, confirming an order of 25 June 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-opening","record":{"id":"c-ins-opening","kind":"fact","text":"The Munich local court opened insolvency proceedings over Wirecard AG on 25 August 2020 (1542 IN 1308/20), dissolving the company, and appointed Michael Jaffé insolvency administrator of Wirecard AG and of Wirecard Technologies GmbH, Wirecard Issuing Technologies GmbH, Wirecard Service Technologies GmbH, Wirecard Acceptance Technologies GmbH, Wirecard Sales International Holding GmbH and Wirecard Global Sales GmbH. Register entries record the openings for the subsidiaries under case numbers 1542 IN 1351/20 to 1356/20 and the lapse of the remaining powers of attorney; the register shows Wirecard AG in liquidation from 4 September 2020.","source_ids":["src-026","src-002","src-014","src-018","src-041","src-042","src-043","src-015","src-001"],"entity_ids":["wirecard","jaffe","wd-tech","wd-issuing-tech","wd-service-tech","wd-acceptance-tech","wd-sih","wd-global-sales","ag-muenchen"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["wirecard","wd-tech","wd-issuing-tech","wd-service-tech","wd-acceptance-tech","wd-sih","wd-global-sales"]},"reading":"Fact: The Munich local court opened insolvency proceedings over Wirecard AG on 25 August 2020 (1542 IN 1308/20), dissolving the company, and appointed Michael Jaffé insolvency administrator of Wirecard AG and of Wirecard Technologies GmbH, Wirecard Issuing Technologies GmbH, Wirecard Service Technologies GmbH, Wirecard Acceptance Technologies GmbH, Wirecard Sales International Holding GmbH and Wirecard Global Sales GmbH. Register entries record the openings for the subsidiaries under case numbers 1542 IN 1351/20 to 1356/20 and the lapse of the remaining powers of attorney; the register shows Wirecard AG in liquidation from 4 September 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-comm-services","record":{"id":"c-ins-comm-services","kind":"fact","text":"The Leipzig local court opened insolvency proceedings over Wirecard Communication Services GmbH on 31 August 2020 (403 IN 960/20), dissolving the company; the powers of attorney of Thorsten Holten, Andrea Görres and Daniel Steinhoff lapsed.","source_ids":["src-019"],"entity_ids":["wd-comm-services","holten","goerres","steinhoff"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["wd-comm-services"]},"reading":"Fact: The Leipzig local court opened insolvency proceedings over Wirecard Communication Services GmbH on 31 August 2020 (403 IN 960/20), dissolving the company; the powers of attorney of Thorsten Holten, Andrea Görres and Daniel Steinhoff lapsed."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-staff","record":{"id":"c-ins-staff","kind":"fact","text":"In early July 2020 Wirecard filed for insolvency of six further German service subsidiaries with 1,270 employees, which the administrator wanted to continue where possible; Wirecard AG itself had 250 employees. After the opening of the proceedings, about 730 jobs were cut, while 570 staff in Aschheim, 350 of them in the insolvent companies and 220 at the solvent Wirecard Bank AG, kept their jobs, according to the administrator.","source_ids":["src-076","src-048"],"entity_ids":["wirecard","jaffe","wd-bank"],"qualification":"","response":"","outcome":""},"reading":"Fact: In early July 2020 Wirecard filed for insolvency of six further German service subsidiaries with 1,270 employees, which the administrator wanted to continue where possible; Wirecard AG itself had 250 employees. After the opening of the proceedings, about 730 jobs were cut, while 570 staff in Aschheim, 350 of them in the insolvent companies and 220 at the solvent Wirecard Bank AG, kept their jobs, according to the administrator."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-moelis","record":{"id":"c-ins-moelis","kind":"fact","text":"On 5 July 2020 the management of Wirecard Acquiring & Issuing GmbH, in agreement with its shareholder Wirecard AG and the preliminary administrator, engaged the US investment bank Moelis & Company to run the sale of Wirecard North America.","source_ids":["src-048"],"entity_ids":["wd-acq-iss","wirecard","moelis","wd-north-america"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 5 July 2020 the management of Wirecard Acquiring & Issuing GmbH, in agreement with its shareholder Wirecard AG and the preliminary administrator, engaged the US investment bank Moelis & Company to run the sale of Wirecard North America."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-santander","record":{"id":"c-ins-santander","kind":"fact","text":"The sale of the core assets of Wirecard AG and Wirecard Technologies GmbH, the European technology platform, to the Banco Santander group closed on 28 January 2021 after signing in mid-November 2020; about 500 employees moved to Santander's Getnet platform. The administrator had earlier sold Wirecard North America to Syncapay, Wirecard Brazil to PagSeguro and Wirecard Romania to SIBS.","source_ids":["src-029"],"entity_ids":["wirecard","wd-tech","santander","jaffe","wd-north-america","syncapay","wd-brazil","pagseguro","wd-romania","sibs"],"qualification":"","response":"","outcome":""},"reading":"Fact: The sale of the core assets of Wirecard AG and Wirecard Technologies GmbH, the European technology platform, to the Banco Santander group closed on 28 January 2021 after signing in mid-November 2020; about 500 employees moved to Santander's Getnet platform. The administrator had earlier sold Wirecard North America to Syncapay, Wirecard Brazil to PagSeguro and Wirecard Romania to SIBS."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-brazil-railsbank","record":{"id":"c-ins-brazil-railsbank","kind":"fact","text":"Wirecard announced in 2020 that an agreement had been signed under which a subsidiary of PagSeguro Digital Ltd. (listed in New York) would acquire 100% of Wirecard Brazil, subject to approval by Brazilian regulators, and that Wirecard Card Solutions Ltd. had agreed in principle with Railsbank Technology Limited to sell certain customer relationships and other assets.","source_ids":["src-048"],"entity_ids":["wirecard","wd-brazil","pagseguro","wd-card-solutions","railsbank"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard announced in 2020 that an agreement had been signed under which a subsidiary of PagSeguro Digital Ltd. (listed in New York) would acquire 100% of Wirecard Brazil, subject to approval by Brazilian regulators, and that Wirecard Card Solutions Ltd. had agreed in principle with Railsbank Technology Limited to sell certain customer relationships and other assets."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-romania","record":{"id":"c-ins-romania","kind":"fact","text":"On 28 September 2020 the administrator closed the sale of all shares in Wirecard Romania SA, held by Wirecard Sales International Holding GmbH, to the payment provider SIBS, together with its subsidiaries Romcard and Supercard Solutions & Services; PT Prima Vista Solusi, PT Wirecard Technologies Indonesia and Wirecard (Vietnam) Company Limited were then in advanced auction processes. Wirecard Sales International Holding GmbH held the group's international subsidiaries, including those in Asia.","source_ids":["src-046","src-048"],"entity_ids":["wd-romania","wd-sih","sibs","romcard","supercard","prima-vista","wd-indonesia","wd-vietnam","jaffe","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 28 September 2020 the administrator closed the sale of all shares in Wirecard Romania SA, held by Wirecard Sales International Holding GmbH, to the payment provider SIBS, together with its subsidiaries Romcard and Supercard Solutions & Services; PT Prima Vista Solusi, PT Wirecard Technologies Indonesia and Wirecard (Vietnam) Company Limited were then in advanced auction processes. Wirecard Sales International Holding GmbH held the group's international subsidiaries, including those in Asia."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-cee","record":{"id":"c-ins-cee","kind":"fact","text":"The business of the Austrian Wirecard Central Eastern Europe GmbH was sold with the insolvency court's approval to the best bidder, AURIN Investment Group GmbH (Frankfurt), with effect from 30 September 2020, according to its insolvency administrator Dr. Ulla Reisch.","source_ids":["src-035"],"entity_ids":["wd-cee","aurin","reisch"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["wd-cee"]},"reading":"Fact: The business of the Austrian Wirecard Central Eastern Europe GmbH was sold with the insolvency court's approval to the best bidder, AURIN Investment Group GmbH (Frankfurt), with effect from 30 September 2020, according to its insolvency administrator Dr. Ulla Reisch."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-turkey","record":{"id":"c-ins-turkey","kind":"fact","text":"On 30 March 2021 the administrator announced the sale of the indirect Turkish subsidiary Wirecard Ödeme ve Elektronik Para Hizmetleri to Nomu Pay, a newly formed Irish company of the financial investor Finch Capital, subject to approval by local supervisors; the creditors' committee approved the deal.","source_ids":["src-045"],"entity_ids":["wd-turkey","nomu-pay","jaffe","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 30 March 2021 the administrator announced the sale of the indirect Turkish subsidiary Wirecard Ödeme ve Elektronik Para Hizmetleri to Nomu Pay, a newly formed Irish company of the financial investor Finch Capital, subject to approval by local supervisors; the creditors' committee approved the deal."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-asia-sales","record":{"id":"c-ins-asia-sales","kind":"fact","text":"On 16 April 2021 the administrator announced the sale of the shares in Wirecard e-Money Philippines, Wirecard Payment Solutions Malaysia, Wirecard (Thailand) and Wirecard Payment Solutions Hong Kong to Nomu Pay Ltd, owned by Finch Capital, including assets and licences linked to the data centre of Wirecard Asia Holding and Wirecard Singapore, and of PT Wirecard Technologies Indonesia (about 360 staff) to the technology holding company of an Indonesian group; Wirecard Australia A&I Pty Ltd. had earlier been sold to an Australian payment provider.","source_ids":["src-026"],"entity_ids":["jaffe","wd-emoney-ph","wd-ps-malaysia","wd-thailand","wd-ps-hk","nomu-pay","wd-asia-holding","wd-singapore","wd-indonesia","wd-australia-ai","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 16 April 2021 the administrator announced the sale of the shares in Wirecard e-Money Philippines, Wirecard Payment Solutions Malaysia, Wirecard (Thailand) and Wirecard Payment Solutions Hong Kong to Nomu Pay Ltd, owned by Finch Capital, including assets and licences linked to the data centre of Wirecard Asia Holding and Wirecard Singapore, and of PT Wirecard Technologies Indonesia (about 360 staff) to the technology holding company of an Indonesian group; Wirecard Australia A&I Pty Ltd. had earlier been sold to an Australian payment provider."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-status","record":{"id":"c-ins-status","kind":"fact","text":"The administrator's law firm describes the proceedings as continuing: by mid-2021 the core acquiring and issuing business and the valuable foreign subsidiaries had been sold for a total in the \"high three-digit millions\" for the estates, about 2,700 jobs had been preserved, and claims for damages were being pursued against those involved in many jurisdictions.","source_ids":["src-028"],"entity_ids":["jaffe","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: The administrator's law firm describes the proceedings as continuing: by mid-2021 the core acquiring and issuing business and the valuable foreign subsidiaries had been sold for a total in the \"high three-digit millions\" for the estates, about 2,700 jobs had been preserved, and claims for damages were being pursued against those involved in many jurisdictions."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-irish","record":{"id":"c-ins-irish","kind":"fact","text":"Irish filings show that Wirecard UK and Ireland Limited is being wound up by the court, with a court order dated 28 October 2020, a change of directors on 8 July 2020 and liquidator's reports from 2021 to April 2026.","source_ids":["src-064"],"entity_ids":["wd-uki"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["wd-uki"]},"reading":"Fact: Irish filings show that Wirecard UK and Ireland Limited is being wound up by the court, with a court order dated 28 October 2020, a change of directors on 8 July 2020 and liquidator's reports from 2021 to April 2026."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-claims","record":{"id":"c-ins-claims","kind":"fact","text":"According to the Federal Court of Justice, about 50,000 Wirecard AG shareholders filed damage claims of about EUR 8.5 billion arising from their share purchases; claims filed in total amount to about EUR 15.4 billion, including those of bondholders of EUR 500 million, against an estate of about EUR 650 million.","source_ids":["src-056"],"entity_ids":["wirecard","bgh","jaffe"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the Federal Court of Justice, about 50,000 Wirecard AG shareholders filed damage claims of about EUR 8.5 billion arising from their share purchases; claims filed in total amount to about EUR 15.4 billion, including those of bondholders of EUR 500 million, against an estate of about EUR 650 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-bgh-shareholders","record":{"id":"c-ins-bgh-shareholders","kind":"fact","text":"On 13 November 2025 the Federal Court of Justice (IX ZR 127/24) ruled that shareholders of an insolvent stock corporation cannot share in the distribution of the estate as ordinary insolvency creditors with their capital-market damage claims; it set aside a Munich higher regional court judgment of 17 September 2024 to that extent and restored the Munich I regional court's dismissal of 23 November 2022 (29 O 7754/21, amount in dispute EUR 2,525,414.93).","source_ids":["src-056","src-051"],"entity_ids":["bgh","wirecard","lg-muenchen"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 13 November 2025 the Federal Court of Justice (IX ZR 127/24) ruled that shareholders of an insolvent stock corporation cannot share in the distribution of the estate as ordinary insolvency creditors with their capital-market damage claims; it set aside a Munich higher regional court judgment of 17 September 2024 to that extent and restored the Munich I regional court's dismissal of 23 November 2022 (29 O 7754/21, amount in dispute EUR 2,525,414.93)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-annulment","record":{"id":"c-ins-annulment","kind":"fact","text":"On 5 May 2022 the 5th commercial chamber of the Munich I regional court declared Wirecard AG's annual accounts for 2017 and 2018 void (5 HK O 15710/20).","source_ids":["src-051"],"entity_ids":["lg-muenchen","wirecard"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["wirecard"]},"reading":"Fact: On 5 May 2022 the 5th commercial chamber of the Munich I regional court declared Wirecard AG's annual accounts for 2017 and 2018 void (5 HK O 15710/20)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-ins-court-volume","record":{"id":"c-ins-court-volume","kind":"fact","text":"The Munich I regional court reported that 2,251 Wirecard-related cases reached it from mid-2019 to 31 December 2022. Wirecard AG's action against the Financial Times and its reporter (39 O 4017/19, filed 22 March 2019) was interrupted by the claimant's insolvency in September 2020 and withdrawn on 28 October 2020.","source_ids":["src-051"],"entity_ids":["lg-muenchen","wirecard","ft"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Munich I regional court reported that 2,251 Wirecard-related cases reached it from mid-2019 to 31 December 2022. Wirecard AG's action against the Financial Times and its reporter (39 O 4017/19, filed 22 March 2019) was interrupted by the claimant's insolvency in September 2020 and withdrawn on 28 October 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-crim-indictment-2022","record":{"id":"c-crim-indictment-2022","kind":"attributed","text":"On 10 March 2022 the Munich I public prosecutor charged \"Dr. B.\" (former CEO of Wirecard AG), \"von E.\" (former head of accounting) and \"B.\" (former managing director of CardSystems Middle East, a Dubai-based second-tier subsidiary of Wirecard AG) before the 4th criminal chamber (commercial crime) of the Munich I regional court in a 474-page indictment; two of the three were in pre-trial detention. A later press report on the trial names the defendants as Markus Braun, Stephan von Erffa and Oliver Bellenhaus.","source_ids":["src-038","src-051","src-054"],"entity_ids":["sta-muenchen","braun","von-erffa","bellenhaus","cardsystems-me","wirecard","lg-muenchen"],"qualification":"The indictment states the prosecution's case, which the court has to establish; the release abbreviates the defendants' names.","response":"","outcome":"The trial began on 8 December 2022; in May 2026 the court set further hearing dates up to 23 December 2026, and no judgment had been announced by the cutoff.","adverse_subject_ids":["braun","von-erffa","bellenhaus"]},"reading":"Attributed: On 10 March 2022 the Munich I public prosecutor charged \"Dr. B.\" (former CEO of Wirecard AG), \"von E.\" (former head of accounting) and \"B.\" (former managing director of CardSystems Middle East, a Dubai-based second-tier subsidiary of Wirecard AG) before the 4th criminal chamber (commercial crime) of the Munich I regional court in a 474-page indictment; two of the three were in pre-trial detention. A later press report on the trial names the defendants as Markus Braun, Stephan von Erffa and Oliver Bellenhaus."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-crim-charges-accounts","record":{"id":"c-crim-charges-accounts","kind":"attributed","text":"The prosecution's case is that Wirecard's consolidated accounts for 2015 to 2018 were false because they included revenue said to come from TPA business with three partners in Dubai, the Philippines and Singapore, which was booked as receivables from the partners or as balances on trust accounts in Singapore but did not exist; a balance of almost one billion euros (2018) supposedly managed by a trustee \"C.\" in Singapore never existed, and balance confirmations were forged by the trustee or by the accused \"B.\" on the instructions of \"von E.\".","source_ids":["src-038","src-060"],"entity_ids":["sta-muenchen","wirecard","citadelle","bellenhaus","von-erffa","braun","marsalek"],"qualification":"Prosecution allegations; at the evidence cutoff the trial had not reached a verdict.","response":"Braun's defence in the trial was that the TPA business existed and its proceeds were embezzled by Jan Marsalek's circle; the presiding judge called this unsupported in September 2026 (see the trial).","outcome":"","adverse_subject_ids":["braun","von-erffa","bellenhaus"]},"reading":"Attributed: The prosecution's case is that Wirecard's consolidated accounts for 2015 to 2018 were false because they included revenue said to come from TPA business with three partners in Dubai, the Philippines and Singapore, which was booked as receivables from the partners or as balances on trust accounts in Singapore but did not exist; a balance of almost one billion euros (2018) supposedly managed by a trustee \"C.\" in Singapore never existed, and balance confirmations were forged by the trustee or by the accused \"B.\" on the instructions of \"von E.\"."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-crim-charges-market","record":{"id":"c-crim-charges-market","kind":"attributed","text":"The prosecution accuses \"Dr. B.\" of professional market manipulation, including deciding alone to publish an ad hoc announcement on 22 April 2020 that falsely suggested KPMG's report would clear Wirecard of all allegations of balance-sheet manipulation; in total the indictment lists 26 counts of market manipulation for 1 January 2015 to 27 April 2019. It says that part of his pay was linked to the share price and that he personally held a substantial share of the capital, latterly about 7%, receiving dividends of about EUR 5.5 million in total.","source_ids":["src-038"],"entity_ids":["sta-muenchen","braun","wirecard","kpmg"],"qualification":"Prosecution allegations; the court later dropped the market-manipulation counts (see the restriction of February 2025).","response":"","outcome":""},"reading":"Attributed: The prosecution accuses \"Dr. B.\" of professional market manipulation, including deciding alone to publish an ad hoc announcement on 22 April 2020 that falsely suggested KPMG's report would clear Wirecard of all allegations of balance-sheet manipulation; in total the indictment lists 26 counts of market manipulation for 1 January 2015 to 27 April 2019. It says that part of his pay was linked to the share price and that he personally held a substantial share of the capital, latterly about 7%, receiving dividends of about EUR 5.5 million in total."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-crim-charges-fraud","record":{"id":"c-crim-charges-fraud","kind":"attributed","text":"The prosecution charges six counts of professional gang fraud: banks that believed they were dealing with a successful and creditworthy DAX company paid out four loans of about EUR 1.7 billion, and two bonds of about EUR 1.4 billion were issued, on the basis of figures that included non-existent receivables from TPA partners and trust account balances.","source_ids":["src-038"],"entity_ids":["sta-muenchen","wirecard"],"qualification":"Prosecution allegations; the banks are not named in the release.","response":"","outcome":""},"reading":"Attributed: The prosecution charges six counts of professional gang fraud: banks that believed they were dealing with a successful and creditworthy DAX company paid out four loans of about EUR 1.7 billion, and two bonds of about EUR 1.4 billion were issued, on the basis of figures that included non-existent receivables from TPA partners and trust account balances."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-crim-trial","record":{"id":"c-crim-trial","kind":"fact","text":"The main trial before the 4th (grand) criminal chamber of the Munich I regional court (4 KLs 402 Js 108194/22) began on 8 December 2022. On 27 February 2025 the chamber, at its own suggestion and with the prosecutor's agreement, limited the case (§§ 154(2), 154a(2) of the Code of Criminal Procedure); for the remaining counts of breach of trust and fraud each carries up to ten years and an aggregate sentence up to fifteen years. The discontinued counts include false 2015 consolidated accounts, guarantees by Wirecard AG for Wirecard Bank AG loans to OCAP Management Pte. Ltd. (December 2017 and April 2019), Wirecard Asia Holding loans to OCAP (September 2018), fraud in extending and increasing the syndicated loan led by \"C. AG\" on 21 March 2016 (EUR 725 million) and 15 February 2017 (EUR 1 billion), fraud in issuing the EUR 500 million bond (ISIN DE000A2YNQ58) and 26 counts of market manipulation through the 2015–2019 accounts.","source_ids":["src-051","src-055"],"entity_ids":["lg-muenchen","braun","sta-muenchen","wirecard","wd-bank","ocap","wd-asia-holding"],"qualification":"","response":"","outcome":""},"reading":"Fact: The main trial before the 4th (grand) criminal chamber of the Munich I regional court (4 KLs 402 Js 108194/22) began on 8 December 2022. On 27 February 2025 the chamber, at its own suggestion and with the prosecutor's agreement, limited the case (§§ 154(2), 154a(2) of the Code of Criminal Procedure); for the remaining counts of breach of trust and fraud each carries up to ten years and an aggregate sentence up to fifteen years. The discontinued counts include false 2015 consolidated accounts, guarantees by Wirecard AG for Wirecard Bank AG loans to OCAP Management Pte. Ltd. (December 2017 and April 2019), Wirecard Asia Holding loans to OCAP (September 2018), fraud in extending and increasing the syndicated loan led by \"C. AG\" on 21 March 2016 (EUR 725 million) and 15 February 2017 (EUR 1 billion), fraud in issuing the EUR 500 million bond (ISIN DE000A2YNQ58) and 26 counts of market manipulation through the 2015–2019 accounts."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-crim-trial-2026","record":{"id":"c-crim-trial-2026","kind":"fact","text":"Press releases of the Munich higher regional court show the criminal case against \"Dr. Markus B. and others\" continuing in 2026: on 26 May 2026 the presiding judge set hearing dates up to 23 December 2026, stating that this allowed no conclusion about when the trial would end, and on 19 June 2026 the court published the next hearing dates after a move of premises; no judgment had been announced.","source_ids":["src-054","src-039"],"entity_ids":["olg-muenchen","lg-muenchen","braun"],"qualification":"","response":"","outcome":""},"reading":"Fact: Press releases of the Munich higher regional court show the criminal case against \"Dr. Markus B. and others\" continuing in 2026: on 26 May 2026 the presiding judge set hearing dates up to 23 December 2026, stating that this allowed no conclusion about when the trial would end, and on 19 June 2026 the court published the next hearing dates after a move of premises; no judgment had been announced."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-crim-judge-2026","record":{"id":"c-crim-judge-2026","kind":"attributed","text":"According to a press report of 14 September 2026, presiding judge Markus Födisch said in the trial (4 KLs 402 Js 108194/22) that there were \"no indications whatsoever\" that the TPA business with partners in Dubai, Singapore and the Philippines existed, and called Braun's account that the profits had been embezzled by Jan Marsalek's circle untenable \"speculation\"; Braun had then been in pre-trial detention without interruption since July 2020. The judge formally warned the three defendants that proceeds could be confiscated if they were convicted: almost EUR 39 million in Braun's case, most of it held by his personal investment company, more than EUR 6 million for the key prosecution witness Oliver Bellenhaus, who had confirmed the indictment in its essential points, and more than EUR 600,000 for the former chief accountant Stephan von Erffa.","source_ids":["src-060"],"entity_ids":["lg-muenchen","braun","marsalek","bellenhaus","von-erffa"],"qualification":"Statements by the presiding judge during the trial as reported in the press; they are not a judgment, and the defendants are presumed innocent until a final verdict.","response":"Braun maintains that the TPA business existed and that its proceeds were embezzled by others.","outcome":""},"reading":"Attributed: According to a press report of 14 September 2026, presiding judge Markus Födisch said in the trial (4 KLs 402 Js 108194/22) that there were \"no indications whatsoever\" that the TPA business with partners in Dubai, Singapore and the Philippines existed, and called Braun's account that the profits had been embezzled by Jan Marsalek's circle untenable \"speculation\"; Braun had then been in pre-trial detention without interruption since July 2020. The judge formally warned the three defendants that proceeds could be confiscated if they were convicted: almost EUR 39 million in Braun's case, most of it held by his personal investment company, more than EUR 6 million for the key prosecution witness Oliver Bellenhaus, who had confirmed the indictment in its essential points, and more than EUR 600,000 for the former chief accountant Stephan von Erffa."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-crim-ley","record":{"id":"c-crim-ley","kind":"attributed","text":"On 12 December 2023 the Munich I prosecutor indicted the former chief financial officer of Wirecard AG, \"L.\", for misrepresentation, market manipulation, professional gang fraud, breach of trust and aiding these offences: he is accused of having joined Dr. Braun, \"von E.\", \"B.\" and \"M.\" in simulating the TPA business, of signing the 2015 and 2016 accounts as CFO, of acting as a perpetrator in 2015–2017 and, after leaving on 1 January 2018, of aiding the others with advice, and of breach of trust through Wirecard AG's guarantee of a Wirecard Bank MCA loan to a Singapore company.","source_ids":["src-053"],"entity_ids":["sta-muenchen","ley","wirecard","braun","wd-bank"],"qualification":"Prosecution allegations; the release abbreviates the name, and the description matches Burkhard Ley, finance director until 31 December 2017. The 12th commercial crime chamber was to decide whether to open the trial; no decision is in the record.","response":"","outcome":"According to the prosecutor, the 12th commercial crime chamber of the Munich I regional court was to decide whether to open the trial; no decision is in the record.","adverse_subject_ids":["ley"]},"reading":"Attributed: On 12 December 2023 the Munich I prosecutor indicted the former chief financial officer of Wirecard AG, \"L.\", for misrepresentation, market manipulation, professional gang fraud, breach of trust and aiding these offences: he is accused of having joined Dr. Braun, \"von E.\", \"B.\" and \"M.\" in simulating the TPA business, of signing the 2015 and 2016 accounts as CFO, of acting as a perpetrator in 2015–2017 and, after leaving on 1 January 2018, of aiding the others with advice, and of breach of trust through Wirecard AG's guarantee of a Wirecard Bank MCA loan to a Singapore company."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-crim-knoop-steidl","record":{"id":"c-crim-knoop-steidl","kind":"attributed","text":"On 31 July 2024 the Munich I prosecutor indicted two further former Wirecard AG board members, \"von K.\" (finance) for several counts of breach of trust and aiding breach of trust and \"S.\" (product development) for several counts of breach of trust, concerning the December 2019 security deposit and the OCAP loans; the 12th commercial crime chamber of the Munich I regional court was to decide whether to open the trial.","source_ids":["src-052"],"entity_ids":["sta-muenchen","von-knoop","steidl","wirecard","ocap","ruprecht"],"qualification":"Prosecution allegations; the release abbreviates the names, and the posts match Alexander von Knoop and Susanne Steidl. No decision on opening the trial is in the record.","response":"","outcome":"","adverse_subject_ids":["von-knoop","steidl"]},"reading":"Attributed: On 31 July 2024 the Munich I prosecutor indicted two further former Wirecard AG board members, \"von K.\" (finance) for several counts of breach of trust and aiding breach of trust and \"S.\" (product development) for several counts of breach of trust, concerning the December 2019 security deposit and the OCAP loans; the 12th commercial crime chamber of the Munich I regional court was to decide whether to open the trial."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-crim-marsalek-wanted","record":{"id":"c-crim-marsalek-wanted","kind":"fact","text":"The Munich I public prosecutor is investigating Jan Marsalek on suspicion of professional gang fraud, aggravated breach of trust and other financial and economic offences; the Federal Criminal Police Office (BKA) and Munich police have issued a public appeal for his arrest and consider it very likely that he is abroad. The BKA also states that he is suspected of having bought shares in a company at an inflated price, contrary to his duties to the Wirecard group, damaging its assets.","source_ids":["src-003"],"entity_ids":["sta-muenchen","bka","marsalek","wirecard"],"qualification":"Suspicions, not charges proved in court; Marsalek has not been tried.","response":"","outcome":"","adverse_subject_ids":["marsalek"]},"reading":"Fact: The Munich I public prosecutor is investigating Jan Marsalek on suspicion of professional gang fraud, aggravated breach of trust and other financial and economic offences; the Federal Criminal Police Office (BKA) and Munich police have issued a public appeal for his arrest and consider it very likely that he is abroad. The BKA also states that he is suspected of having bought shares in a company at an inflated price, contrary to his duties to the Wirecard group, damaging its assets."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-crim-von-erffa-admission","record":{"id":"c-crim-von-erffa-admission","kind":"attributed","text":"According to a July 2022 press report based on another newspaper's information from people familiar with the matter, Stephan von Erffa admitted to prosecutors that in early 2020 he had fabricated, after the event, an e-mail and a trustee request form for the EUR 50 million transfer Wirecard received in 2018 supposedly from an Asian trust account, documents that were passed to KPMG and EY; he called the forgery a one-off. According to the prosecutors as reported, the EUR 50 million came from an Asian partner that had borrowed EUR 100 million from Wirecard and returned half through a chain of opaque companies.","source_ids":["src-067"],"entity_ids":["von-erffa","kpmg","ey","wirecard","sta-muenchen"],"qualification":"Second-hand press account of an admission and of investigators' findings; no court finding.","response":"","outcome":"","adverse_subject_ids":["von-erffa"]},"reading":"Attributed: According to a July 2022 press report based on another newspaper's information from people familiar with the matter, Stephan von Erffa admitted to prosecutors that in early 2020 he had fabricated, after the event, an e-mail and a trustee request form for the EUR 50 million transfer Wirecard received in 2018 supposedly from an Asian trust account, documents that were passed to KPMG and EY; he called the forgery a one-off. According to the prosecutors as reported, the EUR 50 million came from an Asian partner that had borrowed EUR 100 million from Wirecard and returned half through a chain of opaque companies."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-crim-holten","record":{"id":"c-crim-holten","kind":"fact","text":"The Munich I prosecutor closed its investigation into Wirecard's former treasurer Thorsten Holten, as his defence lawyer confirmed in July 2024, saying the accusations had proved entirely false; the reported source does not give the legal basis for the closure.","source_ids":["src-061"],"entity_ids":["sta-muenchen","holten","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Munich I prosecutor closed its investigation into Wirecard's former treasurer Thorsten Holten, as his defence lawyer confirmed in July 2024, saying the accusations had proved entirely false; the reported source does not give the legal basis for the closure."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-crim-matthias","record":{"id":"c-crim-matthias","kind":"attributed","text":"A newspaper reported on 21 May 2021, citing an e-mail from his lawyer to the Bundestag committee of inquiry, that the Munich prosecutor had formally opened an investigation into former supervisory board chairman Wulf Matthias, among other former supervisory board members, following complaints by investors (case 402 Js 199828/20); An FDP deputy suggested the investigation might concern breach of trust by omitting required controls, while stressing the presumption of innocence.","source_ids":["src-074"],"entity_ids":["matthias","sta-muenchen","wirecard","bundestag"],"qualification":"Opening of an investigation as reported by a newspaper; no charge or outcome is recorded.","response":"Through his lawyer, Matthias told the committee that he would make use of his comprehensive right to remain silent.","outcome":"","adverse_subject_ids":["matthias"]},"reading":"Attributed: A newspaper reported on 21 May 2021, citing an e-mail from his lawyer to the Bundestag committee of inquiry, that the Munich prosecutor had formally opened an investigation into former supervisory board chairman Wulf Matthias, among other former supervisory board members, following complaints by investors (case 402 Js 199828/20); An FDP deputy suggested the investigation might concern breach of trust by omitting required controls, while stressing the presumption of innocence."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-crim-bundestag-witnesses","record":{"id":"c-crim-bundestag-witnesses","kind":"fact","text":"At the Bundestag inquiry committee's session of 19 November 2020, Dr. Markus Braun invoked his right not to incriminate himself, said the courts should establish where the embezzled company funds had gone and announced a detailed statement to the Munich prosecutor; Oliver Bellenhaus, who had run the group's card-payment subsidiary in the Middle East and joined from prison, also declined to answer, but described events as a \"huge catastrophe\" and apologised to those harmed.","source_ids":["src-079"],"entity_ids":["braun","bellenhaus","bundestag","cardsystems-me","sta-muenchen"],"qualification":"","response":"","outcome":""},"reading":"Fact: At the Bundestag inquiry committee's session of 19 November 2020, Dr. Markus Braun invoked his right not to incriminate himself, said the courts should establish where the embezzled company funds had gone and announced a detailed statement to the Munich prosecutor; Oliver Bellenhaus, who had run the group's card-payment subsidiary in the Middle East and joined from prison, also declined to answer, but described events as a \"huge catastrophe\" and apologised to those harmed."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-crim-haeuser-axtner","record":{"id":"c-crim-haeuser-axtner","kind":"fact","text":"The Singapore Police Force stated on 31 March 2026 that Germany had requested the provisional arrest of Brigitte Häuser-Axtner on 24 October 2025, that a Singapore court issued a warrant on 3 November 2025, that she was arrested on 4 November 2025, that a formal extradition request followed on 24 December 2025 and that she consented to extradition on 10 February 2026; she was extradited to Germany on 30 March 2026, where she was wanted on suspicion of involvement in a criminal organisation, computer fraud and money laundering connected with the Wirecard group. At the time of her arrest she worked for an unrelated Singapore company.","source_ids":["src-085","src-081"],"entity_ids":["spf","haeuser-axtner","wirecard","wd-asia-holding"],"qualification":"Suspicions stated in the extradition proceedings; Singapore police said she was not accused of offences in Singapore.","response":"","outcome":"","adverse_subject_ids":["haeuser-axtner"]},"reading":"Fact: The Singapore Police Force stated on 31 March 2026 that Germany had requested the provisional arrest of Brigitte Häuser-Axtner on 24 October 2025, that a Singapore court issued a warrant on 3 November 2025, that she was arrested on 4 November 2025, that a formal extradition request followed on 24 December 2025 and that she consented to extradition on 10 February 2026; she was extradited to Germany on 30 March 2026, where she was wanted on suspicion of involvement in a criminal organisation, computer fraud and money laundering connected with the Wirecard group. At the time of her arrest she worked for an unrelated Singapore company."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mar-career","record":{"id":"c-mar-career","kind":"fact","text":"According to the Federal Criminal Police Office (BKA), Jan Marsalek worked at Wirecard AG from January 2000 as a project manager for payment systems and was a member of the management board from February 2010 to June 2020; as chief operating officer he was responsible for all operations including sales and, from at least 2015, chiefly for the Asian business and the TPA business.","source_ids":["src-003"],"entity_ids":["marsalek","wirecard","bka"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the Federal Criminal Police Office (BKA), Jan Marsalek worked at Wirecard AG from January 2000 as a project manager for payment systems and was a member of the management board from February 2010 to June 2020; as chief operating officer he was responsible for all operations including sales and, from at least 2015, chiefly for the Asian business and the TPA business."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mar-registry","record":{"id":"c-mar-registry","kind":"fact","text":"A registry aggregator links Jan Marsalek in the German register to Click2Pay GmbH, Wirecard AG, Wirecard Global Sales GmbH, Wirecard Sales International Holding GmbH and Wirecard Technologies GmbH and to the deleted Trustpay International AG and Wirecard Technologies AG, without naming his role in each.","source_ids":["src-007"],"entity_ids":["marsalek","click2pay","wirecard","wd-global-sales","wd-sih","wd-tech"],"qualification":"","response":"","outcome":""},"reading":"Fact: A registry aggregator links Jan Marsalek in the German register to Click2Pay GmbH, Wirecard AG, Wirecard Global Sales GmbH, Wirecard Sales International Holding GmbH and Wirecard Technologies GmbH and to the deleted Trustpay International AG and Wirecard Technologies AG, without naming his role in each."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mar-ecredit","record":{"id":"c-mar-ecredit","kind":"fact","text":"An extract from an EY compliance check, reproduced in OCR form in the special investigators' report, records that Jan Marsalek was appointed a director of E-Credit Plus Pte. Ltd., the earlier name of the Singapore company later called Wirecard Asia Pte. Ltd., on 18 March 2010.","source_ids":["src-027"],"entity_ids":["marsalek","wd-asia-pte","ey"],"qualification":"The extract is an optical-character-recognition rendering of an image whose words, including the date, are split across a recognition table; the compliance check's source for the appointment is not given.","response":"","outcome":""},"reading":"Fact: An extract from an EY compliance check, reproduced in OCR form in the special investigators' report, records that Jan Marsalek was appointed a director of E-Credit Plus Pte. Ltd., the earlier name of the Singapore company later called Wirecard Asia Pte. Ltd., on 18 March 2010."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mar-ireland","record":{"id":"c-mar-ireland","kind":"fact","text":"Ireland's Corporate Enforcement Authority reports that the liquidators of Wirecard UK & Ireland Limited recommended disqualifying its two remaining directors, Jan Marsalek (spelt \"Marsalak\"), the company's chief executive and the Wirecard AG group's chief operating officer, and Markus-Konrad Fuchs, its sales director and the group's head of sales and acquiring. Because of the grave nature of the allegations the authority declined to offer them undertakings and instructed the liquidators to seek disqualification in the High Court; Fuchs was disqualified for nine years, while the case against Marsalek was adjourned with liberty to re-enter because he could not be served.","source_ids":["src-044"],"entity_ids":["cea-ireland","wd-uki","marsalek","fuchs","wirecard"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["fuchs","marsalek"]},"reading":"Fact: Ireland's Corporate Enforcement Authority reports that the liquidators of Wirecard UK & Ireland Limited recommended disqualifying its two remaining directors, Jan Marsalek (spelt \"Marsalak\"), the company's chief executive and the Wirecard AG group's chief operating officer, and Markus-Konrad Fuchs, its sales director and the group's head of sales and acquiring. Because of the grave nature of the allegations the authority declined to offer them undertakings and instructed the liquidators to seek disqualification in the High Court; Fuchs was disqualified for nine years, while the case against Marsalek was adjourned with liberty to re-enter because he could not be served."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mar-screening","record":{"id":"c-mar-screening","kind":"fact","text":"A sanctions and wanted-persons database lists Jan Marsalek on the BKA wanted list and on INTERPOL's red notices, with the BKA page as its source; among the alternative names in the record are Alexander Michaelowitsch Nelidov and German Baschenow.","source_ids":["src-004"],"entity_ids":["marsalek","bka"],"qualification":"A screening record that repeats official wanted notices; the alternative names are those recorded in the notices, not names he is known to use lawfully.","response":"","outcome":""},"reading":"Fact: A sanctions and wanted-persons database lists Jan Marsalek on the BKA wanted list and on INTERPOL's red notices, with the BKA page as its source; among the alternative names in the record are Alexander Michaelowitsch Nelidov and German Baschenow."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mar-belarus","record":{"id":"c-mar-belarus","kind":"attributed","text":"An investigation published on 18 July 2020 by an investigative outlet with two partner media, based on Russian and Belarusian border data, reported that Jan Marsalek entered Belarus by private jet in the first minutes of 19 June 2020 and, according to the records, never left; it also reported that, according to Philippine authorities, records of a trip to Manila on 23 June had been a red herring and immigration records had been falsified.","source_ids":["src-075","src-003","src-102"],"entity_ids":["marsalek","bka","bayoblg"],"qualification":"Media findings from leaked border data; no official confirmation is in the record.","response":"","outcome":"He remains wanted: the BKA's notice asks for information on his whereabouts since June 2020, and an order of the Bavarian Supreme Regional Court of May 2024 lists him as of unknown whereabouts.","adverse_subject_ids":["marsalek"]},"reading":"Attributed: An investigation published on 18 July 2020 by an investigative outlet with two partner media, based on Russian and Belarusian border data, reported that Jan Marsalek entered Belarus by private jet in the first minutes of 19 June 2020 and, according to the records, never left; it also reported that, according to Philippine authorities, records of a trip to Manila on 23 June had been a red herring and immigration records had been falsified."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mar-russia-travel","record":{"id":"c-mar-russia-travel","kind":"attributed","text":"The same investigation reported that Marsalek travelled to Russia more than 60 times in ten years and that his Russian migration file runs to 597 pages; that on 15 September 2017 the FSB border service refused to let him leave Moscow on a private jet; that from 2015 to the end of 2018 an FSB database tracked all his international trips except intra-EU travel; and that the file lists a diplomatic passport \"issued to a non-citizen\" (number DA0000051) by an unnamed state.","source_ids":["src-075"],"entity_ids":["marsalek","fsb"],"qualification":"Media findings from leaked Russian records; the outlet interprets the tracking as a special interest of the FSB.","response":"","outcome":"","adverse_subject_ids":["marsalek"]},"reading":"Attributed: The same investigation reported that Marsalek travelled to Russia more than 60 times in ten years and that his Russian migration file runs to 597 pages; that on 15 September 2017 the FSB border service refused to let him leave Moscow on a private jet; that from 2015 to the end of 2018 an FSB database tracked all his international trips except intra-EU travel; and that the file lists a diplomatic passport \"issued to a non-citizen\" (number DA0000051) by an unnamed state."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mar-libya","record":{"id":"c-mar-libya","kind":"attributed","text":"According to the July 2020 investigation, from 2015 Marsalek pursued projects in Libya, including an investment in the Libya Cement Company, and discussed \"humanitarian reconstruction\" plans with Russian advisers and European officials; his adviser on the Libyan initiative was a Russian expert on the Arab world whom, according to the outlet, Western intelligence services believe to be a former senior GRU officer.","source_ids":["src-075"],"entity_ids":["marsalek","libya-cement"],"qualification":"Allegations by an investigative outlet; no response from Marsalek is in the record.","response":"","outcome":"","adverse_subject_ids":["marsalek"]},"reading":"Attributed: According to the July 2020 investigation, from 2015 Marsalek pursued projects in Libya, including an investment in the Libya Cement Company, and discussed \"humanitarian reconstruction\" plans with Russian advisers and European officials; his adviser on the Libyan initiative was a Russian expert on the Arab world whom, according to the outlet, Western intelligence services believe to be a former senior GRU officer."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mar-flight","record":{"id":"c-mar-flight","kind":"attributed","text":"An investigation published on 19 July 2022 by an investigative outlet with a German newspaper reported that a request for special handling of Marsalek at Minsk airport attached a copy of a Grenadian diplomatic passport in his name, although he was not known to hold Grenadian citizenship; that his escape on 18–19 June 2020 was organised by Martin Weiss, a former head of operations of Austria's BVT intelligence agency who had worked with him since 2019, and by the former Freedom Party MP Thomas Schellenbacher, who chartered the private jet; and that Austrian investigators believe another former BVT officer drove him from Germany to Austria.","source_ids":["src-086"],"entity_ids":["marsalek","weiss","schellenbacher"],"qualification":"Media allegations; the record contains no response from the persons named and no court finding on the escape.","response":"","outcome":"","adverse_subject_ids":["marsalek"]},"reading":"Attributed: An investigation published on 19 July 2022 by an investigative outlet with a German newspaper reported that a request for special handling of Marsalek at Minsk airport attached a copy of a Grenadian diplomatic passport in his name, although he was not known to hold Grenadian citizenship; that his escape on 18–19 June 2020 was organised by Martin Weiss, a former head of operations of Austria's BVT intelligence agency who had worked with him since 2019, and by the former Freedom Party MP Thomas Schellenbacher, who chartered the private jet; and that Austrian investigators believe another former BVT officer drove him from Germany to Austria."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mar-russia-identity","record":{"id":"c-mar-russia-identity","kind":"attributed","text":"The same 2022 investigation reported that Marsalek lives in Moscow under round-the-clock FSB protection, acquired Russian citizenship and an internal passport on 10 June 2021 and later changed his identity to that of \"German Bazhenov\"; the outlet could not find this passport in the Russian passport database.","source_ids":["src-086"],"entity_ids":["marsalek","fsb"],"qualification":"Media allegations that the outlet itself could only partly verify.","response":"The outlet notes that Marsalek has consistently denied any links with Russian intelligence.","outcome":"","adverse_subject_ids":["marsalek"]},"reading":"Attributed: The same 2022 investigation reported that Marsalek lives in Moscow under round-the-clock FSB protection, acquired Russian citizenship and an internal passport on 10 June 2021 and later changed his identity to that of \"German Bazhenov\"; the outlet could not find this passport in the Russian passport database."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mar-uk-trial","record":{"id":"c-mar-uk-trial","kind":"fact","text":"In sentencing remarks of 12 May 2025 in R v Roussev and others at the Central Criminal Court (Old Bailey), a case of conspiracy to spy for Russia under the Official Secrets Act 1911, the judge recorded the prosecution's case that the Russian agent using the alias \"Rupert Ticz\" was Jan Marsalek, an Austrian national who fled Germany to avoid arrest for fraud, and that his communications with Orlin Roussev referred to the GRU, FSB and KGB. Roussev's basis of plea did not accept that \"Rupert Ticz\" was Marsalek, while agreeing that this did not matter.","source_ids":["src-037"],"entity_ids":["marsalek","roussev","fsb"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["marsalek"]},"reading":"Fact: In sentencing remarks of 12 May 2025 in R v Roussev and others at the Central Criminal Court (Old Bailey), a case of conspiracy to spy for Russia under the Official Secrets Act 1911, the judge recorded the prosecution's case that the Russian agent using the alias \"Rupert Ticz\" was Jan Marsalek, an Austrian national who fled Germany to avoid arrest for fraud, and that his communications with Orlin Roussev referred to the GRU, FSB and KGB. Roussev's basis of plea did not accept that \"Rupert Ticz\" was Marsalek, while agreeing that this did not matter."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-mar-uk-trial-tasks","record":{"id":"c-mar-uk-trial-tasks","kind":"fact","text":"The sentencing remarks record that on 23 February 2022 Marsalek messaged Roussev that he was applying for EUR 1 million as a \"search and capture budget\" for a target, that there was evidence of substantial cryptocurrency payments from Marsalek to Roussev, and that between July and September 2021 they discussed surveilling the investigative journalist Christo Grozev and kidnapping him and taking him to Moscow.","source_ids":["src-037"],"entity_ids":["marsalek","roussev"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["marsalek"]},"reading":"Fact: The sentencing remarks record that on 23 February 2022 Marsalek messaged Roussev that he was applying for EUR 1 million as a \"search and capture budget\" for a target, that there was evidence of substantial cryptocurrency payments from Marsalek to Roussev, and that between July and September 2021 they discussed surveilling the investigative journalist Christo Grozev and kidnapping him and taking him to Moscow."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-civ-ey-suits","record":{"id":"c-civ-ey-suits","kind":"fact","text":"According to a press release of the Munich I regional court of 27 January 2023, investors began suing the auditor EY for compensation in June 2020; 1,178 such suits had been filed, handled by nine banking chambers. In March 2022 the court initiated an investor model proceeding (Kapitalanleger-Musterverfahren) against EY, conducted by the Bavarian Supreme Regional Court under case number 101 KAP 1/22.","source_ids":["src-051"],"entity_ids":["lg-muenchen","ey","bayoblg"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to a press release of the Munich I regional court of 27 January 2023, investors began suing the auditor EY for compensation in June 2020; 1,178 such suits had been filed, handled by nine banking chambers. In March 2022 the court initiated an investor model proceeding (Kapitalanleger-Musterverfahren) against EY, conducted by the Bavarian Supreme Regional Court under case number 101 KAP 1/22."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-civ-kapmug-parties","record":{"id":"c-civ-kapmug-parties","kind":"fact","text":"An order of the Bavarian Supreme Regional Court of 13 May 2024 records that the Munich I regional court's referral order of 14 March 2022 (3 OH 2767/22) started the model proceeding, and lists eleven model defendants: Markus Braun; EY; four EY auditors who worked on the 2014–2018 audits; Alexander von Knoop; Jan Marsalek, whose whereabouts are unknown; MB Beteiligungsgesellschaft mbH, now represented by its provisional insolvency administrator; Michael Jaffé as insolvency administrator of Wirecard AG; and Oliver Bellenhaus, who headed Wirecard AG's branch in Dubai.","source_ids":["src-102"],"entity_ids":["bayoblg","lg-muenchen","braun","ey","von-knoop","marsalek","mb-beteiligung","jaffe","bellenhaus","wirecard"],"qualification":"The four EY auditors are not named here; the order names them only as further parties to the proceedings.","response":"","outcome":""},"reading":"Fact: An order of the Bavarian Supreme Regional Court of 13 May 2024 records that the Munich I regional court's referral order of 14 March 2022 (3 OH 2767/22) started the model proceeding, and lists eleven model defendants: Markus Braun; EY; four EY auditors who worked on the 2014–2018 audits; Alexander von Knoop; Jan Marsalek, whose whereabouts are unknown; MB Beteiligungsgesellschaft mbH, now represented by its provisional insolvency administrator; Michael Jaffé as insolvency administrator of Wirecard AG; and Oliver Bellenhaus, who headed Wirecard AG's branch in Dubai."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-civ-kapmug-allegations","record":{"id":"c-civ-kapmug-allegations","kind":"attributed","text":"EY audited Wirecard AG for the financial years 2014 to 2018 and gave unqualified opinions on the consolidated financial statements and group management reports for each of those years. According to the facts set out in the referral order, Braun is accused of having misinformed the capital market as chief executive: the consolidated statements for 2014–2018 were allegedly incorrect, required disclosures were not made and untrue ad hoc announcements were published. EY is accused of issuing false audit opinions and of aiding the alleged breaches of disclosure duties.","source_ids":["src-102"],"entity_ids":["ey","wirecard","braun","bayoblg"],"qualification":"These are the claimants' allegations as summarised by the court in a procedural order; the court did not rule on them.","response":"","outcome":"","adverse_subject_ids":["braun","ey"]},"reading":"Attributed: EY audited Wirecard AG for the financial years 2014 to 2018 and gave unqualified opinions on the consolidated financial statements and group management reports for each of those years. According to the facts set out in the referral order, Braun is accused of having misinformed the capital market as chief executive: the consolidated statements for 2014–2018 were allegedly incorrect, required disclosures were not made and untrue ad hoc announcements were published. EY is accused of issuing false audit opinions and of aiding the alleged breaches of disclosure duties."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-civ-kapmug-may2024","record":{"id":"c-civ-kapmug-may2024","kind":"fact","text":"On 13 May 2024 the court issued three orders in the model proceeding. It held that the provisional insolvency administrator of MB Beteiligungsgesellschaft mbH had become the defendant in its place and that the proceeding was interrupted against it, but not against the other ten defendants. It refused to restore EY's former party name after EY's conversion into EY GmbH & Co. KG Wirtschaftsprüfungsgesellschaft (registered on 1 February 2024), rejecting the applicants' argument that the conversion was void for breaching creditor-protection rules. It also refused to sever the proceedings against EY, against MB and against Braun, holding that severance would create two parallel model proceedings with partly identical objectives.","source_ids":["src-090"],"entity_ids":["bayoblg","mb-beteiligung","ey","braun"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 13 May 2024 the court issued three orders in the model proceeding. It held that the provisional insolvency administrator of MB Beteiligungsgesellschaft mbH had become the defendant in its place and that the proceeding was interrupted against it, but not against the other ten defendants. It refused to restore EY's former party name after EY's conversion into EY GmbH & Co. KG Wirtschaftsprüfungsgesellschaft (registered on 1 February 2024), rejecting the applicants' argument that the conversion was void for breaching creditor-protection rules. It also refused to sever the proceedings against EY, against MB and against Braun, holding that severance would create two parallel model proceedings with partly identical objectives."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-civ-mb-insolvency","record":{"id":"c-civ-mb-insolvency","kind":"fact","text":"MB Beteiligungsgesellschaft mbH secured loans with private assets of Markus Braun. By order of 21 February 2024 (9 IN 20/24) the Limburg an der Lahn local court ordered provisional administration of its assets, appointed the lawyer Carsten Koch as provisional insolvency administrator and imposed a general prohibition on disposals. In the suspended suits against it, claimants seek damages on the ground that the company, acting through Braun as its then managing director, unlawfully helped to put his assets beyond the reach of his creditors. A registry aggregator records a liquidation entry of 25 June 2024 and an update of the insolvency proceedings on 8 May 2026.","source_ids":["src-102","src-091"],"entity_ids":["mb-beteiligung","braun","ag-limburg"],"qualification":"The claim that the company helped shield Braun's assets is the claimants' allegation as summarised by the court.","response":"","outcome":"","adverse_subject_ids":["mb-beteiligung"]},"reading":"Fact: MB Beteiligungsgesellschaft mbH secured loans with private assets of Markus Braun. By order of 21 February 2024 (9 IN 20/24) the Limburg an der Lahn local court ordered provisional administration of its assets, appointed the lawyer Carsten Koch as provisional insolvency administrator and imposed a general prohibition on disposals. In the suspended suits against it, claimants seek damages on the ground that the company, acting through Braun as its then managing director, unlawfully helped to put his assets beyond the reach of his creditors. A registry aggregator records a liquidation entry of 25 June 2024 and an update of the insolvency proceedings on 8 May 2026."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-braun-arrest","record":{"id":"c-braun-arrest","kind":"fact","text":"On 9 June 2022 the 5th commercial chamber of the Munich I regional court confirmed an attachment order (Arrest) of EUR 140 million against Markus Braun (5 HK O 17659/21). According to the court in January 2023, the main action relating to the attachment (5 HK O 17452/21) was pending, already ran to more than 1,000 pages and was not expected to reach an oral hearing before autumn 2023.","source_ids":["src-051"],"entity_ids":["lg-muenchen","braun"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["braun"]},"reading":"Fact: On 9 June 2022 the 5th commercial chamber of the Munich I regional court confirmed an attachment order (Arrest) of EUR 140 million against Markus Braun (5 HK O 17659/21). According to the court in January 2023, the main action relating to the attachment (5 HK O 17452/21) was pending, already ran to more than 1,000 pages and was not expected to reach an oral hearing before autumn 2023."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-braun-insider","record":{"id":"c-braun-insider","kind":"attributed","text":"According to a press report of 14 July 2020, a BaFin spokesperson said the authority had filed a criminal complaint with the Munich public prosecutor against MB Beteiligungsgesellschaft, the company behind Braun, over the sale of Wirecard shares for EUR 6.6 million on 24 June 2020, the day before the insolvency filing; further sales of EUR 3.4 million two days earlier were still under review. Braun had sold most of his 8% stake on 18 and 19 June for EUR 155 million; BaFin said these sales would also be examined for possible insider trading. Braun had been released from custody on 22 June 2020 on bail of EUR 5 million.","source_ids":["src-063"],"entity_ids":["bafin","mb-beteiligung","braun","sta-muenchen","wirecard"],"qualification":"A complaint and an examination, not a finding; the record contains no outcome of the insider-trading review.","response":"According to the report, it was said at the time that he had to sell the shares to meet lenders' margin calls after the share price collapse.","outcome":"","adverse_subject_ids":["mb-beteiligung"]},"reading":"Attributed: According to a press report of 14 July 2020, a BaFin spokesperson said the authority had filed a criminal complaint with the Munich public prosecutor against MB Beteiligungsgesellschaft, the company behind Braun, over the sale of Wirecard shares for EUR 6.6 million on 24 June 2020, the day before the insolvency filing; further sales of EUR 3.4 million two days earlier were still under review. Braun had sold most of his 8% stake on 18 and 19 June for EUR 155 million; BaFin said these sales would also be examined for possible insider trading. Braun had been released from custody on 22 June 2020 on bail of EUR 5 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-braun-kitzbuehel","record":{"id":"c-braun-kitzbuehel","kind":"attributed","text":"A press report of 1 July 2020 stated that Braun had pledged real estate, including a villa in Kitzbühel worth millions.","source_ids":["src-034"],"entity_ids":["braun"],"qualification":"Press report; the record does not say to whom the property was pledged.","response":"","outcome":""},"reading":"Attributed: A press report of 1 July 2020 stated that Braun had pledged real estate, including a villa in Kitzbühel worth millions."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-civ-dno","record":{"id":"c-civ-dno","kind":"fact","text":"On 29 November 2024 the Frankfurt am Main higher regional court (7 U 82/22, not final; appeal on points of law allowed) ruled that the D&O insurer owed no further cover to Wirecard AG's former director of accounting, who had also been managing director of Wirecard Technologies GmbH, a subsidiary active in the third-party acquiring business in Asia. The court held that the insured event occurred in 2020, not 2019, because the circumstances he cited (critical Financial Times reporting, Singapore investigations and a US class action) had not been properly notified to the insurer; the 2020 limit of EUR 15 million had been fully paid out for covered costs of the Wirecard scandal. He had argued for the 2019 limit of EUR 25 million.","source_ids":["src-058"],"entity_ids":["olg-frankfurt","wirecard","wd-tech","ft"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 29 November 2024 the Frankfurt am Main higher regional court (7 U 82/22, not final; appeal on points of law allowed) ruled that the D&O insurer owed no further cover to Wirecard AG's former director of accounting, who had also been managing director of Wirecard Technologies GmbH, a subsidiary active in the third-party acquiring business in Asia. The court held that the insured event occurred in 2020, not 2019, because the circumstances he cited (critical Financial Times reporting, Singapore investigations and a US class action) had not been properly notified to the insurer; the 2020 limit of EUR 15 million had been fully paid out for covered costs of the Wirecard scandal. He had argued for the 2019 limit of EUR 25 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-bank-origin","record":{"id":"c-bank-origin","kind":"fact","text":"According to ESMA's chronology, Wirecard bought XCOM in 2006 and renamed it Wirecard Bank, thereby obtaining Visa and Mastercard licences to issue credit cards and handle money on behalf of merchants. A European Parliament briefing describes Wirecard Bank AG as holding a full German banking licence, supervised by BaFin and a member of the Deposit Protection Fund of the Association of German Banks.","source_ids":["src-087","src-025"],"entity_ids":["wirecard","wd-bank","xcom","esma","europarl","bafin"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to ESMA's chronology, Wirecard bought XCOM in 2006 and renamed it Wirecard Bank, thereby obtaining Visa and Mastercard licences to issue credit cards and handle money on behalf of merchants. A European Parliament briefing describes Wirecard Bank AG as holding a full German banking licence, supervised by BaFin and a member of the Deposit Protection Fund of the Association of German Banks."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-bank-licences","record":{"id":"c-bank-licences","kind":"fact","text":"Wirecard AG's 2011 annual report states that Wirecard Bank AG was a principal member of MasterCard and Visa and a member of JCB International, with licences for card issuing and merchant acquiring, and held online-acquiring licences for China UnionPay and Discover/Diners Club. The 2019 bond prospectus adds that the bank also held acquiring licences for American Express. In the half-year report for 2019 the Acquiring & Issuing segment comprised Wirecard Bank AG, Wirecard Acquiring & Issuing GmbH, Wirecard Ödeme ve Elektronik Para Hizmetleri A.Ş., Wirecard Brazil S.A., Wirecard Card Solutions Ltd. and Wirecard North America Inc.","source_ids":["src-010","src-012","src-066"],"entity_ids":["wirecard","wd-bank","unionpay","wd-acq-iss","wd-turkey","wd-brazil","wd-card-solutions","wd-north-america"],"qualification":"","response":"","outcome":""},"reading":"Fact: Wirecard AG's 2011 annual report states that Wirecard Bank AG was a principal member of MasterCard and Visa and a member of JCB International, with licences for card issuing and merchant acquiring, and held online-acquiring licences for China UnionPay and Discover/Diners Club. The 2019 bond prospectus adds that the bank also held acquiring licences for American Express. In the half-year report for 2019 the Acquiring & Issuing segment comprised Wirecard Bank AG, Wirecard Acquiring & Issuing GmbH, Wirecard Ödeme ve Elektronik Para Hizmetleri A.Ş., Wirecard Brazil S.A., Wirecard Card Solutions Ltd. and Wirecard North America Inc."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-bank-restructuring","record":{"id":"c-bank-restructuring","kind":"fact","text":"According to the Federal Ministry of Finance's timeline, Wirecard Bank AG applied to BaFin on 8 May 2018 for approval of a restructuring that would make the bank a direct subsidiary of Wirecard AG; this started an owner-control procedure involving BaFin, the Bundesbank and the European Central Bank, and the application was finally approved in January 2019. Because Wirecard did not meet the deadline for the restructuring, it had to file a new application in January 2020.","source_ids":["src-069"],"entity_ids":["wd-bank","wirecard","bafin","bundesbank","ecb","bmf"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the Federal Ministry of Finance's timeline, Wirecard Bank AG applied to BaFin on 8 May 2018 for approval of a restructuring that would make the bank a direct subsidiary of Wirecard AG; this started an owner-control procedure involving BaFin, the Bundesbank and the European Central Bank, and the application was finally approved in January 2019. Because Wirecard did not meet the deadline for the restructuring, it had to file a new application in January 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-bank-marisk","record":{"id":"c-bank-marisk","kind":"fact","text":"According to the Federal Government, a 2017 special audit of Wirecard Bank AG under the minimum requirements for risk management (MaRisk) by BaFin and the Bundesbank found weaknesses in lending: no risk classification procedure for strategic loans, weaknesses in loan approval (collateral valuation and debt-service capacity), incomplete disclosure of financial statements for risk-relevant exposures and no evidence of regular impairment tests on collateral. The Finance Ministry's timeline lists several special audits of the bank under section 44 of the Banking Act between 2010 and 2019, including one of its lending organisation from 3 June to 21 July 2017.","source_ids":["src-073","src-069"],"entity_ids":["wd-bank","bafin","bundesbank","bundestag","bmf"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the Federal Government, a 2017 special audit of Wirecard Bank AG under the minimum requirements for risk management (MaRisk) by BaFin and the Bundesbank found weaknesses in lending: no risk classification procedure for strategic loans, weaknesses in loan approval (collateral valuation and debt-service capacity), incomplete disclosure of financial statements for risk-relevant exposures and no evidence of regular impairment tests on collateral. The Finance Ministry's timeline lists several special audits of the bank under section 44 of the Banking Act between 2010 and 2019, including one of its lending organisation from 3 June to 21 July 2017."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-bank-aml","record":{"id":"c-bank-aml","kind":"fact","text":"BaFin carried out a special anti-money-laundering audit of Wirecard Bank AG in early July 2019 and on 15 July 2019 placed the bank under intensive anti-money-laundering supervision, a classification that, according to the ministry, resulted from a differentiated risk analysis and was unrelated to the allegations against the parent company. On 3 June 2019, after press reports that the bank processed payments for operators of fraudulent trading sites, BaFin asked the public prosecutor and the Financial Intelligence Unit (FIU) for further supervisory information.","source_ids":["src-069"],"entity_ids":["bafin","wd-bank","fiu","bmf","wirecard"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["wd-bank"]},"reading":"Fact: BaFin carried out a special anti-money-laundering audit of Wirecard Bank AG in early July 2019 and on 15 July 2019 placed the bank under intensive anti-money-laundering supervision, a classification that, according to the ministry, resulted from a differentiated risk analysis and was unrelated to the allegations against the parent company. On 3 June 2019, after press reports that the bank processed payments for operators of fraudulent trading sites, BaFin asked the public prosecutor and the Financial Intelligence Unit (FIU) for further supervisory information."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-bank-fiu","record":{"id":"c-bank-fiu","kind":"fact","text":"The Finance Ministry reported that the FIU had received more than 500 suspicious-transaction reports from Wirecard Bank AG concerning the bank's customers and held more than 1,000 reports or items of information with links to Wirecard; after re-screening them on 22 June 2020, 72 reports were, as of 9 July 2020, possibly connected with the current allegations against Wirecard AG.","source_ids":["src-069"],"entity_ids":["fiu","wd-bank","wirecard","bmf"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Finance Ministry reported that the FIU had received more than 500 suspicious-transaction reports from Wirecard Bank AG concerning the bank's customers and held more than 1,000 reports or items of information with links to Wirecard; after re-screening them on 22 June 2020, 72 reports were, as of 9 July 2020, possibly connected with the current allegations against Wirecard AG."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-bank-fine","record":{"id":"c-bank-fine","kind":"fact","text":"By decision of 13 January 2021 BaFin imposed two administrative fines totalling EUR 60,000 on Wirecard Bank AG under section 56(2) no. 5 of the Banking Act; the decision became final on 2 February 2021.","source_ids":["src-047"],"entity_ids":["bafin","wd-bank"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["wd-bank"]},"reading":"Fact: By decision of 13 January 2021 BaFin imposed two administrative fines totalling EUR 60,000 on Wirecard Bank AG under section 56(2) no. 5 of the Banking Act; the decision became final on 2 February 2021."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-bank-after-insolvency","record":{"id":"c-bank-after-insolvency","kind":"fact","text":"According to the company's statement of 25 June 2020, cited in a European Parliament briefing, Wirecard Bank AG was not part of the insolvency proceedings and BaFin had appointed a special representative for it. Estonia's e-Residency programme reported that the bank assured customers that deposits were protected by two schemes up to EUR 19.7 million per customer, and that the service provider Xolo, which had offered e-residents Wirecard Bank IBAN accounts since March 2020, suspended opening new accounts.","source_ids":["src-088","src-025"],"entity_ids":["wd-bank","bafin","europarl","xolo","wirecard"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the company's statement of 25 June 2020, cited in a European Parliament briefing, Wirecard Bank AG was not part of the insolvency proceedings and BaFin had appointed a special representative for it. Estonia's e-Residency programme reported that the bank assured customers that deposits were protected by two schemes up to EUR 19.7 million per customer, and that the service provider Xolo, which had offered e-residents Wirecard Bank IBAN accounts since March 2020, suspended opening new accounts."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-bank-customers-2020","record":{"id":"c-bank-customers-2020","kind":"attributed","text":"A news report of 2 July 2020 citing insiders said Deutsche Bank intended to help the then still solvent Wirecard Bank and was thereby positioning itself for a possible takeover; BaFin had installed the Bundesbank as special representative to ensure that no funds flowed to the parent company. According to the report, Aldi Süd had moved its customers' card payments to Payone (part of Ingenico) from early July, keeping only its gift card with Wirecard Bank, and the bank's 2018 annual report showed total assets of EUR 1.6 billion and customer savings of almost EUR 1.4 billion, protected by statutory deposit insurance and the private banks' fund.","source_ids":["src-076","src-065"],"entity_ids":["deutsche-bank","wd-bank","bafin","bundesbank","aldi-sued","payone"],"qualification":"Insider account in a press report; no statement by Deutsche Bank is in the record and no takeover followed in the record.","response":"","outcome":"The record shows no takeover by Deutsche Bank; the bank was later renamed WDB Abwicklungs AG."},"reading":"Attributed: A news report of 2 July 2020 citing insiders said Deutsche Bank intended to help the then still solvent Wirecard Bank and was thereby positioning itself for a possible takeover; BaFin had installed the Bundesbank as special representative to ensure that no funds flowed to the parent company. According to the report, Aldi Süd had moved its customers' card payments to Payone (part of Ingenico) from early July, keeping only its gift card with Wirecard Bank, and the bank's 2018 annual report showed total assets of EUR 1.6 billion and customer savings of almost EUR 1.4 billion, protected by statutory deposit insurance and the private banks' fund."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-acq-ecredit","record":{"id":"c-acq-ecredit","kind":"fact","text":"On 16 December 2009 Wirecard AG signed an agreement to buy 100% of E-Credit Plus Pte. Ltd. of Singapore and its subsidiaries; the transfer of shares closed on 28 December 2009, and Wirecard obtained control under IFRS 3 on 1 January 2010, so the stake was carried as an associate at the end of 2009. The 2010 annual report puts the fair value of the E-Credit group, and the purchase price, at EUR 13.283 million.","source_ids":["src-023"],"entity_ids":["wirecard","wd-asia-pte"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 16 December 2009 Wirecard AG signed an agreement to buy 100% of E-Credit Plus Pte. Ltd. of Singapore and its subsidiaries; the transfer of shares closed on 28 December 2009, and Wirecard obtained control under IFRS 3 on 1 January 2010, so the stake was carried as an associate at the end of 2009. The 2010 annual report puts the fair value of the E-Credit group, and the purchase price, at EUR 13.283 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-acq-2011","record":{"id":"c-acq-2011","kind":"fact","text":"With effect from 13 January 2011 Wirecard AG took over Procard Services FZ LLC of Dubai, a provider of payment processing, card acceptance and card issuing services, for EUR 670,000 plus assumed debt of EUR 11.561 million. In December 2011 the group bought Systems@Work Pte. Ltd. of Singapore, known for its TeleMoney brand, with its subsidiaries Systems@Work (M) Sdn Bhd (Kuala Lumpur) and Safe2Pay Pte. Ltd. (Singapore), for cash of EUR 34.726 million plus two earn-out components of up to SGD 22.5 million.","source_ids":["src-010"],"entity_ids":["wirecard","procard","wd-singapore","systemsatwork-my","safe2pay"],"qualification":"","response":"","outcome":""},"reading":"Fact: With effect from 13 January 2011 Wirecard AG took over Procard Services FZ LLC of Dubai, a provider of payment processing, card acceptance and card issuing services, for EUR 670,000 plus assumed debt of EUR 11.561 million. In December 2011 the group bought Systems@Work Pte. Ltd. of Singapore, known for its TeleMoney brand, with its subsidiaries Systems@Work (M) Sdn Bhd (Kuala Lumpur) and Safe2Pay Pte. Ltd. (Singapore), for cash of EUR 34.726 million plus two earn-out components of up to SGD 22.5 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-acq-newcastle","record":{"id":"c-acq-newcastle","kind":"fact","text":"Also in December 2011 the newly formed British subsidiary Wirecard Card Solutions Ltd. took over the prepaid card issuing business of Newcastle Building Society, about 1.5 million prepaid cards in six European countries, in two phases: first as outsourcing provider for the main functions, then taking control once the UK Financial Services Authority authorised it as an e-money institution. The chief executive's letter for 2011 also notes that Wirecard Bank was the first non-Chinese bank to offer China UnionPay's online acquiring licence and that the platform processed EUR 15.5 billion in 2011.","source_ids":["src-010"],"entity_ids":["wd-card-solutions","newcastle-bs","wirecard","wd-bank","unionpay"],"qualification":"","response":"","outcome":""},"reading":"Fact: Also in December 2011 the newly formed British subsidiary Wirecard Card Solutions Ltd. took over the prepaid card issuing business of Newcastle Building Society, about 1.5 million prepaid cards in six European countries, in two phases: first as outsourcing provider for the main functions, then taking control once the UK Financial Services Authority authorised it as an e-money institution. The chief executive's letter for 2011 also notes that Wirecard Bank was the first non-Chinese bank to offer China UnionPay's online acquiring licence and that the platform processed EUR 15.5 billion in 2011."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-acq-2017","record":{"id":"c-acq-2017","kind":"fact","text":"The purchase of Citi Prepaid Card Services, announced on 29 June 2016 as a combined share and asset deal, closed on 9 March 2017 with control over Ecount Inc. and the individual assets; the transaction vehicle Kestrel Mergers Acquisitions Corp. of Conshohocken, Pennsylvania, merged into Wirecard North America Inc. on closing. On 6 March 2017 Wirecard AG bought all shares in MyGate Communications Pty Ltd. of Cape Town, a payment service provider with about 20 staff, for an agreed price of EUR 13.1 million.","source_ids":["src-020"],"entity_ids":["wirecard","citigroup","ecount","kestrel","wd-north-america","mygate"],"qualification":"","response":"","outcome":""},"reading":"Fact: The purchase of Citi Prepaid Card Services, announced on 29 June 2016 as a combined share and asset deal, closed on 9 March 2017 with control over Ecount Inc. and the individual assets; the transaction vehicle Kestrel Mergers Acquisitions Corp. of Conshohocken, Pennsylvania, merged into Wirecard North America Inc. on closing. On 6 March 2017 Wirecard AG bought all shares in MyGate Communications Pty Ltd. of Cape Town, a payment service provider with about 20 staff, for an agreed price of EUR 13.1 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-acq-citi-asia","record":{"id":"c-acq-citi-asia","kind":"fact","text":"On 13 March 2017 Wirecard agreed with the Citigroup subsidiaries Citibank, N.A. and Citibank Overseas Investment Corporation to acquire the customer portfolios of Citi's card-acceptance business in eleven Asia-Pacific markets, with more than 20,000 merchants; the portfolios for Malaysia were taken over on 31 January 2018, for India on 31 August 2018 and for Australia and New Zealand on 25 October 2018. In 2018 Wirecard thus acquired customer portfolios of Citigroup's card acceptance business in Asia-Pacific, in particular in Malaysia and India; mainly as a result, goodwill rose by EUR 39.7 million to EUR 705.9 million at 31 December 2018 (2017: EUR 675.8 million). EY treated the acquisition as a key audit matter because management had to exercise judgement on whether it was a business combination under IFRS 3, on the purchase price allocation and on valuing liabilities from customer contracts.","source_ids":["src-005"],"entity_ids":["wirecard","citigroup","citibank-na","citi-overseas","ey"],"qualification":"","response":"","outcome":""},"reading":"Fact: On 13 March 2017 Wirecard agreed with the Citigroup subsidiaries Citibank, N.A. and Citibank Overseas Investment Corporation to acquire the customer portfolios of Citi's card-acceptance business in eleven Asia-Pacific markets, with more than 20,000 merchants; the portfolios for Malaysia were taken over on 31 January 2018, for India on 31 August 2018 and for Australia and New Zealand on 25 October 2018. In 2018 Wirecard thus acquired customer portfolios of Citigroup's card acceptance business in Asia-Pacific, in particular in Malaysia and India; mainly as a result, goodwill rose by EUR 39.7 million to EUR 705.9 million at 31 December 2018 (2017: EUR 675.8 million). EY treated the acquisition as a key audit matter because management had to exercise judgement on whether it was a business combination under IFRS 3, on the purchase price allocation and on valuing liabilities from customer contracts."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-acq-partnerships-2018","record":{"id":"c-acq-partnerships-2018","kind":"fact","text":"The 2018 annual report describes a strategic partnership with Crédit Agricole Payment Services (CAPS) to offer e-commerce payment acceptance and processing services, mobile and other point-of-sale solutions across Europe, and a partnership with Mizuho Bank under which customer relationships were concluded with Japanese retailers in Singapore and Hong Kong.","source_ids":["src-005"],"entity_ids":["wirecard","caps","mizuho"],"qualification":"","response":"","outcome":""},"reading":"Fact: The 2018 annual report describes a strategic partnership with Crédit Agricole Payment Services (CAPS) to offer e-commerce payment acceptance and processing services, mobile and other point-of-sale solutions across Europe, and a partnership with Mizuho Bank under which customer relationships were concluded with Japanese retailers in Singapore and Hong Kong."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-2012-control-agreements","record":{"id":"c-str-2012-control-agreements","kind":"fact","text":"The invitation to Wirecard AG's annual general meeting of 26 June 2012, published on 16 May 2012, asked shareholders to approve two control and profit-transfer agreements concluded on 10 May 2012 with Wire Card Beteiligungs GmbH (to be renamed Wirecard Acquiring & Issuing GmbH, HRB 156848) and with Trustpay International GmbH (to be renamed Wirecard Sales International GmbH, HRB 187465). Both were signed for Wirecard AG's management board by Dr. Markus Braun, Burkhard Ley and Jan Marsalek; Braun signed for the management of Wire Card Beteiligungs GmbH and Marsalek for that of Trustpay International GmbH.","source_ids":["src-050"],"entity_ids":["wirecard","wd-acq-iss","wd-sih","braun","ley","marsalek"],"qualification":"","response":"","outcome":""},"reading":"Fact: The invitation to Wirecard AG's annual general meeting of 26 June 2012, published on 16 May 2012, asked shareholders to approve two control and profit-transfer agreements concluded on 10 May 2012 with Wire Card Beteiligungs GmbH (to be renamed Wirecard Acquiring & Issuing GmbH, HRB 156848) and with Trustpay International GmbH (to be renamed Wirecard Sales International GmbH, HRB 187465). Both were signed for Wirecard AG's management board by Dr. Markus Braun, Burkhard Ley and Jan Marsalek; Braun signed for the management of Wire Card Beteiligungs GmbH and Marsalek for that of Trustpay International GmbH."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-str-parent-guarantees-2018","record":{"id":"c-str-parent-guarantees-2018","kind":"fact","text":"In its 2018 single-entity accounts Wirecard AG states that, for corporate-law reasons, it issued a letter of comfort covering all liabilities of its subsidiary Wirecard Payment Solutions Holdings Ltd. of Dublin and did not expect to be called upon under it.","source_ids":["src-008"],"entity_ids":["wirecard","wd-psh"],"qualification":"The amounts of the liabilities are not legible in the retained text layer of the accounts.","response":"","outcome":""},"reading":"Fact: In its 2018 single-entity accounts Wirecard AG states that, for corporate-law reasons, it issued a letter of comfort covering all liabilities of its subsidiary Wirecard Payment Solutions Holdings Ltd. of Dublin and did not expect to be called upon under it."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-fin-2015-balance","record":{"id":"c-fin-2015-balance","kind":"fact","text":"According to the consolidated balance sheet at 31 December 2015 reproduced in the special investigators' report, Wirecard reported cash and cash equivalents of EUR 1,062.968 million, receivables from the acquiring business of EUR 334.055 million and total assets of EUR 2,935.501 million.","source_ids":["src-027"],"entity_ids":["wirecard","bundestag"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the consolidated balance sheet at 31 December 2015 reproduced in the special investigators' report, Wirecard reported cash and cash equivalents of EUR 1,062.968 million, receivables from the acquiring business of EUR 334.055 million and total assets of EUR 2,935.501 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-gomopa-2010","record":{"id":"c-sup-gomopa-2010","kind":"fact","text":"According to the supervisory board's report for 2010, at its meeting in April 2010 the board discussed, besides the 2009 accounts, the allegations made against the Wirecard group, published among other places on the gomoPa website, and the necessary countermeasures; the report does not describe the allegations.","source_ids":["src-023"],"entity_ids":["wirecard","gomopa"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the supervisory board's report for 2010, at its meeting in April 2010 the board discussed, besides the 2009 accounts, the allegations made against the Wirecard group, published among other places on the gomoPa website, and the necessary countermeasures; the report does not describe the allegations."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lit-uk-fraud-2010","record":{"id":"c-lit-uk-fraud-2010","kind":"fact","text":"Wirecard's 2011 annual report states that the group pursued damages claims in Great Britain, in particular for fraud, against a customer and persons close to it; following a High Court judgment in London in its favour it began enforcement in 2010 and in 2011 recovered most of the outstanding money through the forced sale of a property.","source_ids":["src-010"],"entity_ids":["wirecard"],"qualification":"The report does not name the defendants.","response":"","outcome":""},"reading":"Fact: Wirecard's 2011 annual report states that the group pursued damages claims in Great Britain, in particular for fraud, against a customer and persons close to it; following a High Court judgment in London in its favour it began enforcement in 2010 and in 2011 recovered most of the outstanding money through the forced sale of a property."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lit-it-provider","record":{"id":"c-lit-it-provider","kind":"fact","text":"The 2019 bond prospectus discloses that the insolvency administrator of a former IT service provider was seeking to enforce a claim against a group company based on a confession of judgment from 2014, and that Wirecard had appealed against enforcement on the ground that the claim had already been settled.","source_ids":["src-012"],"entity_ids":["wirecard"],"qualification":"Parties are not named in the prospectus; no outcome is in the record.","response":"","outcome":""},"reading":"Fact: The 2019 bond prospectus discloses that the insolvency administrator of a former IT service provider was seeking to enforce a claim against a group company based on a confession of judgment from 2014, and that Wirecard had appealed against enforcement on the ground that the claim had already been settled."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-tpa-evidence","record":{"id":"c-aud-tpa-evidence","kind":"fact","text":"The special investigators' report lists the evidence EY obtained on the TPA business: Wirecard Bank AG statements of the group companies concerned, balance confirmations from the TPA partners, unsigned Excel or PDF lists of transaction volumes, screenshots of test purchases in the partners' payment systems and, after the trust accounts were set up in 2015, trust agreements and balance confirmations from the trustee Citadelle Corporate Services Pte. Ltd. EY also made site visits to Al Alam Solution Provider Inc. in Dubai (2015), PayEasy Solutions Inc. in Manila (2016) and Senjo in Singapore (2017).","source_ids":["src-027"],"entity_ids":["ey","wirecard","wd-bank","citadelle","al-alam","payeasy","senjo","bundestag"],"qualification":"","response":"","outcome":""},"reading":"Fact: The special investigators' report lists the evidence EY obtained on the TPA business: Wirecard Bank AG statements of the group companies concerned, balance confirmations from the TPA partners, unsigned Excel or PDF lists of transaction volumes, screenshots of test purchases in the partners' payment systems and, after the trust accounts were set up in 2015, trust agreements and balance confirmations from the trustee Citadelle Corporate Services Pte. Ltd. EY also made site visits to Al Alam Solution Provider Inc. in Dubai (2015), PayEasy Solutions Inc. in Manila (2016) and Senjo in Singapore (2017)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-aud-singapore-confirmations","record":{"id":"c-aud-singapore-confirmations","kind":"fact","text":"According to the special investigators' report, the component auditor of Wirecard Singapore Pte. Ltd., Ernst & Young LLP Singapore, reported to the group audit team that the recoverability of receivables of about EUR 8.9 million was doubtful; on 4 April 2017, one day before the date of the audit opinion, the auditor received balance confirmations for two of the receivables totalling about EUR 6.2 million. The confirmation for the debtor Centurion was signed by a person who also held a position at the TPA partner PayEasy.","source_ids":["src-027"],"entity_ids":["ey","wd-singapore","payeasy","bundestag"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the special investigators' report, the component auditor of Wirecard Singapore Pte. Ltd., Ernst & Young LLP Singapore, reported to the group audit team that the recoverability of receivables of about EUR 8.9 million was doubtful; on 4 April 2017, one day before the date of the audit opinion, the auditor received balance confirmations for two of the receivables totalling about EUR 6.2 million. The confirmation for the debtor Centurion was signed by a person who also held a position at the TPA partner PayEasy."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-sup-esma-disclosure","record":{"id":"c-sup-esma-disclosure","kind":"fact","text":"ESMA's peer review records that Wirecard published its 2015 financial statements with an unqualified audit opinion on 6 April 2016, the day an FT article again questioned its Indian acquisition, and that on 10 December 2019 Wirecard published a statement explaining how it processed and accounted for payment transactions via routing partners; the review committee considered that exchanges between FREP and Wirecard in October or November 2019 could have prompted more detailed and transparent information in that statement and in later reports.","source_ids":["src-087"],"entity_ids":["esma","wirecard","ey","ft","dpr"],"qualification":"","response":"","outcome":""},"reading":"Fact: ESMA's peer review records that Wirecard published its 2015 financial statements with an unqualified audit opinion on 6 April 2016, the day an FT article again questioned its Indian acquisition, and that on 10 December 2019 Wirecard published a statement explaining how it processed and accounted for payment transactions via routing partners; the review committee considered that exchanges between FREP and Wirecard in October or November 2019 could have prompted more detailed and transparent information in that statement and in later reports."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-crim-dubai-arrest","record":{"id":"c-crim-dubai-arrest","kind":"attributed","text":"According to a news agency report of 6 July 2020, the Munich prosecutor said it had questioned the chief executive of Cardsystems Middle East FZ-LLC, Wirecard's Dubai-based subsidiary, and arrested him on a warrant after he travelled from Dubai and turned himself in; the arrest was on suspicion of conspiracy to commit fraud, attempted fraud and aiding and abetting other offences, with a risk of flight or tampering with evidence. The prosecutors did not name him.","source_ids":["src-094","src-038","src-067"],"entity_ids":["sta-muenchen","cardsystems-me","wirecard","bellenhaus"],"qualification":"Arrest on suspicion; the later charges and trial are described with the criminal proceedings.","response":"","outcome":"On 10 March 2022 the prosecutor charged \"B.\", a former managing director of CardSystems Middle East, together with Braun and von Erffa; a July 2022 press report identifies the head of the Dubai subsidiary who turned himself in in July 2020 as Oliver Bellenhaus, who acted as a principal prosecution witness."},"reading":"Attributed: According to a news agency report of 6 July 2020, the Munich prosecutor said it had questioned the chief executive of Cardsystems Middle East FZ-LLC, Wirecard's Dubai-based subsidiary, and arrested him on a warrant after he travelled from Dubai and turned himself in; the arrest was on suspicion of conspiracy to commit fraud, attempted fraud and aiding and abetting other offences, with a risk of flight or tampering with evidence. The prosecutors did not name him."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-lead-klestil","record":{"id":"c-lead-klestil","kind":"attributed","text":"A technology news site described supervisory board deputy chairman Stefan Klestil on 23 July 2020 as a partner of the Vienna venture capital firm Speedinvest, responsible for investments such as Iyzico, Curve, Payworks, Wefox, Billie and Fincompare, a co-founder of Fintech Austria, a member of the Austrian government's fintech advisory council and the first investor in N26; it reported that Markus Braun had brought him onto the board many years earlier. Wirecard's 2019 half-year report lists board mandates at Wirecard Bank AG, Billie, Curve, Iyzico, N26 Bank, N26, Payworks, wefox and FinCompare for the member who became deputy chairman on 18 June 2019.","source_ids":["src-082","src-066","src-062"],"entity_ids":["klestil","speedinvest","braun","wirecard","wd-bank","lg-muenchen","jaffe"],"qualification":"In the half-year report the mandate list is printed without the member's name; it is attributed to Klestil from its position and its match with the published profile.","response":"Asked for an interview, Klestil replied through a representative that only the chairman spoke for the supervisory board and that he, like the whole board, was doing everything to help clarify all open questions about Wirecard's accounts.","outcome":"In 2024 the Munich I regional court dismissed the insolvency administrator's damages claim against him: it found that he had neglected his supervisory duties but doubted that proper supervision would have changed the management board's conduct; no criminal offence is alleged against him."},"reading":"Attributed: A technology news site described supervisory board deputy chairman Stefan Klestil on 23 July 2020 as a partner of the Vienna venture capital firm Speedinvest, responsible for investments such as Iyzico, Curve, Payworks, Wefox, Billie and Fincompare, a co-founder of Fintech Austria, a member of the Austrian government's fintech advisory council and the first investor in N26; it reported that Markus Braun had brought him onto the board many years earlier. Wirecard's 2019 half-year report lists board mandates at Wirecard Bank AG, Billie, Curve, Iyzico, N26 Bank, N26, Payworks, wefox and FinCompare for the member who became deputy chairman on 18 June 2019."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"c-bank-braun-loan","record":{"id":"c-bank-braun-loan","kind":"attributed","text":"The same report, citing a newspaper, said that Wirecard Bank had granted Markus Braun a loan early in 2020, reportedly of EUR 35 million, approved according to that newspaper by the supervisory board on which Klestil sat; the supervisory board said it had not known of the loan.","source_ids":["src-082"],"entity_ids":["wd-bank","braun","klestil","ft","wirecard"],"qualification":"Second-hand press account of a rumoured amount; the record contains no bank or court document on the loan.","response":"The supervisory board stated that it had not known of the loan.","outcome":""},"reading":"Attributed: The same report, citing a newspaper, said that Wirecard Bank had granted Markus Braun a loan early in 2020, reportedly of EUR 35 million, approved according to that newspaper by the supervisory board on which Klestil sat; the supervisory board said it had not known of the loan."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-3dbb00fb237ef3fdf297efc9","record":{"id":"display-claim-3dbb00fb237ef3fdf297efc9","kind":"analysis","text":"Wirecard AG, registered in Munich and a DAX 30 member from September 2018, reported a growing share of its revenue through three third-party acquiring partners, Al Alam, PayEasy and Senjo. In June 2020 its auditor EY could not confirm EUR 1.9 billion on trust accounts, the company said the balances probably did not exist, and it applied for insolvency. This edition follows the business from the special investigators' reconstruction of EY's files to the auditor oversight body's findings, ESMA's review of the supervisors, the insolvency estate and the criminal trial, keeping each party's response and the unresolved status of the charges beside every account.","source_ids":["src-002","src-012","src-006","src-016","src-001","src-087","src-025","src-027","src-024","src-031","src-067","src-069","src-030","src-009","src-029","src-056","src-038","src-051","src-054","src-060","src-003","src-037"],"entity_ids":["wirecard","click2pay","wd-bank","xcom","esma","europarl","bafin","al-alam","payeasy","senjo","ey","cardsystems-me","ft","kpmg","bdo","bpi","ocbc","jaffe","bmf","apas","dpr","ag-muenchen","wd-tech","santander","wd-north-america","syncapay","wd-brazil","pagseguro","wd-romania","sibs","bgh","sta-muenchen","braun","von-erffa","bellenhaus","lg-muenchen","marsalek","bka","roussev","fsb"],"premise_claim_ids":["c-id-registration","c-id-names","c-bank-origin","c-id-dax","c-tpa-rp-two-models","c-tpa-rp-figures","c-tpa-ft-2019","c-tpa-adhoc-2020-06-18","c-tpa-2020-06-22","c-tpa-philippines","c-tpa-ocbc","c-aud-unqualified-2009-2018","c-aud-apas","c-sup-esma-findings","c-ins-petition","c-ins-santander","c-ins-claims","c-crim-indictment-2022","c-crim-judge-2026","c-crim-marsalek-wanted","c-mar-uk-trial"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard AG, registered in Munich and a DAX 30 member from September 2018, reported a growing share of its revenue through three third-party acquiring partners, Al Alam, PayEasy and Senjo. In June 2020 its auditor EY could not confirm EUR 1.9 billion on trust accounts, the company said the balances probably did not exist, and it applied for insolvency. This edition follows the business from the special investigators' reconstruction of EY's files to the auditor oversight body's findings, ESMA's review of the supervisors, the insolvency estate and the criminal trial, keeping each party's response and the unresolved status of the charges beside every account."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-9a9f7522129c58ed2c6b883c","record":{"id":"display-claim-9a9f7522129c58ed2c6b883c","kind":"analysis","text":"Wirecard AG is a German stock corporation registered with the Munich local court under HRB 169227 since 6 August 2007. According to its 2019 bond prospectus it was incorporated in Berlin on 6 May 1999 and moved its seat after a shareholders' resolution of 14 June 2007; its earlier names were InfoGenie Europe AG and Wire Card AG. In 2006 Wirecard bought XCOM and renamed it Wirecard Bank, obtaining Visa and Mastercard licences; the bank held a full German banking licence under BaFin's supervision. ESMA describes Wirecard AG as a fintech company included in the DAX 30 from September 2018 and notes that allegations of accounting irregularities raised several times during its rapid growth were systematically rejected by the company.","source_ids":["src-002","src-012","src-006","src-016","src-001","src-087","src-025"],"entity_ids":["wirecard","click2pay","wd-bank","xcom","esma","europarl","bafin"],"premise_claim_ids":["c-id-registration","c-id-names","c-bank-origin","c-id-dax"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard AG is a German stock corporation registered with the Munich local court under HRB 169227 since 6 August 2007. According to its 2019 bond prospectus it was incorporated in Berlin on 6 May 1999 and moved its seat after a shareholders' resolution of 14 June 2007; its earlier names were InfoGenie Europe AG and Wire Card AG. In 2006 Wirecard bought XCOM and renamed it Wirecard Bank, obtaining Visa and Mastercard licences; the bank held a full German banking licence under BaFin's supervision. ESMA describes Wirecard AG as a fintech company included in the DAX 30 from September 2018 and notes that allegations of accounting irregularities raised several times during its rapid growth were systematically rejected by the company."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-9a88bc8cd9d08f25b1e01404","record":{"id":"display-claim-9a88bc8cd9d08f25b1e01404","kind":"analysis","text":"The special investigators appointed by the Bundestag's committee of inquiry describe two business models: Wirecard's own business, running the whole payment chain with Wirecard Bank as acquirer, and third-party acquiring, in which payment processing and the acquiring bank's services were outsourced to three partners, Al Alam, PayEasy and Senjo, which alone held contracts with the merchants. Their table of key figures from the accounts and EY's working papers shows TPA revenue rising from EUR 308 million in 2014 to EUR 1,034 million in 2018, against group revenue of EUR 2,016 million that year, and escrow balances counted as cash rising from EUR 114 million (2015) to EUR 976 million (2018).","source_ids":["src-027"],"entity_ids":["wirecard","wd-bank","al-alam","payeasy","senjo","ey"],"premise_claim_ids":["c-tpa-rp-two-models","c-tpa-rp-figures"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The special investigators appointed by the Bundestag's committee of inquiry describe two business models: Wirecard's own business, running the whole payment chain with Wirecard Bank as acquirer, and third-party acquiring, in which payment processing and the acquiring bank's services were outsourced to three partners, Al Alam, PayEasy and Senjo, which alone held contracts with the merchants. Their table of key figures from the accounts and EY's working papers shows TPA revenue rising from EUR 308 million in 2014 to EUR 1,034 million in 2018, against group revenue of EUR 2,016 million that year, and escrow balances counted as cash rising from EUR 114 million (2015) to EUR 976 million (2018)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-15050b1ffc6f14bbc9841a2b","record":{"id":"display-claim-15050b1ffc6f14bbc9841a2b","kind":"analysis","text":"Financial Times articles of 2019, as summarised by ESMA, reported that half of Wirecard's revenue and almost all its profit came from three opaque partners and that profits were channelled mainly through CardSystems Middle East in Dubai; later reports said that payments for clients routed through Al Alam included companies that had never heard of it and that EUR 334 million on trust accounts in 2017 had been wrongly classified as cash. Wirecard rejected such allegations at the time. On 22 June 2020 it stated that the trust account balances of EUR 1.9 billion probably did not exist.","source_ids":["src-087","src-025"],"entity_ids":["wirecard","cardsystems-me","al-alam","esma","ft"],"premise_claim_ids":["c-tpa-ft-2019"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Financial Times articles of 2019, as summarised by ESMA, reported that half of Wirecard's revenue and almost all its profit came from three opaque partners and that profits were channelled mainly through CardSystems Middle East in Dubai; later reports said that payments for clients routed through Al Alam included companies that had never heard of it and that EUR 334 million on trust accounts in 2017 had been wrongly classified as cash. Wirecard rejected such allegations at the time. On 22 June 2020 it stated that the trust account balances of EUR 1.9 billion probably did not exist."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-1cc54b58c664afef9d1d979b","record":{"id":"display-claim-1cc54b58c664afef9d1d979b","kind":"analysis","text":"On 18 June 2020 Wirecard announced that EY could not obtain sufficient audit evidence for EUR 1.9 billion on trust accounts, about a quarter of the balance sheet total, that there were indications of false balance confirmations presented to deceive the auditor, and that the 2019 accounts were postponed. Four days later it said there was a prevailing likelihood that the balances did not exist, and ESMA records that the company filed for insolvency a week later. According to press reports, the governor of the Philippine central bank said the money had not entered the Philippine financial system and that the names of BDO Unibank and Bank of the Philippine Islands had been used to cover the perpetrators' tracks; both banks said Wirecard was not their client. A European Parliament briefing notes that the key question of KPMG's special audit was whether EUR 1.9 billion supposedly held in an escrow account at OCBC Bank in Singapore existed, and that the report did not clarify all questions; according to a later press report, OCBC told the insolvency administrator that it had never held significant sums for the trustee and that some accounts had never existed.","source_ids":["src-024","src-025","src-087","src-031","src-067"],"entity_ids":["wirecard","ey","esma","europarl","kpmg","bdo","bpi","ocbc","jaffe"],"premise_claim_ids":["c-tpa-adhoc-2020-06-18","c-tpa-2020-06-22","c-tpa-philippines","c-tpa-ocbc"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 18 June 2020 Wirecard announced that EY could not obtain sufficient audit evidence for EUR 1.9 billion on trust accounts, about a quarter of the balance sheet total, that there were indications of false balance confirmations presented to deceive the auditor, and that the 2019 accounts were postponed. Four days later it said there was a prevailing likelihood that the balances did not exist, and ESMA records that the company filed for insolvency a week later. According to press reports, the governor of the Philippine central bank said the money had not entered the Philippine financial system and that the names of BDO Unibank and Bank of the Philippine Islands had been used to cover the perpetrators' tracks; both banks said Wirecard was not their client. A European Parliament briefing notes that the key question of KPMG's special audit was whether EUR 1.9 billion supposedly held in an escrow account at OCBC Bank in Singapore existed, and that the report did not clarify all questions; according to a later press report, OCBC told the insolvency administrator that it had never held significant sums for the trustee and that some accounts had never existed."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-a1699cee6b9855fd10fdd883","record":{"id":"display-claim-a1699cee6b9855fd10fdd883","kind":"analysis","text":"EY gave unqualified opinions on Wirecard's accounts for every year from 2009 to 2018, as the Finance Ministry reported to the Bundestag. On 31 March 2023 Germany's auditor oversight body APAS found breaches of professional duties in the 2016–2018 audits of Wirecard AG and Wirecard Bank AG, fined the audit firm EUR 500,000 and barred it for two years from new statutory audits of public-interest entities; its announcement does not name the firm, which for those years was EY. ESMA's peer review of November 2020 found a heightened risk of Finance Ministry influence on BaFin, trading in Wirecard shares by some staff of BaFin's market-abuse team, and that the enforcement panel FREP did not select the 2015–2017 accounts for examination nor did BaFin request it.","source_ids":["src-069","src-030","src-087"],"entity_ids":["wirecard","ey","bmf","apas","wd-bank","esma","bafin","dpr"],"premise_claim_ids":["c-aud-unqualified-2009-2018","c-aud-apas","c-sup-esma-findings"],"qualification":"","response":"","outcome":""},"reading":"Analysis: EY gave unqualified opinions on Wirecard's accounts for every year from 2009 to 2018, as the Finance Ministry reported to the Bundestag. On 31 March 2023 Germany's auditor oversight body APAS found breaches of professional duties in the 2016–2018 audits of Wirecard AG and Wirecard Bank AG, fined the audit firm EUR 500,000 and barred it for two years from new statutory audits of public-interest entities; its announcement does not name the firm, which for those years was EY. ESMA's peer review of November 2020 found a heightened risk of Finance Ministry influence on BaFin, trading in Wirecard shares by some staff of BaFin's market-abuse team, and that the enforcement panel FREP did not select the 2015–2017 accounts for examination nor did BaFin request it."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-c60ae7f83b81e82e3a9a74fe","record":{"id":"display-claim-c60ae7f83b81e82e3a9a74fe","kind":"analysis","text":"Wirecard AG applied to open insolvency proceedings on 25 June 2020, and the Munich insolvency court appointed Dr. Michael Jaffé as preliminary administrator. The European technology platform was sold to the Santander group, closing on 28 January 2021; North America, Brazil and Romania had already been sold. According to the Federal Court of Justice, about 50,000 shareholders filed claims of about EUR 8.5 billion, and claims in total of about EUR 15.4 billion face an estate of about EUR 650 million.","source_ids":["src-009","src-002","src-025","src-029","src-056"],"entity_ids":["wirecard","jaffe","ag-muenchen","wd-tech","santander","wd-north-america","syncapay","wd-brazil","pagseguro","wd-romania","sibs","bgh"],"premise_claim_ids":["c-ins-petition","c-ins-santander","c-ins-claims"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard AG applied to open insolvency proceedings on 25 June 2020, and the Munich insolvency court appointed Dr. Michael Jaffé as preliminary administrator. The European technology platform was sold to the Santander group, closing on 28 January 2021; North America, Brazil and Romania had already been sold. According to the Federal Court of Justice, about 50,000 shareholders filed claims of about EUR 8.5 billion, and claims in total of about EUR 15.4 billion face an estate of about EUR 650 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-f4a7aa113536a8240710ccde","record":{"id":"display-claim-f4a7aa113536a8240710ccde","kind":"analysis","text":"On 10 March 2022 the Munich I prosecutor charged the former chief executive, the former head of accounting and the former managing director of the Dubai subsidiary CardSystems Middle East, later named in the press as Markus Braun, Stephan von Erffa and Oliver Bellenhaus; the indictment states the prosecution's case, which the court has to establish. The trial began on 8 December 2022 and hearing dates have been set up to 23 December 2026, with no judgment by the cutoff. According to a press report of September 2026, the presiding judge said there were no indications that the TPA business existed and called Braun's account that its proceeds were embezzled by Marsalek's circle untenable speculation. The statements are not a judgment, the defendants are presumed innocent until a final verdict, and Braun maintains his account.","source_ids":["src-038","src-051","src-054","src-060"],"entity_ids":["sta-muenchen","braun","von-erffa","bellenhaus","cardsystems-me","wirecard","lg-muenchen","marsalek"],"premise_claim_ids":["c-crim-indictment-2022","c-crim-judge-2026"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 10 March 2022 the Munich I prosecutor charged the former chief executive, the former head of accounting and the former managing director of the Dubai subsidiary CardSystems Middle East, later named in the press as Markus Braun, Stephan von Erffa and Oliver Bellenhaus; the indictment states the prosecution's case, which the court has to establish. The trial began on 8 December 2022 and hearing dates have been set up to 23 December 2026, with no judgment by the cutoff. According to a press report of September 2026, the presiding judge said there were no indications that the TPA business existed and called Braun's account that its proceeds were embezzled by Marsalek's circle untenable speculation. The statements are not a judgment, the defendants are presumed innocent until a final verdict, and Braun maintains his account."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-15c86b84386443c0380cd38a","record":{"id":"display-claim-15c86b84386443c0380cd38a","kind":"analysis","text":"Jan Marsalek is under investigation for professional gang fraud, aggravated breach of trust and other offences, and the Federal Criminal Police Office has issued a public appeal for his arrest; he has not been tried. In sentencing remarks of 12 May 2025 in a London case of conspiracy to spy for Russia, the judge recorded the prosecution's case that the agent using the alias \"Rupert Ticz\" was Marsalek; the main defendant's plea did not accept the identification but agreed it did not matter.","source_ids":["src-003","src-037"],"entity_ids":["sta-muenchen","bka","marsalek","wirecard","roussev","fsb"],"premise_claim_ids":["c-crim-marsalek-wanted","c-mar-uk-trial"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Jan Marsalek is under investigation for professional gang fraud, aggravated breach of trust and other offences, and the Federal Criminal Police Office has issued a public appeal for his arrest; he has not been tried. In sentencing remarks of 12 May 2025 in a London case of conspiracy to spy for Russia, the judge recorded the prosecution's case that the agent using the alias \"Rupert Ticz\" was Marsalek; the main defendant's plea did not accept the identification but agreed it did not matter."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-0daca3123c756cd59ccd71e1","record":{"id":"display-claim-0daca3123c756cd59ccd71e1","kind":"analysis","text":"Wirecard AG is a German Aktiengesellschaft registered with the Munich local court under HRB 169227 since 6 August 2007. Its 2019 bond prospectus traces it to a company incorporated in Berlin on 6 May 1999 and registered at the Charlottenburg local court under HRB 88060 B, which moved its seat after a shareholders' resolution of 14 June 2007. The register gives its earlier names as InfoGenie Europe AG and Wire Card AG and its earlier seats as Berlin and Grasbrunn, and a subsidiary's register entry confirms that InfoGenie Europe AG (HRB 88060 B) was renamed Wirecard AG. The register also records the mergers into the company of InfoGenie Deutschland GmbH and InfoGenie ComService GmbH of Berlin and, under merger agreements of 29 June 2005, of net sales GmbH and InfoGenie Global GmbH of Grasbrunn.","source_ids":["src-002","src-012","src-006","src-016","src-001"],"entity_ids":["wirecard","click2pay","infogenie-de","infogenie-comservice","net-sales","infogenie-global"],"premise_claim_ids":["c-id-registration","c-id-names","c-id-mergers"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard AG is a German Aktiengesellschaft registered with the Munich local court under HRB 169227 since 6 August 2007. Its 2019 bond prospectus traces it to a company incorporated in Berlin on 6 May 1999 and registered at the Charlottenburg local court under HRB 88060 B, which moved its seat after a shareholders' resolution of 14 June 2007. The register gives its earlier names as InfoGenie Europe AG and Wire Card AG and its earlier seats as Berlin and Grasbrunn, and a subsidiary's register entry confirms that InfoGenie Europe AG (HRB 88060 B) was renamed Wirecard AG. The register also records the mergers into the company of InfoGenie Deutschland GmbH and InfoGenie ComService GmbH of Berlin and, under merger agreements of 29 June 2005, of net sales GmbH and InfoGenie Global GmbH of Grasbrunn."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-179a266ef31580ced5176cb2","record":{"id":"display-claim-179a266ef31580ced5176cb2","kind":"analysis","text":"Its registered purpose is the development, operation and marketing of information services, especially through electronic media, and of technical applications, services and projects in payment systems, including the acquisition and granting of licences in the financial services sector. Register entries place it at Bretonischer Ring 4 in Grasbrunn from 3 March 2009, at Einsteinring 35 in Aschheim from 22 July 2011 and at Humboldtstraße 8 in Aschheim from 27 June 2022. Its subscribed capital was EUR 101,803,139, in as many no-par bearer shares, at the end of 2011; a capital increase registered on 9 March 2012 raised it to EUR 111,983,452, and further steps took it to EUR 123,565,586 by 26 January 2016.","source_ids":["src-001","src-002","src-010"],"entity_ids":["wirecard"],"premise_claim_ids":["c-id-purpose","c-id-addresses-capital","c-id-capital-2011"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Its registered purpose is the development, operation and marketing of information services, especially through electronic media, and of technical applications, services and projects in payment systems, including the acquisition and granting of licences in the financial services sector. Register entries place it at Bretonischer Ring 4 in Grasbrunn from 3 March 2009, at Einsteinring 35 in Aschheim from 22 July 2011 and at Humboldtstraße 8 in Aschheim from 27 June 2022. Its subscribed capital was EUR 101,803,139, in as many no-par bearer shares, at the end of 2011; a capital increase registered on 9 March 2012 raised it to EUR 111,983,452, and further steps took it to EUR 123,565,586 by 26 January 2016."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-6c7ed58e0b8c6717ab8f74ef","record":{"id":"display-claim-6c7ed58e0b8c6717ab8f74ef","kind":"analysis","text":"The 2019 bond prospectus gives Wirecard AG's Legal Entity Identifier as 529900A8LX4KL0YUTH71, which a registry aggregator repeats together with the European unique identifier DED2601V.HRB169227 and the earlier register numbers HRB 88060 B (Charlottenburg) and HRB 131672 (Munich). The same prospectus gives the identifiers of the five subsidiaries that guaranteed the bond: Wirecard Technologies GmbH 529900Z54V2EA48D2Y27, Wirecard Sales International Holding GmbH 529900VH0MQZASU8AR79, Wirecard Payment Solutions Holdings Limited of Dublin 529900BWETZJRMZMRV03, CardSystems Middle East FZ-LLC 529900QITH4S89RB2V17 and Wirecard Processing FZ-LLC 529900NB6TN7EHS4MA55.","source_ids":["src-012","src-001"],"entity_ids":["wirecard","wd-tech","wd-sih","wd-psh","cardsystems-me","wd-processing"],"premise_claim_ids":["c-id-identifiers","c-id-guarantor-leis"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The 2019 bond prospectus gives Wirecard AG's Legal Entity Identifier as 529900A8LX4KL0YUTH71, which a registry aggregator repeats together with the European unique identifier DED2601V.HRB169227 and the earlier register numbers HRB 88060 B (Charlottenburg) and HRB 131672 (Munich). The same prospectus gives the identifiers of the five subsidiaries that guaranteed the bond: Wirecard Technologies GmbH 529900Z54V2EA48D2Y27, Wirecard Sales International Holding GmbH 529900VH0MQZASU8AR79, Wirecard Payment Solutions Holdings Limited of Dublin 529900BWETZJRMZMRV03, CardSystems Middle East FZ-LLC 529900QITH4S89RB2V17 and Wirecard Processing FZ-LLC 529900NB6TN7EHS4MA55."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-a9b0d7b9da8dc288ffaebe68","record":{"id":"display-claim-a9b0d7b9da8dc288ffaebe68","kind":"analysis","text":"A registry aggregator lists six group companies at the later address, Humboldtstraße 8 in Aschheim: WDB Abwicklungs AG, formerly Wirecard Bank AG (HRB 161178), Wirecard Acquiring & Issuing GmbH, Wirecard Global Sales GmbH, Wirecard Sales International Holding GmbH, Wirecard Service Technologies GmbH and Wirecard Technologies GmbH. Its network view of the German register shows Click2Pay GmbH, Wirecard Sales International Holding GmbH and Wirecard Technologies GmbH as wholly owned by Wirecard AG; for a stock corporation such as Wirecard AG itself the register keeps no shareholder list.","source_ids":["src-002","src-033"],"entity_ids":["wirecard","wd-bank","wd-acq-iss","wd-global-sales","wd-sih","wd-service-tech","wd-tech","click2pay"],"premise_claim_ids":["c-id-same-address","c-str-registry-profile"],"qualification":"","response":"","outcome":""},"reading":"Analysis: A registry aggregator lists six group companies at the later address, Humboldtstraße 8 in Aschheim: WDB Abwicklungs AG, formerly Wirecard Bank AG (HRB 161178), Wirecard Acquiring & Issuing GmbH, Wirecard Global Sales GmbH, Wirecard Sales International Holding GmbH, Wirecard Service Technologies GmbH and Wirecard Technologies GmbH. Its network view of the German register shows Click2Pay GmbH, Wirecard Sales International Holding GmbH and Wirecard Technologies GmbH as wholly owned by Wirecard AG; for a stock corporation such as Wirecard AG itself the register keeps no shareholder list."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-d0d097e1c35a3a825692ab57","record":{"id":"display-claim-d0d097e1c35a3a825692ab57","kind":"analysis","text":"The invitation to the annual general meeting of 26 June 2012 asked shareholders to approve control and profit-transfer agreements concluded on 10 May 2012 with Wire Card Beteiligungs GmbH and Trustpay International GmbH, which were to be renamed Wirecard Acquiring & Issuing GmbH and Wirecard Sales International GmbH. Markus Braun, Burkhard Ley and Jan Marsalek signed for Wirecard AG's management board; Braun also signed for the management of Wire Card Beteiligungs GmbH and Marsalek for that of Trustpay International GmbH. In its 2018 single-entity accounts Wirecard AG states that, for corporate-law reasons, it issued a letter of comfort covering all liabilities of Wirecard Payment Solutions Holdings Ltd. of Dublin and did not expect to be called upon under it; the amounts are not legible in the retained text of the accounts. Under an internal cash-management agreement described in the 2019 prospectus, Wirecard AG supplied subsidiaries with funds for their operations and collected their unused surpluses.","source_ids":["src-050","src-008","src-012"],"entity_ids":["wirecard","wd-acq-iss","wd-sih","braun","ley","marsalek","wd-psh"],"premise_claim_ids":["c-str-2012-control-agreements","c-str-parent-guarantees-2018","c-fin-cash-pool"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The invitation to the annual general meeting of 26 June 2012 asked shareholders to approve control and profit-transfer agreements concluded on 10 May 2012 with Wire Card Beteiligungs GmbH and Trustpay International GmbH, which were to be renamed Wirecard Acquiring & Issuing GmbH and Wirecard Sales International GmbH. Markus Braun, Burkhard Ley and Jan Marsalek signed for Wirecard AG's management board; Braun also signed for the management of Wire Card Beteiligungs GmbH and Marsalek for that of Trustpay International GmbH. In its 2018 single-entity accounts Wirecard AG states that, for corporate-law reasons, it issued a letter of comfort covering all liabilities of Wirecard Payment Solutions Holdings Ltd. of Dublin and did not expect to be called upon under it; the amounts are not legible in the retained text of the accounts. Under an internal cash-management agreement described in the 2019 prospectus, Wirecard AG supplied subsidiaries with funds for their operations and collected their unused surpluses."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-e330a238e635436df3944d50","record":{"id":"display-claim-e330a238e635436df3944d50","kind":"analysis","text":"Wirecard's 2010 annual report lists its subsidiaries, each held at 100%: Click2Pay GmbH; InfoGenie Ltd. of Windsor; Wirecard (Gibraltar) Ltd.; Trustpay International GmbH, formerly Trustpay International AG; the Dublin companies Wirecard Payment Solutions Holdings Ltd., Wirecard UK and Ireland Ltd. (formerly Wirecard Payment Solutions Ltd.) and Herview Ltd.; Wirecard Central Eastern Europe GmbH of Klagenfurt; Wirecard Technologies AG; Wirecard Communication Services GmbH of Leipzig; Wirecard Retail Services GmbH; cardSystems FZ-LLC of Dubai; Wire Card Beteiligungs GmbH; Wirecard Bank AG; and in Asia E-Credit Plus Pte. Ltd. (later Wirecard Asia Pte. Ltd.), E-Credit Plus Corp. of the Philippines, Credence Collection SDN BHD of Malaysia and E-Payments Singapore Pte. Ltd. To simplify the group, Pro Card Kartensysteme GmbH was merged into Wirecard Retail Services GmbH in 2010 and webcommunication EDV of Graz into Wirecard Central Eastern Europe; 18 subsidiaries were fully consolidated at the end of 2010, against 16 a year earlier.","source_ids":["src-023"],"entity_ids":["wirecard","click2pay","infogenie-ltd","wd-gibraltar","wd-sih","wd-psh","wd-uki","herview","wd-cee","wd-tech","wd-comm-services","wd-retail-services","cardsystems-fz","wd-acq-iss","wd-bank","wd-asia-pte","ecredit-corp","wd-malaysia","epayments-sg","procard-kartensysteme"],"premise_claim_ids":["c-str-2010-list","c-str-2010-mergers"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard's 2010 annual report lists its subsidiaries, each held at 100%: Click2Pay GmbH; InfoGenie Ltd. of Windsor; Wirecard (Gibraltar) Ltd.; Trustpay International GmbH, formerly Trustpay International AG; the Dublin companies Wirecard Payment Solutions Holdings Ltd., Wirecard UK and Ireland Ltd. (formerly Wirecard Payment Solutions Ltd.) and Herview Ltd.; Wirecard Central Eastern Europe GmbH of Klagenfurt; Wirecard Technologies AG; Wirecard Communication Services GmbH of Leipzig; Wirecard Retail Services GmbH; cardSystems FZ-LLC of Dubai; Wire Card Beteiligungs GmbH; Wirecard Bank AG; and in Asia E-Credit Plus Pte. Ltd. (later Wirecard Asia Pte. Ltd.), E-Credit Plus Corp. of the Philippines, Credence Collection SDN BHD of Malaysia and E-Payments Singapore Pte. Ltd. To simplify the group, Pro Card Kartensysteme GmbH was merged into Wirecard Retail Services GmbH in 2010 and webcommunication EDV of Graz into Wirecard Central Eastern Europe; 18 subsidiaries were fully consolidated at the end of 2010, against 16 a year earlier."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-451b514c6c9417c1917cdaff","record":{"id":"display-claim-451b514c6c9417c1917cdaff","kind":"analysis","text":"In 2011 the number of fully consolidated subsidiaries rose to 22 with Procard Services FZ LLC of Dubai and Systems@Work Pte. Ltd., Systems@Work (M) SDN BHD and Safe2Pay Pte. Ltd. in Singapore and Kuala Lumpur, and the Malaysian Credence Collection became Wirecard Malaysia SDN BHD. Wire Card Beteiligungs GmbH and Trustpay International GmbH in Aschheim acted as intermediate holding companies without operating business of their own and, with Wirecard Technologies AG, were exempt from preparing their own consolidated accounts because Wirecard AG's group accounts covered them. The 2011 report describes Wirecard Technologies AG and Wirecard (Gibraltar) Ltd. as developers and operators of the software platform at the centre of the group's products, Click2Pay GmbH as operator of the CLICK2PAY internet payment system, and the Dublin companies and Wirecard Central Eastern Europe as providers of sales and processing services.","source_ids":["src-010"],"entity_ids":["wirecard","procard","wd-singapore","systemsatwork-my","safe2pay","wd-sih","wd-acq-iss","wd-tech","cardsystems-fz","wd-asia-pte","ecredit-corp","wd-malaysia","epayments-sg","wd-gibraltar","click2pay","wd-psh","wd-uki","herview","wd-cee"],"premise_claim_ids":["c-str-2011-list","c-str-2011-holdings","c-str-2011-functions"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In 2011 the number of fully consolidated subsidiaries rose to 22 with Procard Services FZ LLC of Dubai and Systems@Work Pte. Ltd., Systems@Work (M) SDN BHD and Safe2Pay Pte. Ltd. in Singapore and Kuala Lumpur, and the Malaysian Credence Collection became Wirecard Malaysia SDN BHD. Wire Card Beteiligungs GmbH and Trustpay International GmbH in Aschheim acted as intermediate holding companies without operating business of their own and, with Wirecard Technologies AG, were exempt from preparing their own consolidated accounts because Wirecard AG's group accounts covered them. The 2011 report describes Wirecard Technologies AG and Wirecard (Gibraltar) Ltd. as developers and operators of the software platform at the centre of the group's products, Click2Pay GmbH as operator of the CLICK2PAY internet payment system, and the Dublin companies and Wirecard Central Eastern Europe as providers of sales and processing services."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-0d0dd53306d6df437d6434a6","record":{"id":"display-claim-0d0dd53306d6df437d6434a6","kind":"analysis","text":"ESMA notes that the 2014 consolidated accounts covered 33 wholly owned companies. By the end of 2016, 46 subsidiaries were fully consolidated, against 37 a year earlier, and the shareholdings list included companies that no longer appear under those names in 2018, such as Payment Technologies Ltd. of Wilmington, Provus Service Provider S.A. of Bucharest and Trans Infotech (Vietnam) and (Laos). The 2017 list records Provus as Wirecard Romania S.A., Trans Infotech (Vietnam) as Wirecard (Vietnam) Ltd. and Systems@Work as Wirecard Singapore Pte. Ltd. In 2017 the group founded Wirecard (Thailand) Co. Ltd., Wirecard E-Money Philippines Inc. and three German companies in Aschheim: Wirecard Issuing Technologies, Wirecard Service Technologies and Wirecard Acceptance Technologies.","source_ids":["src-087","src-032","src-020"],"entity_ids":["wirecard","esma","payment-tech","wd-romania","wd-vietnam","trans-laos","wd-singapore","wd-thailand","wd-emoney-ph","wd-issuing-tech","wd-service-tech","wd-acceptance-tech"],"premise_claim_ids":["c-str-2014-count","c-str-2016-list","c-str-2017-list","c-str-2017-founded"],"qualification":"","response":"","outcome":""},"reading":"Analysis: ESMA notes that the 2014 consolidated accounts covered 33 wholly owned companies. By the end of 2016, 46 subsidiaries were fully consolidated, against 37 a year earlier, and the shareholdings list included companies that no longer appear under those names in 2018, such as Payment Technologies Ltd. of Wilmington, Provus Service Provider S.A. of Bucharest and Trans Infotech (Vietnam) and (Laos). The 2017 list records Provus as Wirecard Romania S.A., Trans Infotech (Vietnam) as Wirecard (Vietnam) Ltd. and Systems@Work as Wirecard Singapore Pte. Ltd. In 2017 the group founded Wirecard (Thailand) Co. Ltd., Wirecard E-Money Philippines Inc. and three German companies in Aschheim: Wirecard Issuing Technologies, Wirecard Service Technologies and Wirecard Acceptance Technologies."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-b8c89017db0811bd28b66438","record":{"id":"display-claim-b8c89017db0811bd28b66438","kind":"analysis","text":"The shareholdings list in the 2018 annual report counts 53 fully consolidated subsidiaries (50 a year earlier), all held directly or indirectly at 100% except GI Technology Pte. Ltd. of Chennai, held at 60% and accounted for by the equity method. Besides the holding companies in Aschheim and Dublin it includes Asian companies such as Wirecard Asia Holding Pte. Ltd. and Wirecard Singapore Pte. Ltd., PT Prima Vista Solusi and PT Aprisma Indonesia, Wirecard India Private Ltd., Hermes I Tickets Pte Ltd of Chennai, GI Philippines Corp and Wirecard Forex India; Wirecard Romania with Romcard and Supercard of Bucharest; Wirecard companies in Poland, Mexico, Brazil, Turkey, Luxembourg, Slovakia, South Africa, Namibia, Australia, New Zealand, Hong Kong and Moscow; American Payment Holding Inc. of Toronto and Wirecard North America Inc. of Conshohocken; the Dubai companies cardSystems Middle East FZ-LLC and Wirecard Processing FZ LLC; and Wirecard Bank AG, Wirecard Acquiring & Issuing GmbH and Wirecard Card Solutions Ltd. of Newcastle. The 2019 prospectus adds the companies founded in 2018 in Košice, Moscow, Luxembourg and Windhoek and three founded in 2019: Beijing Wirecard Technology Solutions, Wirecard U.S. Holdings, Inc. and WDB US, Inc. of Salt Lake City.","source_ids":["src-005","src-012"],"entity_ids":["wirecard","wd-sih","wd-psh","wd-uki","herview","wd-cee","wd-asia-holding","wd-singapore","wd-vietnam","wd-ps-malaysia","prima-vista","wd-indonesia","wd-myanmar","wd-thailand","wd-india","american-payment","hermes","gi-philippines","wd-forex-india","wd-romania","romcard","supercard","wd-global-sales","wd-poland","wd-llc","wd-mexico","wd-tech","wd-comm-services","wd-retail-services","cardsystems-me","mygate","wd-acceptance-tech","wd-service-tech","wd-issuing-tech","wd-nz","wd-australia","wd-africa-holding","wd-south-africa","wd-namibia","wd-slovakia","click2pay","wd-gibraltar","wd-processing","wd-acq-iss","wd-bank","wd-brazil","wd-card-solutions","wd-emoney-ph","wd-luxembourg","wd-turkey","wd-north-america","wd-australia-ai","wd-hk","wd-ps-hk","gi-technology","beijing-wd","wd-us-holding","wdb-us"],"premise_claim_ids":["c-str-2018-list-1","c-str-2018-list-2","c-str-2018-founded"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The shareholdings list in the 2018 annual report counts 53 fully consolidated subsidiaries (50 a year earlier), all held directly or indirectly at 100% except GI Technology Pte. Ltd. of Chennai, held at 60% and accounted for by the equity method. Besides the holding companies in Aschheim and Dublin it includes Asian companies such as Wirecard Asia Holding Pte. Ltd. and Wirecard Singapore Pte. Ltd., PT Prima Vista Solusi and PT Aprisma Indonesia, Wirecard India Private Ltd., Hermes I Tickets Pte Ltd of Chennai, GI Philippines Corp and Wirecard Forex India; Wirecard Romania with Romcard and Supercard of Bucharest; Wirecard companies in Poland, Mexico, Brazil, Turkey, Luxembourg, Slovakia, South Africa, Namibia, Australia, New Zealand, Hong Kong and Moscow; American Payment Holding Inc. of Toronto and Wirecard North America Inc. of Conshohocken; the Dubai companies cardSystems Middle East FZ-LLC and Wirecard Processing FZ LLC; and Wirecard Bank AG, Wirecard Acquiring & Issuing GmbH and Wirecard Card Solutions Ltd. of Newcastle. The 2019 prospectus adds the companies founded in 2018 in Košice, Moscow, Luxembourg and Windhoek and three founded in 2019: Beijing Wirecard Technology Solutions, Wirecard U.S. Holdings, Inc. and WDB US, Inc. of Salt Lake City."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-4f8d0527829aa25b059d6b47","record":{"id":"display-claim-4f8d0527829aa25b059d6b47","kind":"analysis","text":"The 2019 bond prospectus still lists every subsidiary at 100% except GI Technology (60%), among them PT Wirecard Technologies Indonesia, Wirecard Solutions South Africa (Pty) Ltd of Cape Town, Wirecard Bank AG, Wirecard Card Solutions Ltd. and Wirecard North America Inc. The half-year report at 30 June 2019 counts 53 fully consolidated subsidiaries, names PT Wirecard Technologies Indonesia as the former PT Aprisma Indonesia and records the merger of Wirecard South Africa and MyGate Communications into Wirecard Africa Holding Proprietary Ltd. of Cape Town.","source_ids":["src-012","src-066"],"entity_ids":["wirecard","gi-technology","wd-indonesia","wd-sa-solutions","beijing-wd","wd-us-holding","wdb-us","wd-bank","wd-card-solutions","wd-north-america","wd-south-africa","mygate","wd-africa-holding"],"premise_claim_ids":["c-str-2019-list","c-str-2019-halfyear"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The 2019 bond prospectus still lists every subsidiary at 100% except GI Technology (60%), among them PT Wirecard Technologies Indonesia, Wirecard Solutions South Africa (Pty) Ltd of Cape Town, Wirecard Bank AG, Wirecard Card Solutions Ltd. and Wirecard North America Inc. The half-year report at 30 June 2019 counts 53 fully consolidated subsidiaries, names PT Wirecard Technologies Indonesia as the former PT Aprisma Indonesia and records the merger of Wirecard South Africa and MyGate Communications into Wirecard Africa Holding Proprietary Ltd. of Cape Town."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-d28effb97cf8dc025a32329c","record":{"id":"display-claim-d28effb97cf8dc025a32329c","kind":"analysis","text":"Wirecard Sales International Holding GmbH began as the shelf company Blitz 07-210 AG, registered in Munich on 30 April 2007 under HRB 167639 with capital of EUR 50,000; as Trustpay International AG it later moved to Grasbrunn. It was deleted on 24 August 2010, when it was converted into Trustpay International GmbH (HRB 187465), which its shareholders renamed Wirecard Sales International GmbH on 10 May 2012 and Wirecard Sales International Holding GmbH on 18 July 2016. According to the 2019 prospectus Wirecard AG was its sole shareholder, its capital of EUR 50,000 consisted of one share and BakerTilly audited its accounts. Its control and profit-transfer agreement with Wirecard AG, concluded on 10 May 2012 and registered on 11 July 2012, ended by termination on 20 August 2020.","source_ids":["src-011","src-012","src-014","src-001"],"entity_ids":["wd-sih","wirecard","bakertilly"],"premise_claim_ids":["c-str-trustpay-ag","c-str-wsih-history","c-str-wsih-owner","c-str-wsih-control"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard Sales International Holding GmbH began as the shelf company Blitz 07-210 AG, registered in Munich on 30 April 2007 under HRB 167639 with capital of EUR 50,000; as Trustpay International AG it later moved to Grasbrunn. It was deleted on 24 August 2010, when it was converted into Trustpay International GmbH (HRB 187465), which its shareholders renamed Wirecard Sales International GmbH on 10 May 2012 and Wirecard Sales International Holding GmbH on 18 July 2016. According to the 2019 prospectus Wirecard AG was its sole shareholder, its capital of EUR 50,000 consisted of one share and BakerTilly audited its accounts. Its control and profit-transfer agreement with Wirecard AG, concluded on 10 May 2012 and registered on 11 July 2012, ended by termination on 20 August 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-cb42f0b2a681fce07d884403","record":{"id":"display-claim-cb42f0b2a681fce07d884403","kind":"analysis","text":"Wirecard Technologies GmbH was formed on 13 August 2012 by converting Wirecard Technologies AG. According to the prospectus that company started on 24 August 2000 as a shelf company registered in Potsdam, was renamed \"Wirecard AG\" on 21 January 2002, a name that then belonged to this predecessor and not to the listed parent, which was called InfoGenie Europe AG and later Wire Card AG, took the name Wirecard Technologies AG on 17 December 2004 and has had its seat in Aschheim since 11 April 2011. The prospectus describes it as an intermediate holding company wholly owned by Wirecard AG and parent of Wirecard Issuing Technologies and Wirecard Acceptance Technologies among others, with share capital of EUR 1,101,000 and EY as auditor for 2017 and 2018. Its register shows a profit-transfer agreement of 19 July 2005 with Wire Card AG and a control agreement of 7 May 2008 with Wirecard AG, both terminated at the end of 2018, and a new profit-transfer agreement of 11 December 2018 that ended by termination on 20 August 2020.","source_ids":["src-012","src-015","src-001"],"entity_ids":["wd-tech","wirecard","wd-issuing-tech","wd-acceptance-tech","ey"],"premise_claim_ids":["c-str-wdtech-history","c-str-wdtech-holding","c-str-wdtech-agreements"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard Technologies GmbH was formed on 13 August 2012 by converting Wirecard Technologies AG. According to the prospectus that company started on 24 August 2000 as a shelf company registered in Potsdam, was renamed \"Wirecard AG\" on 21 January 2002, a name that then belonged to this predecessor and not to the listed parent, which was called InfoGenie Europe AG and later Wire Card AG, took the name Wirecard Technologies AG on 17 December 2004 and has had its seat in Aschheim since 11 April 2011. The prospectus describes it as an intermediate holding company wholly owned by Wirecard AG and parent of Wirecard Issuing Technologies and Wirecard Acceptance Technologies among others, with share capital of EUR 1,101,000 and EY as auditor for 2017 and 2018. Its register shows a profit-transfer agreement of 19 July 2005 with Wire Card AG and a control agreement of 7 May 2008 with Wirecard AG, both terminated at the end of 2018, and a new profit-transfer agreement of 11 December 2018 that ended by termination on 20 August 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-258937bce1e0d90a97bf7dde","record":{"id":"display-claim-258937bce1e0d90a97bf7dde","kind":"analysis","text":"Wirecard Acquiring & Issuing GmbH (HRB 156848, capital EUR 25,000) was registered on 15 April 2005 as the shelf company Blitz 05-059 GmbH. In June 2005 it became Wire Card Beteiligungs GmbH, moved to Grasbrunn and took on the purpose of acquiring and managing holdings; it received its later name on 10 May 2012, the day it concluded a control and profit-transfer agreement with Wirecard AG that ended with effect from 20 August 2020. Click2Pay GmbH (HRB 149001) was registered on 1 September 2003 as Matterhorn 291. V V GmbH and moved through Hallbergmoos and Grasbrunn to Aschheim; its control and profit-transfer agreement of 28 May 2004 with InfoGenie Europe AG, later Wirecard AG, ended by termination on 10 September 2020. Wirecard Global Sales GmbH (HRB 223366) was founded on 15 January 2016 as Wirecard Sales Europe GmbH, a holding company for interests in payment-system companies with capital of EUR 50,000, and was renamed by a resolution of 18 January 2016 registered on 22 July 2016.","source_ids":["src-013","src-001","src-016","src-018"],"entity_ids":["wd-acq-iss","wirecard","click2pay","wd-global-sales"],"premise_claim_ids":["c-str-acq-iss-history","c-str-acq-iss-control","c-str-click2pay","c-str-global-sales"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard Acquiring & Issuing GmbH (HRB 156848, capital EUR 25,000) was registered on 15 April 2005 as the shelf company Blitz 05-059 GmbH. In June 2005 it became Wire Card Beteiligungs GmbH, moved to Grasbrunn and took on the purpose of acquiring and managing holdings; it received its later name on 10 May 2012, the day it concluded a control and profit-transfer agreement with Wirecard AG that ended with effect from 20 August 2020. Click2Pay GmbH (HRB 149001) was registered on 1 September 2003 as Matterhorn 291. V V GmbH and moved through Hallbergmoos and Grasbrunn to Aschheim; its control and profit-transfer agreement of 28 May 2004 with InfoGenie Europe AG, later Wirecard AG, ended by termination on 10 September 2020. Wirecard Global Sales GmbH (HRB 223366) was founded on 15 January 2016 as Wirecard Sales Europe GmbH, a holding company for interests in payment-system companies with capital of EUR 50,000, and was renamed by a resolution of 18 January 2016 registered on 22 July 2016."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-7d87e8c77351757c8c41276c","record":{"id":"display-claim-7d87e8c77351757c8c41276c","kind":"analysis","text":"The three companies founded in 2017 were registered between September 2017 and January 2018: Wirecard Issuing Technologies GmbH (HRB 235570), Wirecard Acceptance Technologies GmbH (HRB 238107) and Wirecard Service Technologies GmbH (HRB 238150), each with capital of EUR 25,000 at Einsteinring 35 in Aschheim, developing payment, risk and cash-management applications. Wirecard Communication Services GmbH, which provides communication and call-centre services, was founded in Berlin on 7 May 2003 as United Data GmbH, moved its seat to Leipzig by a resolution of 22 January 2009 (HRB 24925, capital EUR 30,400) and is shown in a register database as in liquidation.","source_ids":["src-042","src-041","src-043","src-049","src-019"],"entity_ids":["wd-issuing-tech","wd-acceptance-tech","wd-service-tech","wd-comm-services"],"premise_claim_ids":["c-str-new-german-subs","c-str-comm-services"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The three companies founded in 2017 were registered between September 2017 and January 2018: Wirecard Issuing Technologies GmbH (HRB 235570), Wirecard Acceptance Technologies GmbH (HRB 238107) and Wirecard Service Technologies GmbH (HRB 238150), each with capital of EUR 25,000 at Einsteinring 35 in Aschheim, developing payment, risk and cash-management applications. Wirecard Communication Services GmbH, which provides communication and call-centre services, was founded in Berlin on 7 May 2003 as United Data GmbH, moved its seat to Leipzig by a resolution of 22 January 2009 (HRB 24925, capital EUR 30,400) and is shown in a register database as in liquidation."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-afbc96a05c21ec9ec2b0975c","record":{"id":"display-claim-afbc96a05c21ec9ec2b0975c","kind":"analysis","text":"Wirecard Payment Solutions Holdings Limited (Companies Registration Office number 409925) was first named Gateway E-Commerce Solutions Holdings Limited and then Gateway Payment Solutions Holdings Limited, and has carried its current name since 21 December 2007. The 2019 prospectus describes it as an Irish holding company wholly owned by Wirecard Sales International Holding GmbH, itself wholly owned by Wirecard AG. Ireland's Corporate Enforcement Authority states that from 2015 it was the sole shareholder of Wirecard UK & Ireland Limited, which processed credit and prepaid card transactions and belonged to the same group as Herview Limited. Wirecard UK & Ireland became insolvent as a result of the suspected fraud in the Wirecard AG group, which included EUR 1.9 billion supposedly held in an escrow account that was later found not to exist. A commercial database shows both Irish companies, incorporated on 25 October 2005 with a Dublin address, in liquidation, with liquidator's statements up to August 2026.","source_ids":["src-012","src-044","src-064","src-093"],"entity_ids":["wd-psh","wd-sih","wirecard","wd-uki","herview","cea-ireland"],"premise_claim_ids":["c-str-wpsh","c-str-wuki-owner","c-str-irish-liquidation"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard Payment Solutions Holdings Limited (Companies Registration Office number 409925) was first named Gateway E-Commerce Solutions Holdings Limited and then Gateway Payment Solutions Holdings Limited, and has carried its current name since 21 December 2007. The 2019 prospectus describes it as an Irish holding company wholly owned by Wirecard Sales International Holding GmbH, itself wholly owned by Wirecard AG. Ireland's Corporate Enforcement Authority states that from 2015 it was the sole shareholder of Wirecard UK & Ireland Limited, which processed credit and prepaid card transactions and belonged to the same group as Herview Limited. Wirecard UK & Ireland became insolvent as a result of the suspected fraud in the Wirecard AG group, which included EUR 1.9 billion supposedly held in an escrow account that was later found not to exist. A commercial database shows both Irish companies, incorporated on 25 October 2005 with a Dublin address, in liquidation, with liquidator's statements up to August 2026."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-f41b2d1b93fd0576146c228f","record":{"id":"display-claim-f41b2d1b93fd0576146c228f","kind":"analysis","text":"In Dubai, CardSystems Middle East FZ-LLC was, according to the 2019 prospectus, an indirect subsidiary of Wirecard AG wholly owned by Wirecard Technologies GmbH; it operated in the group's Asia-Pacific region and cooperated with banks and financial service providers so that it could offer acquiring and issuing services where Wirecard could not use its own licence. Wirecard Processing FZ LLC, also in Dubai, was a direct wholly owned subsidiary of Wirecard AG whose directors were Oliver Bellenhaus and Susanne Steidl.","source_ids":["src-012"],"entity_ids":["cardsystems-me","wirecard","wd-tech","wd-processing","bellenhaus","steidl"],"premise_claim_ids":["c-str-cardsystems-owner","c-str-processing"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In Dubai, CardSystems Middle East FZ-LLC was, according to the 2019 prospectus, an indirect subsidiary of Wirecard AG wholly owned by Wirecard Technologies GmbH; it operated in the group's Asia-Pacific region and cooperated with banks and financial service providers so that it could offer acquiring and issuing services where Wirecard could not use its own licence. Wirecard Processing FZ LLC, also in Dubai, was a direct wholly owned subsidiary of Wirecard AG whose directors were Oliver Bellenhaus and Susanne Steidl."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-39d0e037d451eb6ce9a2ad72","record":{"id":"display-claim-39d0e037d451eb6ce9a2ad72","kind":"analysis","text":"The first Munich register entry of 6 August 2007 names Dr. Markus Braun, Rüdiger Trautmann and Burkhard Ley as the management board and grants joint power of attorney to Andrea Görres, Thorsten Holten, Salim Chujfi La Roche, Eric Pudewill and Jan Marsalek. Trautmann stepped down as sales director for personal reasons at the end of January 2010 and Marsalek joined the board for sales on 1 February 2010; the register entry of 6 May 2010 records both changes and the end of Marsalek's power of attorney. The 2010 report names Ley as chief financial officer and Braun as chairman and chief technology officer. The 2011 report gives Braun's start on the board as 1 October 2004 and Ley's as 1 January 2006; on 22 December 2011 the supervisory board reappointed all three from 2012 for three years and extended their contracts to the end of 2014.","source_ids":["src-006","src-023","src-007","src-010"],"entity_ids":["wirecard","braun","trautmann","ley","goerres","holten","chujfi","pudewill","marsalek"],"premise_claim_ids":["c-lead-2007-board","c-lead-2010-marsalek","c-lead-2010-board","c-lead-2011-board"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The first Munich register entry of 6 August 2007 names Dr. Markus Braun, Rüdiger Trautmann and Burkhard Ley as the management board and grants joint power of attorney to Andrea Görres, Thorsten Holten, Salim Chujfi La Roche, Eric Pudewill and Jan Marsalek. Trautmann stepped down as sales director for personal reasons at the end of January 2010 and Marsalek joined the board for sales on 1 February 2010; the register entry of 6 May 2010 records both changes and the end of Marsalek's power of attorney. The 2010 report names Ley as chief financial officer and Braun as chairman and chief technology officer. The 2011 report gives Braun's start on the board as 1 October 2004 and Ley's as 1 January 2006; on 22 December 2011 the supervisory board reappointed all three from 2012 for three years and extended their contracts to the end of 2014."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-a6ee620e8315b60cb12733d0","record":{"id":"display-claim-a6ee620e8315b60cb12733d0","kind":"analysis","text":"The annual reports disclose the board's pay. Fixed salaries for 2010 were EUR 500,000 for Braun, EUR 450,000 for Ley, EUR 275,000 for Marsalek and EUR 282,500 for the departed Trautmann; total remuneration for 2011 was EUR 1.02 million for Braun, EUR 922,000 for Ley and EUR 703,000 for Marsalek. A change of control, defined as 30% or more of the votes, entitled each board member to a bonus tied to the company's value: 0.4% for Braun and Ley and 0.25% for Marsalek.","source_ids":["src-023","src-010"],"entity_ids":["wirecard","braun","ley","marsalek","trautmann"],"premise_claim_ids":["c-lead-pay-2010-2011"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The annual reports disclose the board's pay. Fixed salaries for 2010 were EUR 500,000 for Braun, EUR 450,000 for Ley, EUR 275,000 for Marsalek and EUR 282,500 for the departed Trautmann; total remuneration for 2011 was EUR 1.02 million for Braun, EUR 922,000 for Ley and EUR 703,000 for Marsalek. A change of control, defined as 30% or more of the votes, entitled each board member to a bonus tied to the company's value: 0.4% for Braun and Ley and 0.25% for Marsalek."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-91e0b2d7aa55a84a922ccacd","record":{"id":"display-claim-91e0b2d7aa55a84a922ccacd","kind":"analysis","text":"At the end of 2016 the management board still consisted of Braun (chairman, technology), Ley (finance) and Marsalek (sales). The supervisory board was chaired by Wulf Matthias, re-elected chairman on 16 June 2016, with Alfons W. Henseler as deputy and Tina Kleingarn, Stefan Klestil and Vuyiswa M'Cwabeni as members; Kleingarn and M'Cwabeni joined when the 2016 shareholders' meeting enlarged the board and first attended its meeting of 8 September 2016. The 2017 report names the same five supervisory board members, all in office throughout 2017, and records Ley as finance director until 31 December 2017.","source_ids":["src-032","src-020","src-005"],"entity_ids":["wirecard","braun","ley","marsalek","matthias","henseler","kleingarn","klestil","mcwabeni"],"premise_claim_ids":["c-lead-2016-boards","c-lead-2017-boards"],"qualification":"","response":"","outcome":""},"reading":"Analysis: At the end of 2016 the management board still consisted of Braun (chairman, technology), Ley (finance) and Marsalek (sales). The supervisory board was chaired by Wulf Matthias, re-elected chairman on 16 June 2016, with Alfons W. Henseler as deputy and Tina Kleingarn, Stefan Klestil and Vuyiswa M'Cwabeni as members; Kleingarn and M'Cwabeni joined when the 2016 shareholders' meeting enlarged the board and first attended its meeting of 8 September 2016. The 2017 report names the same five supervisory board members, all in office throughout 2017, and records Ley as finance director until 31 December 2017."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-b68bd69904cba81601135c6e","record":{"id":"display-claim-b68bd69904cba81601135c6e","kind":"analysis","text":"The register entry of 1 March 2018 records Ley's departure and the appointment of Susanne Steidl and Alexander von Knoop, whose board membership the 2019 half-year report dates from 1 January 2018. At the end of 2018 the management board consisted of Braun (chairman and technology), von Knoop (finance), Marsalek (sales) and Steidl (products); the supervisory board comprised Matthias, Henseler, Klestil, Dr. Anastassia Lauterbach, M'Cwabeni and Susana Quintana-Plaza, and the 2018 report notes that it had extended the appointments of the long-serving chief executive Braun and chief operating officer Marsalek. Henseler left on 18 June 2019, when Thomas Eichelmann joined and Klestil became deputy chairman; three supervisory board committees were set up in early 2019, and all four management board members, by then styled CEO, CFO, COO and CPO, signed the half-year report on 6 August 2019.","source_ids":["src-002","src-066","src-005"],"entity_ids":["wirecard","ley","steidl","von-knoop","braun","marsalek","matthias","henseler","klestil","lauterbach","mcwabeni","quintana","eichelmann"],"premise_claim_ids":["c-lead-2018-change","c-lead-2018-boards","c-lead-2019-boards"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The register entry of 1 March 2018 records Ley's departure and the appointment of Susanne Steidl and Alexander von Knoop, whose board membership the 2019 half-year report dates from 1 January 2018. At the end of 2018 the management board consisted of Braun (chairman and technology), von Knoop (finance), Marsalek (sales) and Steidl (products); the supervisory board comprised Matthias, Henseler, Klestil, Dr. Anastassia Lauterbach, M'Cwabeni and Susana Quintana-Plaza, and the 2018 report notes that it had extended the appointments of the long-serving chief executive Braun and chief operating officer Marsalek. Henseler left on 18 June 2019, when Thomas Eichelmann joined and Klestil became deputy chairman; three supervisory board committees were set up in early 2019, and all four management board members, by then styled CEO, CFO, COO and CPO, signed the half-year report on 6 August 2019."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-05b506c6298201a6a212dec5","record":{"id":"display-claim-05b506c6298201a6a212dec5","kind":"analysis","text":"On 18 June 2020 the supervisory board suspended Marsalek from the management board with immediate effect, revocably, until 30 June 2020, and brought forward to that day the appointment of Dr. James H. Freis, Jr., announced on 8 May for 1 July, to head a newly created Integrity, Legal and Compliance department. On 30 June Wirecard announced that Braun had resigned by mutual consent with immediate effect on 19 June and that the supervisory board had terminated his employment contract. The register entry of 1 July 2020 records the departure of Braun and Marsalek, Freis's appointment with sole power of representation and the end of Stephan Freiherr von Erffa's power of attorney; a registry aggregator shows Wirecard AG as the only German company linked to Freis.","source_ids":["src-040","src-048","src-002"],"entity_ids":["wirecard","marsalek","freis","braun","von-erffa"],"premise_claim_ids":["c-lead-2020-suspension","c-lead-2020-braun-exit","c-lead-2020-register"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 18 June 2020 the supervisory board suspended Marsalek from the management board with immediate effect, revocably, until 30 June 2020, and brought forward to that day the appointment of Dr. James H. Freis, Jr., announced on 8 May for 1 July, to head a newly created Integrity, Legal and Compliance department. On 30 June Wirecard announced that Braun had resigned by mutual consent with immediate effect on 19 June and that the supervisory board had terminated his employment contract. The register entry of 1 July 2020 records the departure of Braun and Marsalek, Freis's appointment with sole power of representation and the end of Stephan Freiherr von Erffa's power of attorney; a registry aggregator shows Wirecard AG as the only German company linked to Freis."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-1101f2d854d57c0168eab867","record":{"id":"display-claim-1101f2d854d57c0168eab867","kind":"analysis","text":"When insolvency proceedings were opened, the register recorded that the powers of attorney of Andrea Görres and Thorsten Holten had lapsed and that Daniel Steinhoff's had also ended. A registry aggregator lists the holders of joint power of attorney over the years, without end dates: Christian von Hammel-Bonten, Holten, Eric Pudewill, Marsalek, Salim Chujfi La Roche, Görres, von Erffa and Steinhoff.","source_ids":["src-002","src-033"],"entity_ids":["wirecard","goerres","holten","steinhoff","hammel-bonten","pudewill","marsalek","chujfi","von-erffa"],"premise_claim_ids":["c-lead-prokura-end","c-lead-other-prokura"],"qualification":"","response":"","outcome":""},"reading":"Analysis: When insolvency proceedings were opened, the register recorded that the powers of attorney of Andrea Görres and Thorsten Holten had lapsed and that Daniel Steinhoff's had also ended. A registry aggregator lists the holders of joint power of attorney over the years, without end dates: Christian von Hammel-Bonten, Holten, Eric Pudewill, Marsalek, Salim Chujfi La Roche, Görres, von Erffa and Steinhoff."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-e687aa18983c934dfd686f2c","record":{"id":"display-claim-e687aa18983c934dfd686f2c","kind":"analysis","text":"Several supervisory board members also oversaw subsidiaries. The 2011 report lists Wulf Matthias as chairman and managing director of Bank Sarasin AG in Frankfurt, also on the supervisory boards of Wirecard Bank AG, Wirecard Technologies AG and Deufol AG; Alfons W. Henseler as deputy chairman and independent consultant, also on the boards of Wirecard Bank AG, Wirecard Technologies AG and Diamos AG; and Stefan Klestil as managing director and owner of Belview Partners GmbH. For 2018 Wirecard disclosed that Matthias, Klestil and Henseler sat on Wirecard Bank AG's supervisory board, at an expense to the group of EUR 0.1 million each. The 2019 prospectus lists Matthias as chairman of the bank's supervisory board and a member of the board of administration of Deufol SE, and Klestil as a partner at Speedinvest GmbH in Vienna, managing director of Belview Partners and a member of the bank's supervisory board. Investor-database profiles add earlier supervisory board seats at Wirecard Technologies GmbH (Matthias, Henseler and Klestil), Wirecard Sales International Holding GmbH (Henseler) and Trustpay International AG (Klestil).","source_ids":["src-010","src-005","src-012","src-097","src-098","src-096"],"entity_ids":["wirecard","matthias","bank-sarasin","wd-bank","wd-tech","deufol","henseler","diamos","klestil","belview","speedinvest","eichelmann","mcwabeni","lauterbach","quintana","wd-sih"],"premise_claim_ids":["c-lead-2011-sb","c-lead-2018-bank-sb","c-lead-2019-sb-mandates","c-lead-sb-later"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Several supervisory board members also oversaw subsidiaries. The 2011 report lists Wulf Matthias as chairman and managing director of Bank Sarasin AG in Frankfurt, also on the supervisory boards of Wirecard Bank AG, Wirecard Technologies AG and Deufol AG; Alfons W. Henseler as deputy chairman and independent consultant, also on the boards of Wirecard Bank AG, Wirecard Technologies AG and Diamos AG; and Stefan Klestil as managing director and owner of Belview Partners GmbH. For 2018 Wirecard disclosed that Matthias, Klestil and Henseler sat on Wirecard Bank AG's supervisory board, at an expense to the group of EUR 0.1 million each. The 2019 prospectus lists Matthias as chairman of the bank's supervisory board and a member of the board of administration of Deufol SE, and Klestil as a partner at Speedinvest GmbH in Vienna, managing director of Belview Partners and a member of the bank's supervisory board. Investor-database profiles add earlier supervisory board seats at Wirecard Technologies GmbH (Matthias, Henseler and Klestil), Wirecard Sales International Holding GmbH (Henseler) and Trustpay International AG (Klestil)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-207c741699159a5fa661954d","record":{"id":"display-claim-207c741699159a5fa661954d","kind":"analysis","text":"Tina Kleingarn told the Bundestag's committee of inquiry on 19 November 2020, as the Bundestag reported, that she had sat on the supervisory board in 2016–2017 and left it in protest against an opaque corporate culture, explaining her departure in a letter to the remaining members. In her account Braun brought new management board members in without effective involvement of the supervisory board, and the management board resisted effective oversight and withheld information the supervisory board needed. An investor database records that Susana Quintana-Plaza's term ended on 6 April 2020 and lists Dr. Anastassia Lauterbach as a former member; the 2019 prospectus gives Lauterbach's other positions as chief executive of Lauterbach Consulting and Venturing GmbH, non-executive director of easyJet plc and of Dun & Bradstreet Corp. and chair of censhare AG.","source_ids":["src-079","src-099","src-012"],"entity_ids":["kleingarn","wirecard","braun","bundestag","quintana","lauterbach","easyjet","dun-bradstreet","censhare"],"premise_claim_ids":["c-lead-kleingarn","c-lead-quintana","c-lead-lauterbach"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Tina Kleingarn told the Bundestag's committee of inquiry on 19 November 2020, as the Bundestag reported, that she had sat on the supervisory board in 2016–2017 and left it in protest against an opaque corporate culture, explaining her departure in a letter to the remaining members. In her account Braun brought new management board members in without effective involvement of the supervisory board, and the management board resisted effective oversight and withheld information the supervisory board needed. An investor database records that Susana Quintana-Plaza's term ended on 6 April 2020 and lists Dr. Anastassia Lauterbach as a former member; the 2019 prospectus gives Lauterbach's other positions as chief executive of Lauterbach Consulting and Venturing GmbH, non-executive director of easyJet plc and of Dun & Bradstreet Corp. and chair of censhare AG."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-bc2ffaf4a9d7fab332752217","record":{"id":"display-claim-bc2ffaf4a9d7fab332752217","kind":"analysis","text":"Stefan Klestil, deputy chairman from June 2019, was described by a technology news site in July 2020 as a partner of the Vienna venture capital firm Speedinvest, a co-founder of Fintech Austria, a member of the Austrian government's fintech advisory council and the first investor in N26, brought onto the board by Braun many years earlier. The 2019 half-year report prints, without the member's name, mandates at Wirecard Bank AG, Billie, Curve, Iyzico, N26 Bank, N26, Payworks, wefox and FinCompare for the member who became deputy chairman on 18 June 2019, which matches the published profile. Asked for an interview, Klestil replied through a representative that only the chairman spoke for the supervisory board and that he, like the whole board, was doing everything to help clarify the open questions about Wirecard's accounts. In 2024 the Munich I regional court dismissed the insolvency administrator's damages claim against him: it found that he had neglected his supervisory duties but doubted that proper supervision would have changed the management board's conduct; no criminal offence is alleged against him.","source_ids":["src-082","src-066","src-062"],"entity_ids":["klestil","speedinvest","braun","wirecard","wd-bank","lg-muenchen","jaffe"],"premise_claim_ids":["c-lead-klestil"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Stefan Klestil, deputy chairman from June 2019, was described by a technology news site in July 2020 as a partner of the Vienna venture capital firm Speedinvest, a co-founder of Fintech Austria, a member of the Austrian government's fintech advisory council and the first investor in N26, brought onto the board by Braun many years earlier. The 2019 half-year report prints, without the member's name, mandates at Wirecard Bank AG, Billie, Curve, Iyzico, N26 Bank, N26, Payworks, wefox and FinCompare for the member who became deputy chairman on 18 June 2019, which matches the published profile. Asked for an interview, Klestil replied through a representative that only the chairman spoke for the supervisory board and that he, like the whole board, was doing everything to help clarify the open questions about Wirecard's accounts. In 2024 the Munich I regional court dismissed the insolvency administrator's damages claim against him: it found that he had neglected his supervisory duties but doubted that proper supervision would have changed the management board's conduct; no criminal offence is alleged against him."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-c9dd3e928ba6fa06974d3582","record":{"id":"display-claim-c9dd3e928ba6fa06974d3582","kind":"analysis","text":"In June 2005, when the shelf company Blitz 05-059 GmbH became Wire Card Beteiligungs GmbH, its first managing director Nicole Liebera left and Braun became sole managing director. As Wirecard Acquiring & Issuing GmbH the company changed management on 10 April 2013, when Braun left and Oliver Bellenhaus, Görres, Ley and Steidl were appointed; Ley left on 26 January 2018 and von Knoop was appointed. Bellenhaus and von Knoop left on 20 August 2020, when von Erffa's power of attorney also ended, and on 2 September 2020 Görres and Steidl left and the lawyer Dr. Christoph Schotte became sole managing director, while the powers of attorney of Holten and Steinhoff ended.","source_ids":["src-013"],"entity_ids":["wd-acq-iss","liebera","braun","bellenhaus","goerres","ley","steidl","von-knoop","von-erffa","schotte","holten","steinhoff"],"premise_claim_ids":["c-lead-acqiss-2005","c-lead-acqiss-officers"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In June 2005, when the shelf company Blitz 05-059 GmbH became Wire Card Beteiligungs GmbH, its first managing director Nicole Liebera left and Braun became sole managing director. As Wirecard Acquiring & Issuing GmbH the company changed management on 10 April 2013, when Braun left and Oliver Bellenhaus, Görres, Ley and Steidl were appointed; Ley left on 26 January 2018 and von Knoop was appointed. Bellenhaus and von Knoop left on 20 August 2020, when von Erffa's power of attorney also ended, and on 2 September 2020 Görres and Steidl left and the lawyer Dr. Christoph Schotte became sole managing director, while the powers of attorney of Holten and Steinhoff ended."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-a25d9e1b360dcbc178d8c947","record":{"id":"display-claim-a25d9e1b360dcbc178d8c947","kind":"analysis","text":"Marsalek ran the international holding company: the first register entry for Trustpay International GmbH (25 August 2010), later Wirecard Sales International Holding GmbH, names him as sole managing director, with von Erffa, Görres and Holten as joint authorised signatories. Holten, in place of his power of attorney, and Brigitte Häuser-Axtner became managing directors on 25 August 2016, and on 14 July 2020 Häuser-Axtner and Marsalek left and von Erffa's power of attorney ended; the 2019 prospectus lists Marsalek, Holten and Häuser-Axtner as managing directors. Wirecard Sales Europe GmbH, later Wirecard Global Sales GmbH, started with Holten, Häuser-Axtner and Marsalek as managing directors and joint powers of attorney for von Erffa and Görres; Häuser-Axtner and Marsalek left on 30 June 2020, when von Erffa's power of attorney also ended. The prospectus names Marsalek, Alan White (also company secretary), Helen Margaret Meehan and Markus-Konrad Fuchs as directors of the Dublin holding company Wirecard Payment Solutions Holdings Limited.","source_ids":["src-014","src-012","src-018"],"entity_ids":["wd-sih","marsalek","von-erffa","goerres","holten","haeuser-axtner","wd-global-sales","wd-psh","white","meehan","fuchs"],"premise_claim_ids":["c-lead-wsih-officers","c-lead-global-sales-officers","c-lead-wpsh-directors"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Marsalek ran the international holding company: the first register entry for Trustpay International GmbH (25 August 2010), later Wirecard Sales International Holding GmbH, names him as sole managing director, with von Erffa, Görres and Holten as joint authorised signatories. Holten, in place of his power of attorney, and Brigitte Häuser-Axtner became managing directors on 25 August 2016, and on 14 July 2020 Häuser-Axtner and Marsalek left and von Erffa's power of attorney ended; the 2019 prospectus lists Marsalek, Holten and Häuser-Axtner as managing directors. Wirecard Sales Europe GmbH, later Wirecard Global Sales GmbH, started with Holten, Häuser-Axtner and Marsalek as managing directors and joint powers of attorney for von Erffa and Görres; Häuser-Axtner and Marsalek left on 30 June 2020, when von Erffa's power of attorney also ended. The prospectus names Marsalek, Alan White (also company secretary), Helen Margaret Meehan and Markus-Konrad Fuchs as directors of the Dublin holding company Wirecard Payment Solutions Holdings Limited."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-e57b4e6de67cf9c3c228a9d5","record":{"id":"display-claim-e57b4e6de67cf9c3c228a9d5","kind":"analysis","text":"Wirecard Technologies GmbH's first register entry (14 August 2012) names Ley, Marsalek and Braun as managing directors and Michael Brinkmann, von Erffa, Görres and Holten as joint authorised signatories. On 5 December 2012 Ley and Marsalek left and Carlos Häuser, Jörg Möller and von Erffa became managing directors; Steidl followed on 7 November 2017, Häuser left on 27 January 2018, Braun and von Erffa on 30 June 2020 and Möller on 3 October 2020; the 2019 prospectus lists Braun, Möller, von Erffa and Steidl as managing directors. Click2Pay GmbH was dissolved by an entry of 30 October 2019 naming Daniel Heuser and Marsalek as liquidators and Görres and Holten as joint authorised signatories; Marsalek ceased to be a liquidator in July 2020, and TEAM TREUHAND GmbH replaced Heuser on 2 March 2021. Wirecard Communication Services GmbH's first Leipzig entry (30 March 2009) names Heiner Bauer, Markus Plänitz and Braun as managing directors; Brinkmann took Braun's place on 1 March 2010, Amra Blume was appointed when Plänitz left in May 2018 and remained after Brinkmann left in August 2020, and a register database lists Bettina Funk as a managing director until 6 July 2020.","source_ids":["src-015","src-012","src-016","src-006","src-104","src-049","src-019","src-105","src-036"],"entity_ids":["wd-tech","ley","marsalek","braun","brinkmann","von-erffa","goerres","holten","c-haeuser","moeller","steidl","click2pay","heuser","team-treuhand","wd-comm-services","bauer-heiner","plaenitz","blume","funk"],"premise_claim_ids":["c-lead-wdtech-officers","c-lead-click2pay-officers","c-lead-commservices-officers"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard Technologies GmbH's first register entry (14 August 2012) names Ley, Marsalek and Braun as managing directors and Michael Brinkmann, von Erffa, Görres and Holten as joint authorised signatories. On 5 December 2012 Ley and Marsalek left and Carlos Häuser, Jörg Möller and von Erffa became managing directors; Steidl followed on 7 November 2017, Häuser left on 27 January 2018, Braun and von Erffa on 30 June 2020 and Möller on 3 October 2020; the 2019 prospectus lists Braun, Möller, von Erffa and Steidl as managing directors. Click2Pay GmbH was dissolved by an entry of 30 October 2019 naming Daniel Heuser and Marsalek as liquidators and Görres and Holten as joint authorised signatories; Marsalek ceased to be a liquidator in July 2020, and TEAM TREUHAND GmbH replaced Heuser on 2 March 2021. Wirecard Communication Services GmbH's first Leipzig entry (30 March 2009) names Heiner Bauer, Markus Plänitz and Braun as managing directors; Brinkmann took Braun's place on 1 March 2010, Amra Blume was appointed when Plänitz left in May 2018 and remained after Brinkmann left in August 2020, and a register database lists Bettina Funk as a managing director until 6 July 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-2df80de16b00ca39eaff7cb9","record":{"id":"display-claim-2df80de16b00ca39eaff7cb9","kind":"analysis","text":"The three technology companies founded in 2017–2018 had small teams with Steidl as a managing director of each: Wirecard Acceptance Technologies started with Stefan Buck and Sreelekha Sankar, Wirecard Issuing Technologies with Sebastian Krahe and Sankar, and Wirecard Service Technologies with Yiannakis Ioannou. Buck and Arne Matthias left on 25 October 2019 and Ioannou on 12 September 2019, Thomas Neeff also left, and Tom Schmidt was appointed on 16 May 2019; von Erffa, Görres and Holten held joint powers of attorney, and Steinhoff received one on 25 October 2019.","source_ids":["src-041","src-042","src-043"],"entity_ids":["wd-acceptance-tech","wd-issuing-tech","wd-service-tech","buck","sankar","steidl","krahe","a-matthias","ioannou","neeff","t-schmidt","von-erffa","goerres","holten","steinhoff"],"premise_claim_ids":["c-lead-newsubs-officers"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The three technology companies founded in 2017–2018 had small teams with Steidl as a managing director of each: Wirecard Acceptance Technologies started with Stefan Buck and Sreelekha Sankar, Wirecard Issuing Technologies with Sebastian Krahe and Sankar, and Wirecard Service Technologies with Yiannakis Ioannou. Buck and Arne Matthias left on 25 October 2019 and Ioannou on 12 September 2019, Thomas Neeff also left, and Tom Schmidt was appointed on 16 May 2019; von Erffa, Görres and Holten held joint powers of attorney, and Steinhoff received one on 25 October 2019."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-4d812fc08678506d5e271cf4","record":{"id":"display-claim-4d812fc08678506d5e271cf4","kind":"analysis","text":"In Dubai, the 2019 prospectus names Marsalek and Bellenhaus as directors of CardSystems Middle East FZ-LLC, with Bellenhaus as the general manager running its business day to day, and Bellenhaus and Steidl as directors of Wirecard Processing FZ LLC, with Nabila Nouinou as general manager. The UK register lists Bellenhaus (February 2012 to June 2020), Ley (February 2012 to December 2017) and von Knoop (January 2018 to July 2020) as former directors of Wirecard Card Solutions Limited (a registry aggregator gives slightly different dates for the 2018 and 2020 changes), and Thomas Michael Richard Jennings and, since August 2020, Andrea Farace as the current directors of the company, which is in liquidation. Register publications summarised by an aggregator show von Knoop at Wirecard Bank AG as an authorised signatory from 2010 and a management board member from 2014 until July 2020, and Ley leaving the bank's board in January 2018, when Daniel Heuser was appointed; an aggregator also shows von Knoop and Jennings leaving the board of Wirecard Luxembourg S.A. in August 2020.","source_ids":["src-012","src-092","src-101","src-100","src-065","src-080"],"entity_ids":["cardsystems-me","marsalek","bellenhaus","wd-processing","steidl","nouinou","wd-card-solutions","ley","von-knoop","jennings","farace","wd-bank","heuser","wd-luxembourg"],"premise_claim_ids":["c-lead-cardsystems-directors","c-lead-wcs-directors","c-lead-bank-officers","c-lead-lux-board"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In Dubai, the 2019 prospectus names Marsalek and Bellenhaus as directors of CardSystems Middle East FZ-LLC, with Bellenhaus as the general manager running its business day to day, and Bellenhaus and Steidl as directors of Wirecard Processing FZ LLC, with Nabila Nouinou as general manager. The UK register lists Bellenhaus (February 2012 to June 2020), Ley (February 2012 to December 2017) and von Knoop (January 2018 to July 2020) as former directors of Wirecard Card Solutions Limited (a registry aggregator gives slightly different dates for the 2018 and 2020 changes), and Thomas Michael Richard Jennings and, since August 2020, Andrea Farace as the current directors of the company, which is in liquidation. Register publications summarised by an aggregator show von Knoop at Wirecard Bank AG as an authorised signatory from 2010 and a management board member from 2014 until July 2020, and Ley leaving the bank's board in January 2018, when Daniel Heuser was appointed; an aggregator also shows von Knoop and Jennings leaving the board of Wirecard Luxembourg S.A. in August 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-58adf20257a566fc4c5b7cc1","record":{"id":"display-claim-58adf20257a566fc4c5b7cc1","kind":"analysis","text":"Wirecard AG's shares were widely held. Its 2010 annual report records that MB Beteiligungsgesellschaft mbH, whose managing director was the management board chairman Dr. Markus Braun, held 7.60%. At the end of 2011 the holders of more than 3% of the votes were MB Beteiligungsgesellschaft (7.60%), Jupiter Asset Management (6.26%), Alken Fund Sicav (5.00%), Wasatch Holdings (3.10%), Columbia Wanger AM (3.08%) and Ameriprise Financial (3.04%), with a free float of 92.4%. MB Beteiligungsgesellschaft held 7.0% at the end of 2016 and 2017; other holders above 3% then included Jupiter, Alken Luxembourg, Citigroup and Artisan Partners and, at the end of 2017, BlackRock (5.12%).","source_ids":["src-023","src-010","src-032","src-020"],"entity_ids":["mb-beteiligung","wirecard","braun","jupiter-am","alken","citigroup","artisan","blackrock"],"premise_claim_ids":["c-own-2010","c-own-2011","c-own-2016-2017"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard AG's shares were widely held. Its 2010 annual report records that MB Beteiligungsgesellschaft mbH, whose managing director was the management board chairman Dr. Markus Braun, held 7.60%. At the end of 2011 the holders of more than 3% of the votes were MB Beteiligungsgesellschaft (7.60%), Jupiter Asset Management (6.26%), Alken Fund Sicav (5.00%), Wasatch Holdings (3.10%), Columbia Wanger AM (3.08%) and Ameriprise Financial (3.04%), with a free float of 92.4%. MB Beteiligungsgesellschaft held 7.0% at the end of 2016 and 2017; other holders above 3% then included Jupiter, Alken Luxembourg, Citigroup and Artisan Partners and, at the end of 2017, BlackRock (5.12%)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-44ad6b13726f0632f9cb21eb","record":{"id":"display-claim-44ad6b13726f0632f9cb21eb","kind":"analysis","text":"At the end of 2018 MB Beteiligungsgesellschaft held 7.05%, and the free float of 92.95% included BlackRock (6.7%), Jupiter (5.1%), Citigroup (4.93%) and Artisan Partners (3.0%); the no-par bearer shares (ISIN DE0007472060, WKN 747206) had been listed since 25 October 2000. Voting-rights notifications in the 2019 half-year report show MB Beteiligungsgesellschaft at 7.05%, and the September 2019 prospectus gives its holding at 31 August 2019, attributed to Braun, as 8.04%, ahead of BlackRock (5.82%), Artisan (5.24%), Jupiter Fund Management (5.00%), Citigroup (4.93%) and Goldman Sachs (3.53%). The shareholders' meeting of 18 June 2019 resolved a dividend for 2018 of EUR 0.20 per share, EUR 24.71 million in total, from a profit of EUR 167.83 million; for 2016 the supervisory board had proposed EUR 0.16 per share.","source_ids":["src-005","src-066","src-012"],"entity_ids":["wirecard","mb-beteiligung","blackrock","jupiter-am","citigroup","artisan","braun","jupiter-fm","goldman"],"premise_claim_ids":["c-own-2018","c-own-2019","c-fin-dividend-2018"],"qualification":"","response":"","outcome":""},"reading":"Analysis: At the end of 2018 MB Beteiligungsgesellschaft held 7.05%, and the free float of 92.95% included BlackRock (6.7%), Jupiter (5.1%), Citigroup (4.93%) and Artisan Partners (3.0%); the no-par bearer shares (ISIN DE0007472060, WKN 747206) had been listed since 25 October 2000. Voting-rights notifications in the 2019 half-year report show MB Beteiligungsgesellschaft at 7.05%, and the September 2019 prospectus gives its holding at 31 August 2019, attributed to Braun, as 8.04%, ahead of BlackRock (5.82%), Artisan (5.24%), Jupiter Fund Management (5.00%), Citigroup (4.93%) and Goldman Sachs (3.53%). The shareholders' meeting of 18 June 2019 resolved a dividend for 2018 of EUR 0.20 per share, EUR 24.71 million in total, from a profit of EUR 167.83 million; for 2016 the supervisory board had proposed EUR 0.16 per share."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-dcaa14248aea7382fac2c756","record":{"id":"display-claim-dcaa14248aea7382fac2c756","kind":"analysis","text":"For 2010 Wirecard reported revenue up 19% to EUR 271.6 million, EBITDA of EUR 73.3 million and more than 12,000 merchant customers, and through the Singapore subsidiary bought in December 2009 announced partnerships with Alipay and China UnionPay. Its consolidated balance sheet at the end of 2015, as reproduced by the special investigators, showed cash of EUR 1,062.968 million, receivables from the acquiring business of EUR 334.055 million and total assets of EUR 2,935.501 million. For 2016 it reported revenue of EUR 1,028.4 million (2015: EUR 771.3 million), EBITDA of EUR 307.4 million, net profit of EUR 266.7 million, equity of EUR 1,475.0 million and total assets of EUR 3,482.1 million.","source_ids":["src-023","src-027","src-032"],"entity_ids":["wirecard","unionpay","bundestag"],"premise_claim_ids":["c-fin-2010-figures","c-fin-2015-balance","c-fin-2016-figures"],"qualification":"","response":"","outcome":""},"reading":"Analysis: For 2010 Wirecard reported revenue up 19% to EUR 271.6 million, EBITDA of EUR 73.3 million and more than 12,000 merchant customers, and through the Singapore subsidiary bought in December 2009 announced partnerships with Alipay and China UnionPay. Its consolidated balance sheet at the end of 2015, as reproduced by the special investigators, showed cash of EUR 1,062.968 million, receivables from the acquiring business of EUR 334.055 million and total assets of EUR 2,935.501 million. For 2016 it reported revenue of EUR 1,028.4 million (2015: EUR 771.3 million), EBITDA of EUR 307.4 million, net profit of EUR 266.7 million, equity of EUR 1,475.0 million and total assets of EUR 3,482.1 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-2e7e0c2212cc08d1eecda03e","record":{"id":"display-claim-2e7e0c2212cc08d1eecda03e","kind":"analysis","text":"Wirecard reported cash and cash equivalents of EUR 2,719.8 million at the end of 2018 (2017: EUR 1,901.3 million), including short-term customer deposits of Wirecard Bank and Wirecard Card Solutions, and a company-calculated net cash position of EUR 1,646.6 million after deducting EUR 1,263.0 million of banking customer deposits. Its half-year report for 2019, approved on 6 August 2019 and neither audited nor reviewed, showed revenue of EUR 1,209.8 million, EBITDA of EUR 342.1 million and total assets of EUR 6,697.6 million, with Asia-Pacific revenue exceeding Europe's for the first time; its cash of EUR 3,047.7 million included EUR 1,559.1 million of banking customer deposits and EUR 346.9 million of Wirecard Bank's acquiring funds. The same report records financing agreements, including with sales partners, of EUR 132.4 million and banking receivables of EUR 107.0 million, and shows legal and reporting costs rising from EUR 6.3 million to EUR 20.9 million and consulting costs from EUR 13.4 million to EUR 20.8 million, which the company attributed to the investigations in Asia.","source_ids":["src-005","src-066"],"entity_ids":["wirecard","wd-bank","wd-card-solutions"],"premise_claim_ids":["c-fin-2018-cash","c-fin-2019-halfyear","c-fin-2019-cash-composition","c-fin-2019-other"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard reported cash and cash equivalents of EUR 2,719.8 million at the end of 2018 (2017: EUR 1,901.3 million), including short-term customer deposits of Wirecard Bank and Wirecard Card Solutions, and a company-calculated net cash position of EUR 1,646.6 million after deducting EUR 1,263.0 million of banking customer deposits. Its half-year report for 2019, approved on 6 August 2019 and neither audited nor reviewed, showed revenue of EUR 1,209.8 million, EBITDA of EUR 342.1 million and total assets of EUR 6,697.6 million, with Asia-Pacific revenue exceeding Europe's for the first time; its cash of EUR 3,047.7 million included EUR 1,559.1 million of banking customer deposits and EUR 346.9 million of Wirecard Bank's acquiring funds. The same report records financing agreements, including with sales partners, of EUR 132.4 million and banking receivables of EUR 107.0 million, and shows legal and reporting costs rising from EUR 6.3 million to EUR 20.9 million and consulting costs from EUR 13.4 million to EUR 20.8 million, which the company attributed to the investigations in Asia."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-4cdc5949065168eb0b140e8d","record":{"id":"display-claim-4cdc5949065168eb0b140e8d","kind":"analysis","text":"Bank debt rose with the acquisitions. The 2011 report says interest-bearing bank liabilities rose by EUR 64.0 million to EUR 86.0 million after they were moved into a long-term framework loan for completed and potential acquisitions. The 2017 and 2018 reports record a firm credit line with an unnamed bank consortium of EUR 1,000 million and then EUR 1,905.6 million, which each member could cancel on a change of control. According to the 2019 prospectus Wirecard AG was the borrower under a EUR 1,750 million syndicated revolving credit facility of 15 June 2018, guaranteed by four subsidiaries, with ABN Amro, Commerzbank, ING (a branch of ING-DiBa AG) and Landesbank Baden-Württemberg as mandated lead arrangers and Commerzbank as agent. Commercial banks had lent the group EUR 1,466.1 million at the end of 2018, and interest-bearing liabilities reached EUR 1,717.6 million at 30 June 2019, which the company attributed to acquisitions, digital lending and licences in Asia and the United States.","source_ids":["src-010","src-020","src-005","src-012","src-066"],"entity_ids":["wirecard","abn-amro","commerzbank","ing-diba","lbbw"],"premise_claim_ids":["c-fin-2011-loans","c-fin-syndicated-2017-2018","c-fin-rcf-2018","c-fin-2018-bank-loans","c-fin-2019-liabilities"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Bank debt rose with the acquisitions. The 2011 report says interest-bearing bank liabilities rose by EUR 64.0 million to EUR 86.0 million after they were moved into a long-term framework loan for completed and potential acquisitions. The 2017 and 2018 reports record a firm credit line with an unnamed bank consortium of EUR 1,000 million and then EUR 1,905.6 million, which each member could cancel on a change of control. According to the 2019 prospectus Wirecard AG was the borrower under a EUR 1,750 million syndicated revolving credit facility of 15 June 2018, guaranteed by four subsidiaries, with ABN Amro, Commerzbank, ING (a branch of ING-DiBa AG) and Landesbank Baden-Württemberg as mandated lead arrangers and Commerzbank as agent. Commercial banks had lent the group EUR 1,466.1 million at the end of 2018, and interest-bearing liabilities reached EUR 1,717.6 million at 30 June 2019, which the company attributed to acquisitions, digital lending and licences in Asia and the United States."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-1687c830549f58c0a9ab9e96","record":{"id":"display-claim-1687c830549f58c0a9ab9e96","kind":"analysis","text":"In September 2019 Wirecard AG issued EUR 500 million of 0.50% notes due 2024 (ISIN DE000A2YNQ58), jointly guaranteed by Wirecard Technologies GmbH, Wirecard Sales International Holding GmbH, Wirecard Payment Solutions Holdings Limited, CardSystems Middle East FZ-LLC and Wirecard Processing FZ-LLC and listed on the Luxembourg Stock Exchange's Euro MTF. The bond initially carried a Moody's Baa3 investment-grade rating, withdrawn on 22 June 2020. The prospectus names Crédit Agricole CIB, ABN AMRO and Credit Suisse as joint global coordinators and Deutsche Bank, ING, Citigroup and Lloyds Bank Corporate Markets Wertpapierhandelsbank as joint bookrunners.","source_ids":["src-012","src-025"],"entity_ids":["wirecard","wd-tech","wd-sih","wd-psh","cardsystems-me","wd-processing","cacib","abn-amro","credit-suisse","deutsche-bank","ing","citigroup","lloyds-cm"],"premise_claim_ids":["c-fin-bond-2019","c-fin-bond-banks"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In September 2019 Wirecard AG issued EUR 500 million of 0.50% notes due 2024 (ISIN DE000A2YNQ58), jointly guaranteed by Wirecard Technologies GmbH, Wirecard Sales International Holding GmbH, Wirecard Payment Solutions Holdings Limited, CardSystems Middle East FZ-LLC and Wirecard Processing FZ-LLC and listed on the Luxembourg Stock Exchange's Euro MTF. The bond initially carried a Moody's Baa3 investment-grade rating, withdrawn on 22 June 2020. The prospectus names Crédit Agricole CIB, ABN AMRO and Credit Suisse as joint global coordinators and Deutsche Bank, ING, Citigroup and Lloyds Bank Corporate Markets Wertpapierhandelsbank as joint bookrunners."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-bb0cfbf873e2293dba13c143","record":{"id":"display-claim-bb0cfbf873e2293dba13c143","kind":"analysis","text":"After the 2018 reporting date Wirecard signed a binding memorandum of understanding with SoftBank Group Corp. under which a SoftBank group company would invest about EUR 900 million through a convertible bond, together with a partnership in digital payments aimed at Japan and South Korea; a binding term sheet of 24 April 2019 provided for five-year bonds convertible into up to 6,923,076 shares at EUR 130 with 1.90% interest, approved by the shareholders on 18 June 2019. The EUR 900 million convertible bond due 2 October 2024 was issued by WD Invest S.à r.l., formerly Luxembourg Investment Company 326 S.à r.l., and guaranteed by Wirecard AG; a credit-derivatives determinations committee listed it, with the EUR 500 million notes, as a deliverable obligation on 18 July 2020. Luxembourg register publications summarised by an aggregator show that the shelf company was registered on 23 August 2019 with Intertrust (Luxembourg) as shareholder and RCS Management (Luxembourg) as manager, both of which left in September 2019, when Thorsten Holten and Stephan von Erffa became managers, followed by Riccardo Incani and Luigi Maula; von Erffa left on 1 July 2020 and Incani and Maula on 3 July 2020.","source_ids":["src-005","src-012","src-022","src-021"],"entity_ids":["wirecard","softbank","wd-invest","intertrust-lux","rcs-mgmt","holten","von-erffa","incani","maula"],"premise_claim_ids":["c-fin-softbank","c-fin-wd-invest","c-fin-wd-invest-managers"],"qualification":"","response":"","outcome":""},"reading":"Analysis: After the 2018 reporting date Wirecard signed a binding memorandum of understanding with SoftBank Group Corp. under which a SoftBank group company would invest about EUR 900 million through a convertible bond, together with a partnership in digital payments aimed at Japan and South Korea; a binding term sheet of 24 April 2019 provided for five-year bonds convertible into up to 6,923,076 shares at EUR 130 with 1.90% interest, approved by the shareholders on 18 June 2019. The EUR 900 million convertible bond due 2 October 2024 was issued by WD Invest S.à r.l., formerly Luxembourg Investment Company 326 S.à r.l., and guaranteed by Wirecard AG; a credit-derivatives determinations committee listed it, with the EUR 500 million notes, as a deliverable obligation on 18 July 2020. Luxembourg register publications summarised by an aggregator show that the shelf company was registered on 23 August 2019 with Intertrust (Luxembourg) as shareholder and RCS Management (Luxembourg) as manager, both of which left in September 2019, when Thorsten Holten and Stephan von Erffa became managers, followed by Riccardo Incani and Luigi Maula; von Erffa left on 1 July 2020 and Incani and Maula on 3 July 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-d3e5aa8665060217e6830557","record":{"id":"display-claim-d3e5aa8665060217e6830557","kind":"analysis","text":"When the trust accounts could not be confirmed, the loans became callable. In an ad hoc announcement of 18 June 2020 Wirecard warned that loans of about EUR 2 billion could be terminated if audited 2019 accounts were not presented by 19 June; on 25 June it said that without agreement with lenders loans of EUR 800 million could be terminated on 30 June and EUR 500 million on 1 July. A European Parliament briefing notes that the consortium reportedly included Commerzbank, LBBW and ING. A news agency reported on 6 July 2020 that the creditors' committee represented the lending banks through ING and LBBW and bondholders through a law firm appointed by Cyrus Capital, and that the company owed creditors about EUR 4 billion. According to the investigation summarised by the Federal Criminal Police Office, banks in Germany and Japan and other investors misled by false financial statements lent Wirecard about EUR 3.2 billion in loans and similar funds, which were probably largely lost in the insolvency; the figure is the prosecution's account in a wanted notice, not a court finding.","source_ids":["src-024","src-025","src-094","src-003"],"entity_ids":["wirecard","commerzbank","lbbw","ing-diba","europarl","ing","bka"],"premise_claim_ids":["c-fin-loans-callable","c-fin-creditors-committee","c-fin-loans-lost"],"qualification":"","response":"","outcome":""},"reading":"Analysis: When the trust accounts could not be confirmed, the loans became callable. In an ad hoc announcement of 18 June 2020 Wirecard warned that loans of about EUR 2 billion could be terminated if audited 2019 accounts were not presented by 19 June; on 25 June it said that without agreement with lenders loans of EUR 800 million could be terminated on 30 June and EUR 500 million on 1 July. A European Parliament briefing notes that the consortium reportedly included Commerzbank, LBBW and ING. A news agency reported on 6 July 2020 that the creditors' committee represented the lending banks through ING and LBBW and bondholders through a law firm appointed by Cyrus Capital, and that the company owed creditors about EUR 4 billion. According to the investigation summarised by the Federal Criminal Police Office, banks in Germany and Japan and other investors misled by false financial statements lent Wirecard about EUR 3.2 billion in loans and similar funds, which were probably largely lost in the insolvency; the figure is the prosecution's account in a wanted notice, not a court finding."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-209e74b1fc4298d7d5186cec","record":{"id":"display-claim-209e74b1fc4298d7d5186cec","kind":"analysis","text":"Wirecard's expansion into Asia began on 16 December 2009 with an agreement to buy all of E-Credit Plus Pte. Ltd. of Singapore and its subsidiaries; the shares were transferred on 28 December 2009, Wirecard obtained control on 1 January 2010, and the 2010 report puts the purchase price at EUR 13.283 million. From 13 January 2011 it took over Procard Services FZ LLC of Dubai, a provider of payment processing, card acceptance and card issuing services, for EUR 670,000 plus EUR 11.561 million of assumed debt, and in December 2011 it bought Systems@Work Pte. Ltd. of Singapore, known for its TeleMoney brand, with subsidiaries in Kuala Lumpur and Singapore, for EUR 34.726 million in cash plus two earn-out components of up to SGD 22.5 million.","source_ids":["src-023","src-010"],"entity_ids":["wirecard","wd-asia-pte","procard","wd-singapore","systemsatwork-my","safe2pay"],"premise_claim_ids":["c-acq-ecredit","c-acq-2011"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard's expansion into Asia began on 16 December 2009 with an agreement to buy all of E-Credit Plus Pte. Ltd. of Singapore and its subsidiaries; the shares were transferred on 28 December 2009, Wirecard obtained control on 1 January 2010, and the 2010 report puts the purchase price at EUR 13.283 million. From 13 January 2011 it took over Procard Services FZ LLC of Dubai, a provider of payment processing, card acceptance and card issuing services, for EUR 670,000 plus EUR 11.561 million of assumed debt, and in December 2011 it bought Systems@Work Pte. Ltd. of Singapore, known for its TeleMoney brand, with subsidiaries in Kuala Lumpur and Singapore, for EUR 34.726 million in cash plus two earn-out components of up to SGD 22.5 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-ee0001cc58555e1d111bd613","record":{"id":"display-claim-ee0001cc58555e1d111bd613","kind":"analysis","text":"In the same month the newly formed British subsidiary Wirecard Card Solutions Ltd. took over Newcastle Building Society's prepaid card issuing business, about 1.5 million cards in six European countries, in two phases: first as outsourcing provider for the main functions, then taking control once the UK Financial Services Authority authorised it as an e-money institution. The chief executive's letter for 2011 notes that Wirecard Bank was the first non-Chinese bank to offer China UnionPay's online acquiring licence and that the platform processed EUR 15.5 billion that year.","source_ids":["src-010"],"entity_ids":["wd-card-solutions","newcastle-bs","wirecard","wd-bank","unionpay"],"premise_claim_ids":["c-acq-newcastle"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In the same month the newly formed British subsidiary Wirecard Card Solutions Ltd. took over Newcastle Building Society's prepaid card issuing business, about 1.5 million cards in six European countries, in two phases: first as outsourcing provider for the main functions, then taking control once the UK Financial Services Authority authorised it as an e-money institution. The chief executive's letter for 2011 notes that Wirecard Bank was the first non-Chinese bank to offer China UnionPay's online acquiring licence and that the platform processed EUR 15.5 billion that year."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-232ef2aeca40ba44c7a9c69c","record":{"id":"display-claim-232ef2aeca40ba44c7a9c69c","kind":"analysis","text":"The purchase of Citi Prepaid Card Services, announced on 29 June 2016 as a combined share and asset deal, closed on 9 March 2017 with control over Ecount Inc. and the individual assets; the transaction vehicle Kestrel Mergers Acquisitions Corp. of Conshohocken merged into Wirecard North America Inc. On 6 March 2017 Wirecard bought MyGate Communications Pty Ltd. of Cape Town, a payment service provider with about 20 staff, for EUR 13.1 million.","source_ids":["src-020"],"entity_ids":["wirecard","citigroup","ecount","kestrel","wd-north-america","mygate"],"premise_claim_ids":["c-acq-2017"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The purchase of Citi Prepaid Card Services, announced on 29 June 2016 as a combined share and asset deal, closed on 9 March 2017 with control over Ecount Inc. and the individual assets; the transaction vehicle Kestrel Mergers Acquisitions Corp. of Conshohocken merged into Wirecard North America Inc. On 6 March 2017 Wirecard bought MyGate Communications Pty Ltd. of Cape Town, a payment service provider with about 20 staff, for EUR 13.1 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-f334ca6d689f20ee7b63c046","record":{"id":"display-claim-f334ca6d689f20ee7b63c046","kind":"analysis","text":"On 13 March 2017 Wirecard agreed with the Citigroup subsidiaries Citibank, N.A. and Citibank Overseas Investment Corporation to acquire the customer portfolios of Citi's card-acceptance business in eleven Asia-Pacific markets with more than 20,000 merchants; the Malaysian portfolio passed on 31 January 2018, the Indian on 31 August 2018 and those of Australia and New Zealand on 25 October 2018. Mainly as a result, goodwill rose by EUR 39.7 million to EUR 705.9 million at the end of 2018. EY treated the acquisition as a key audit matter because management had to judge whether it was a business combination, how to allocate the price and how to value liabilities from customer contracts. The 2018 report also describes partnerships with Crédit Agricole Payment Services in Europe and with Mizuho Bank for Japanese retailers in Singapore and Hong Kong.","source_ids":["src-005"],"entity_ids":["wirecard","citigroup","citibank-na","citi-overseas","ey","caps","mizuho"],"premise_claim_ids":["c-acq-citi-asia","c-acq-partnerships-2018"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 13 March 2017 Wirecard agreed with the Citigroup subsidiaries Citibank, N.A. and Citibank Overseas Investment Corporation to acquire the customer portfolios of Citi's card-acceptance business in eleven Asia-Pacific markets with more than 20,000 merchants; the Malaysian portfolio passed on 31 January 2018, the Indian on 31 August 2018 and those of Australia and New Zealand on 25 October 2018. Mainly as a result, goodwill rose by EUR 39.7 million to EUR 705.9 million at the end of 2018. EY treated the acquisition as a key audit matter because management had to judge whether it was a business combination, how to allocate the price and how to value liabilities from customer contracts. The 2018 report also describes partnerships with Crédit Agricole Payment Services in Europe and with Mizuho Bank for Japanese retailers in Singapore and Hong Kong."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-d4ac75940883dad63fc14e0b","record":{"id":"display-claim-d4ac75940883dad63fc14e0b","kind":"analysis","text":"Wirecard's own reports described the arrangement only in general terms. The 2017 annual report says that Wirecard UK & Ireland, Wirecard Brasil, cardSystems Middle East in Dubai and many East Asian subsidiaries worked with banks and financial service providers so that they could offer acquiring and issuing services where Wirecard could not use its own licence, and that the purchases from Citigroup expanded the network of these unnamed acquiring partners. The 2018 report explains that when an external acquiring partner processed transactions, the partner recorded the payment volumes and Wirecard showed as receivables only its commissions and rolling security reserves; its risk report says Wirecard bore the main opportunities and risks whether transactions ran through its own licensed acquirers or external partners, and that Wirecard Bank in some cases lent to strategic partners. Volumes increasingly ran through a \"technical acquiring model\" and, outside the European licensing area, through BIN-sponsorship models with third-party banks that the report does not name. The 2019 prospectus states that CardSystems Middle East's accounts for 2017 and 2018 were not audited and that it had not appointed its own auditor.","source_ids":["src-020","src-005","src-012"],"entity_ids":["wirecard","wd-uki","wd-brazil","cardsystems-me","citigroup","wd-bank"],"premise_claim_ids":["c-tpa-company-2017","c-tpa-company-2018","c-tpa-company-2018-segment","c-tpa-cardsystems-unaudited"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard's own reports described the arrangement only in general terms. The 2017 annual report says that Wirecard UK & Ireland, Wirecard Brasil, cardSystems Middle East in Dubai and many East Asian subsidiaries worked with banks and financial service providers so that they could offer acquiring and issuing services where Wirecard could not use its own licence, and that the purchases from Citigroup expanded the network of these unnamed acquiring partners. The 2018 report explains that when an external acquiring partner processed transactions, the partner recorded the payment volumes and Wirecard showed as receivables only its commissions and rolling security reserves; its risk report says Wirecard bore the main opportunities and risks whether transactions ran through its own licensed acquirers or external partners, and that Wirecard Bank in some cases lent to strategic partners. Volumes increasingly ran through a \"technical acquiring model\" and, outside the European licensing area, through BIN-sponsorship models with third-party banks that the report does not name. The 2019 prospectus states that CardSystems Middle East's accounts for 2017 and 2018 were not audited and that it had not appointed its own auditor."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-4d893eefa834ed74a584a695","record":{"id":"display-claim-4d893eefa834ed74a584a695","kind":"analysis","text":"Most of what is known about the business comes from the special investigators appointed by the Bundestag's third committee of inquiry. They examined EY's audits of the 2014–2018 accounts, with emphasis on 2014–2016, and where necessary the reporting packages of CardSystems Middle East, Wirecard Technologies, Wirecard UK & Ireland and Wirecard Bank, using EY's electronic working papers; their report was delivered on 16 April 2021. They describe two models: Wirecard's own business across the whole payment chain with Wirecard Bank as acquirer, and third-party acquiring (TPA), in which payment processing and the acquiring bank's services were outsourced to Al Alam, PayEasy and Senjo, which used other acquiring banks and alone held contracts with the merchants, while Wirecard kept customer acquisition and support. According to EY's papers, merchants in adult content and dating, gambling and gaming, multi-level marketing, pharmacy, health and beauty were moved to the partners because they were no longer to be processed on Wirecard's platform or because Wirecard Bank had no acquiring licence for their countries.","source_ids":["src-027"],"entity_ids":["wirecard","cardsystems-me","wd-tech","wd-uki","wd-bank","ey","bundestag","al-alam","payeasy","senjo"],"premise_claim_ids":["c-tpa-rp-scope","c-tpa-rp-two-models","c-tpa-rp-reasons"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Most of what is known about the business comes from the special investigators appointed by the Bundestag's third committee of inquiry. They examined EY's audits of the 2014–2018 accounts, with emphasis on 2014–2016, and where necessary the reporting packages of CardSystems Middle East, Wirecard Technologies, Wirecard UK & Ireland and Wirecard Bank, using EY's electronic working papers; their report was delivered on 16 April 2021. They describe two models: Wirecard's own business across the whole payment chain with Wirecard Bank as acquirer, and third-party acquiring (TPA), in which payment processing and the acquiring bank's services were outsourced to Al Alam, PayEasy and Senjo, which used other acquiring banks and alone held contracts with the merchants, while Wirecard kept customer acquisition and support. According to EY's papers, merchants in adult content and dating, gambling and gaming, multi-level marketing, pharmacy, health and beauty were moved to the partners because they were no longer to be processed on Wirecard's platform or because Wirecard Bank had no acquiring licence for their countries."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-ba23a9bc22a9ca26a76d57a2","record":{"id":"display-claim-ba23a9bc22a9ca26a76d57a2","kind":"analysis","text":"The business rested on reseller agreements that, according to EY's notes, were identical for the three partners: Wirecard earned a commission for referring merchants, payable six to nine months later, deposited cash collateral with the partners (in Al Alam's case first EUR 10 million, later up to EUR 20 million), indemnified them against losses not caused by their own technical errors and provided a rolling 12-month reserve on volumes with long-term risk such as subscriptions. EY's concurrence memorandum of 3 March 2016, as the special investigators read it, gave as the essential business reason the legal carving-out of critical transactions such as adult entertainment, gambling and food supplements and the circumvention of Visa and Mastercard rules and Wirecard Bank's internal rules; the underlying description came from Wirecard's management. The investigators note that Wirecard had contracts neither with the acquiring banks nor with the merchants, and that the extended liability for residual risks served the accounting purpose of showing revenue and costs gross.","source_ids":["src-027"],"entity_ids":["wirecard","al-alam","payeasy","senjo","ey","wd-bank"],"premise_claim_ids":["c-tpa-rp-reseller","c-tpa-rp-business-reason"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The business rested on reseller agreements that, according to EY's notes, were identical for the three partners: Wirecard earned a commission for referring merchants, payable six to nine months later, deposited cash collateral with the partners (in Al Alam's case first EUR 10 million, later up to EUR 20 million), indemnified them against losses not caused by their own technical errors and provided a rolling 12-month reserve on volumes with long-term risk such as subscriptions. EY's concurrence memorandum of 3 March 2016, as the special investigators read it, gave as the essential business reason the legal carving-out of critical transactions such as adult entertainment, gambling and food supplements and the circumvention of Visa and Mastercard rules and Wirecard Bank's internal rules; the underlying description came from Wirecard's management. The investigators note that Wirecard had contracts neither with the acquiring banks nor with the merchants, and that the extended liability for residual risks served the accounting purpose of showing revenue and costs gross."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-d2b1fc0134bc5a4412aaea8c","record":{"id":"display-claim-d2b1fc0134bc5a4412aaea8c","kind":"analysis","text":"In practice, the investigators found, settlement departed considerably from the agreements: by agreement between Wirecard and each partner, receivables were not paid after six to nine months but \"reclassified\" into claims arising from security deposits, so that with fast-growing high-risk business the partners paid Wirecard little or nothing while receivables and reserves accumulated, and no claims were ever made on these securities. The safekeeping of funds at the partners was monitored only through meetings between the management board and the partners' management, without formal documentation. This is the investigators' evaluation of EY's audit files for the parliamentary committee, not a court finding.","source_ids":["src-027"],"entity_ids":["wirecard"],"premise_claim_ids":["c-tpa-rp-practice"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In practice, the investigators found, settlement departed considerably from the agreements: by agreement between Wirecard and each partner, receivables were not paid after six to nine months but \"reclassified\" into claims arising from security deposits, so that with fast-growing high-risk business the partners paid Wirecard little or nothing while receivables and reserves accumulated, and no claims were ever made on these securities. The safekeeping of funds at the partners was monitored only through meetings between the management board and the partners' management, without formal documentation. This is the investigators' evaluation of EY's audit files for the parliamentary committee, not a court finding."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-50bf9324353228854a16211a","record":{"id":"display-claim-50bf9324353228854a16211a","kind":"analysis","text":"The investigators' table shows TPA revenue rising from EUR 308 million in 2014 to EUR 376 million, EUR 541 million, EUR 727 million and EUR 1,034 million in 2018, when group revenue was EUR 2,016 million, while escrow balances counted as cash rose from EUR 114 million (2015) to EUR 976 million (2018) and merchant cash advance loans of EUR 250 million appear for 2018. In 2014 the business accounted for half of revenue, about two thirds of receivables and three quarters of EBITDA (EUR 132.7 million of EUR 172.3 million), in 2015 for 48.7% of revenue and 72.2% of EBITDA, although the 2015 group management report never named it explicitly. Because Wirecard booked the business gross but received money only net, the investigators calculate that about 27% of 2015 group revenue and about 51% of the cost of materials were non-cash transactions, which the notes to the 2015 accounts did not disclose.","source_ids":["src-027"],"entity_ids":["wirecard","ey"],"premise_claim_ids":["c-tpa-rp-figures","c-tpa-rp-2014-2015-share","c-tpa-rp-gross"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The investigators' table shows TPA revenue rising from EUR 308 million in 2014 to EUR 376 million, EUR 541 million, EUR 727 million and EUR 1,034 million in 2018, when group revenue was EUR 2,016 million, while escrow balances counted as cash rose from EUR 114 million (2015) to EUR 976 million (2018) and merchant cash advance loans of EUR 250 million appear for 2018. In 2014 the business accounted for half of revenue, about two thirds of receivables and three quarters of EBITDA (EUR 132.7 million of EUR 172.3 million), in 2015 for 48.7% of revenue and 72.2% of EBITDA, although the 2015 group management report never named it explicitly. Because Wirecard booked the business gross but received money only net, the investigators calculate that about 27% of 2015 group revenue and about 51% of the cost of materials were non-cash transactions, which the notes to the 2015 accounts did not disclose."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-b84b74fe28b6dffd1a830a71","record":{"id":"display-claim-b84b74fe28b6dffd1a830a71","kind":"analysis","text":"According to the investigators' evaluation, receivables from PayEasy, Al Alam and Senjo (formerly Rising Sun), claims on escrow accounts and merchant cash advance loans reached EUR 1,465.5 million at the end of 2018; individual TPA transactions could not be traced from origination to payment in Wirecard's accounting, and EY's 2018 group audit report did not mention bookkeeping deficiencies in the business. Comparing margins, they note that Wirecard Bank's own acquiring fell to a gross margin of 10% in 2018 while the TPA business showed 43–56%, although Wirecard did less of the work there, and regard Wirecard's explanation that the business carried high risks as contradicted by the absence of any liability claims.","source_ids":["src-027"],"entity_ids":["wirecard","payeasy","al-alam","senjo","ey","wd-bank"],"premise_claim_ids":["c-tpa-rp-2018-total","c-tpa-rp-margins"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to the investigators' evaluation, receivables from PayEasy, Al Alam and Senjo (formerly Rising Sun), claims on escrow accounts and merchant cash advance loans reached EUR 1,465.5 million at the end of 2018; individual TPA transactions could not be traced from origination to payment in Wirecard's accounting, and EY's 2018 group audit report did not mention bookkeeping deficiencies in the business. Comparing margins, they note that Wirecard Bank's own acquiring fell to a gross margin of 10% in 2018 while the TPA business showed 43–56%, although Wirecard did less of the work there, and regard Wirecard's explanation that the business carried high risks as contradicted by the absence of any liability claims."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-b5f17c04623f909c0a5df4f7","record":{"id":"display-claim-b5f17c04623f909c0a5df4f7","kind":"analysis","text":"Supervisors' figures point the same way. ESMA notes that the 2014 accounts showed acquiring deposits at Wirecard Bank of EUR 240 million as a separate item, which the 2015 accounts no longer did. Figures from the financial reporting enforcement panel (FREP) in ESMA's report show trust account balances of EUR 849 million at 30 June 2018 and EUR 1.9 billion at the end of 2019, which could not be verified and were most likely inaccessible, and revenue with questionable partners in the first half of 2018 of about EUR 460 million, 51% of EUR 898 million, with gross profit of about EUR 250 million against EBITDA of EUR 245 million.","source_ids":["src-087"],"entity_ids":["wirecard","wd-bank","esma","dpr"],"premise_claim_ids":["c-tpa-2014-deposits","c-tpa-freq-balances"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Supervisors' figures point the same way. ESMA notes that the 2014 accounts showed acquiring deposits at Wirecard Bank of EUR 240 million as a separate item, which the 2015 accounts no longer did. Figures from the financial reporting enforcement panel (FREP) in ESMA's report show trust account balances of EUR 849 million at 30 June 2018 and EUR 1.9 billion at the end of 2019, which could not be verified and were most likely inaccessible, and revenue with questionable partners in the first half of 2018 of about EUR 460 million, 51% of EUR 898 million, with gross profit of about EUR 250 million against EBITDA of EUR 245 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-f3b2e8e7ba4261ea26ff143e","record":{"id":"display-claim-f3b2e8e7ba4261ea26ff143e","kind":"analysis","text":"Money mostly flowed from Wirecard to the partners. The investigators found that Wirecard kept permanent cash collateral of EUR 15–20 million with PayEasy and Al Alam although the acquirer was already protected by four lines of security, agreed in 2016 to raise PayEasy's collateral to EUR 50 million and financed growing collateral, including EUR 14.5 million paid to PayEasy Solutions Inc., from its own and borrowed funds, while the partners' payments were small relative to turnover and arrived only net; their report calls this economically very unusual, and EY performed no analytical procedures on these flows. In 2018, while the business grew sharply, only one payment arrived from the partners, about EUR 15 million from PayEasy in the first quarter, against receivables from PayEasy, including merchant cash advances, of about EUR 278 million at the end of the year; it was booked as a lump sum without reference to particular invoices.","source_ids":["src-027"],"entity_ids":["wirecard","payeasy","al-alam"],"premise_claim_ids":["c-tpa-rp-collateral","c-tpa-rp-2018-payment"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Money mostly flowed from Wirecard to the partners. The investigators found that Wirecard kept permanent cash collateral of EUR 15–20 million with PayEasy and Al Alam although the acquirer was already protected by four lines of security, agreed in 2016 to raise PayEasy's collateral to EUR 50 million and financed growing collateral, including EUR 14.5 million paid to PayEasy Solutions Inc., from its own and borrowed funds, while the partners' payments were small relative to turnover and arrived only net; their report calls this economically very unusual, and EY performed no analytical procedures on these flows. In 2018, while the business grew sharply, only one payment arrived from the partners, about EUR 15 million from PayEasy in the first quarter, against receivables from PayEasy, including merchant cash advances, of about EUR 278 million at the end of the year; it was booked as a lump sum without reference to particular invoices."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-394009a023f04bf74746a107","record":{"id":"display-claim-394009a023f04bf74746a107","kind":"analysis","text":"The payments that did arrive did not refer to invoices, and some came from unknown third parties. On 30 December 2014 Ressource Management Systems Pte. of Singapore paid EUR 23.0 million into an account at Wirecard Bank with the reference \"SETTL. INV PEASYGRP 02-14\", which EY noted as a payment by an unknown third party without further work; in 2015 Tuscany Capital Advisors Pte. Ltd. paid EUR 10 million for Rising Sun/Senjo, and Senjo's management said Tuscany belonged to its group, although Senjo's 2018 accounts do not list it as a subsidiary. Al Alam paid mainly by cheques without payment references, EUR 39.9 million in 2015–2017, drawn on its own accounts at Wirecard Bank, including EUR 14,267,271 on 29 December 2017; the slip for a cheque of EUR 2,997,988.82 dated 9 July 2015 named Wirecard Bank itself, not Al Alam, as the issuing client. The investigators count Al Alam's several accounts at the bank and its German-language cheque forms among the signs of the partners' particular closeness to Wirecard.","source_ids":["src-027"],"entity_ids":["wirecard","wd-bank","ressource","payeasy","tuscany","senjo","ey","al-alam"],"premise_claim_ids":["c-tpa-rp-payers","c-tpa-rp-alalam-cheques"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The payments that did arrive did not refer to invoices, and some came from unknown third parties. On 30 December 2014 Ressource Management Systems Pte. of Singapore paid EUR 23.0 million into an account at Wirecard Bank with the reference \"SETTL. INV PEASYGRP 02-14\", which EY noted as a payment by an unknown third party without further work; in 2015 Tuscany Capital Advisors Pte. Ltd. paid EUR 10 million for Rising Sun/Senjo, and Senjo's management said Tuscany belonged to its group, although Senjo's 2018 accounts do not list it as a subsidiary. Al Alam paid mainly by cheques without payment references, EUR 39.9 million in 2015–2017, drawn on its own accounts at Wirecard Bank, including EUR 14,267,271 on 29 December 2017; the slip for a cheque of EUR 2,997,988.82 dated 9 July 2015 named Wirecard Bank itself, not Al Alam, as the issuing client. The investigators count Al Alam's several accounts at the bank and its German-language cheque forms among the signs of the partners' particular closeness to Wirecard."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-a9f60c26dc4607f77ac3dc99","record":{"id":"display-claim-a9f60c26dc4607f77ac3dc99","kind":"analysis","text":"PayEasy Solutions Inc. accounted at the end of 2014 for receivables of EUR 62.5 million, about 18% of the group's, and for 2014 revenue of EUR 75.8 million and EBITDA of EUR 31.4 million. In March 2015 EY's forensic team could not confirm its existence and location: it was not registered with the Philippine Department of Trade and Industry, was no longer a tenant at its address in Makati, its website was down and its latest filing with the Philippine securities regulator was a general information sheet for 2011. A letter of 13 March 2015 from PayEasy's financial controller explaining the gaps went to Marsalek, who forwarded it to Ley, who passed it to EY; the investigators found no check of these letters, and EY's forensic review ended without remarks before the audit opinion of 7 April 2015 despite warning signs, including two management board members personally obtaining the evidence. The working papers do not document how PayEasy's status was finally clarified.","source_ids":["src-027"],"entity_ids":["payeasy","wirecard","ey","marsalek","ley"],"premise_claim_ids":["c-tpa-rp-payeasy-2014","c-tpa-rp-payeasy-existence"],"qualification":"","response":"","outcome":""},"reading":"Analysis: PayEasy Solutions Inc. accounted at the end of 2014 for receivables of EUR 62.5 million, about 18% of the group's, and for 2014 revenue of EUR 75.8 million and EBITDA of EUR 31.4 million. In March 2015 EY's forensic team could not confirm its existence and location: it was not registered with the Philippine Department of Trade and Industry, was no longer a tenant at its address in Makati, its website was down and its latest filing with the Philippine securities regulator was a general information sheet for 2011. A letter of 13 March 2015 from PayEasy's financial controller explaining the gaps went to Marsalek, who forwarded it to Ley, who passed it to EY; the investigators found no check of these letters, and EY's forensic review ended without remarks before the audit opinion of 7 April 2015 despite warning signs, including two management board members personally obtaining the evidence. The working papers do not document how PayEasy's status was finally clarified."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-a146be258228214b8c7093e1","record":{"id":"display-claim-a146be258228214b8c7093e1","kind":"analysis","text":"Instead of financial statements, EY received from PayEasy a letter of 26 March 2015 with a few 2014 figures, from which the investigators calculate that Wirecard's 2014 revenue with PayEasy (EUR 75.8 million) exceeded PayEasy's own total revenue (EUR 72.2 million). By 2018 PayEasy reported revenue of EUR 666.1 million on transaction volume of EUR 5,519.9 million with personnel costs of EUR 267,000, and audited accounts were available to Wirecard's auditor only for that year. Drawing on EY's compliance check and working papers, the investigators observe that PayEasy received rates of 2.15–3% plus fees and Al Alam only 2%, yet PayEasy reported a gross margin of 0.24% in 2017; that both partners' personnel costs were extremely small for their turnover; and that from September 2016 two registrations of PayEasy Solutions Inc. existed with the same name but different numbers and addresses. PayEasy's main merchant, Escalion, accounted for EUR 1.238 billion in the fourth quarter of 2018, 90% of its volume, which EY reconciled on 20 February 2019 only on totals together with Oliver Bellenhaus; for another merchant, Wirecard's payment system showed 23,033 transactions for October 2018 while a controlling export showed 286,921, differences of an order of magnitude that the auditor did not investigate.","source_ids":["src-027"],"entity_ids":["payeasy","ey","wirecard","al-alam","bellenhaus"],"premise_claim_ids":["c-tpa-rp-payeasy-figures","c-tpa-rp-payeasy-terms","c-tpa-rp-escalion"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Instead of financial statements, EY received from PayEasy a letter of 26 March 2015 with a few 2014 figures, from which the investigators calculate that Wirecard's 2014 revenue with PayEasy (EUR 75.8 million) exceeded PayEasy's own total revenue (EUR 72.2 million). By 2018 PayEasy reported revenue of EUR 666.1 million on transaction volume of EUR 5,519.9 million with personnel costs of EUR 267,000, and audited accounts were available to Wirecard's auditor only for that year. Drawing on EY's compliance check and working papers, the investigators observe that PayEasy received rates of 2.15–3% plus fees and Al Alam only 2%, yet PayEasy reported a gross margin of 0.24% in 2017; that both partners' personnel costs were extremely small for their turnover; and that from September 2016 two registrations of PayEasy Solutions Inc. existed with the same name but different numbers and addresses. PayEasy's main merchant, Escalion, accounted for EUR 1.238 billion in the fourth quarter of 2018, 90% of its volume, which EY reconciled on 20 February 2019 only on totals together with Oliver Bellenhaus; for another merchant, Wirecard's payment system showed 23,033 transactions for October 2018 while a controlling export showed 286,921, differences of an order of magnitude that the auditor did not investigate."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-62ad69745186bff9110305dd","record":{"id":"display-claim-62ad69745186bff9110305dd","kind":"analysis","text":"For Al Alam Solutions Provider FZ-LLC, a credit report in EY's files showed 2016 revenue of about USD 3 million, far below the mid-three-digit million US dollar figures Al Alam reported for 2015–2018, and its website's registrant e-mail used a different domain. The investigators found that EY had only management estimates or forecasts from Al Alam, no actual accounts; that its volumes for the first and second quarters were identical in 2016 and 2017 (EUR 866,491,337 and EUR 963,579,293); and that its gross margin rose from 20.6% to 51.0% while Wirecard Bank's fell, which the auditor did not examine. Al Alam's own position is not in the record. More generally, EY received no audited or other financial statements from any partner for 2015–2017, only unverified summary figures, and for 2018 only from PayEasy and Senjo Group. During the 2014 audit EY's forensic specialists had run compliance quick checks on Al Alam, PayEasy, Rising Sun, Hamesh Ltd and Bonatal Trading Industries Ltd.","source_ids":["src-027"],"entity_ids":["al-alam","ey","wd-bank","wirecard","payeasy","senjo","hamesh","bonatal"],"premise_claim_ids":["c-tpa-rp-alalam","c-tpa-rp-no-accounts","c-tpa-rp-cqc"],"qualification":"","response":"","outcome":""},"reading":"Analysis: For Al Alam Solutions Provider FZ-LLC, a credit report in EY's files showed 2016 revenue of about USD 3 million, far below the mid-three-digit million US dollar figures Al Alam reported for 2015–2018, and its website's registrant e-mail used a different domain. The investigators found that EY had only management estimates or forecasts from Al Alam, no actual accounts; that its volumes for the first and second quarters were identical in 2016 and 2017 (EUR 866,491,337 and EUR 963,579,293); and that its gross margin rose from 20.6% to 51.0% while Wirecard Bank's fell, which the auditor did not examine. Al Alam's own position is not in the record. More generally, EY received no audited or other financial statements from any partner for 2015–2017, only unverified summary figures, and for 2018 only from PayEasy and Senjo Group. During the 2014 audit EY's forensic specialists had run compliance quick checks on Al Alam, PayEasy, Rising Sun, Hamesh Ltd and Bonatal Trading Industries Ltd."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-120d7bdacf4dc15481245054","record":{"id":"display-claim-120d7bdacf4dc15481245054","kind":"analysis","text":"Senjo's leading managers had earlier done business with Wirecard. According to EY's 2016 compliance check, as the investigators summarise it, they sold E-Creditplus Pte. Ltd. to Wirecard for EUR 12.8 million and later bought it back for a net EUR 0.1 million, which the short-seller Zatarra called roundtripping; a director of Senjo Payment Asia had worked at Wirecard Asia; and the secretary of Senjo Payments Asia, R. Shanmugaratnam, matched by name and document number the signatory of a trustee confirmation of 25 May 2016. The investigators say this could indicate a link between Senjo and the trustee and a conflict of interest, an inference rather than an established fact. The annexes to the insolvency administrator's TPA report include an e-mail of 2 June 2015 in which Marsalek asked that Senjo be supported, remarking that this would not create a competitor. Senjo bought Kalixa Payments Group as of 1 June 2017 for EUR 29.0 million, EUR 25.0 million of it lent by Wirecard Bank with the approval of Wirecard's management and supervisory boards; Senjo was the only partner whose creditworthiness was checked, and the group auditor did not take into account the bank auditors' doubts about its ability to service debt.","source_ids":["src-027"],"entity_ids":["senjo","wirecard","wd-asia-pte","rajaratnam","citadelle","marsalek","jaffe","bundestag","kalixa","wd-bank","ey"],"premise_claim_ids":["c-tpa-rp-senjo","c-tpa-rp-senjo-email","c-tpa-rp-kalixa"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Senjo's leading managers had earlier done business with Wirecard. According to EY's 2016 compliance check, as the investigators summarise it, they sold E-Creditplus Pte. Ltd. to Wirecard for EUR 12.8 million and later bought it back for a net EUR 0.1 million, which the short-seller Zatarra called roundtripping; a director of Senjo Payment Asia had worked at Wirecard Asia; and the secretary of Senjo Payments Asia, R. Shanmugaratnam, matched by name and document number the signatory of a trustee confirmation of 25 May 2016. The investigators say this could indicate a link between Senjo and the trustee and a conflict of interest, an inference rather than an established fact. The annexes to the insolvency administrator's TPA report include an e-mail of 2 June 2015 in which Marsalek asked that Senjo be supported, remarking that this would not create a competitor. Senjo bought Kalixa Payments Group as of 1 June 2017 for EUR 29.0 million, EUR 25.0 million of it lent by Wirecard Bank with the approval of Wirecard's management and supervisory boards; Senjo was the only partner whose creditworthiness was checked, and the group auditor did not take into account the bank auditors' doubts about its ability to service debt."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-552c32d66f1d2f2a0e998b63","record":{"id":"display-claim-552c32d66f1d2f2a0e998b63","kind":"analysis","text":"Wirecard gave the auditor no external documents on the partners' financial stability, the investigators found, but memos by Marsalek as chief operating officer explaining why they had been chosen, and had no formalised assessment of them; for receivables from other debtors not confirmed at the end of 2014 EY also obtained internal memos from Marsalek, while Al Alam (EUR 18.1 million), PayEasy (EUR 62.5 million) and Rising Sun (EUR 47.8 million) confirmed their balances without the slightest deviation. In the 2015 audit, documentation and reconciliations for the business came from senior managers: Bellenhaus as managing director of CardSystems Middle East, the head of Wirecard Sales International, Marsalek, and Stephan von Erffa as executive vice president accounting; Marsalek personally joined the auditor's enquiries.","source_ids":["src-027"],"entity_ids":["wirecard","marsalek","al-alam","payeasy","senjo","ey","bellenhaus","cardsystems-me","wd-sih","von-erffa"],"premise_claim_ids":["c-tpa-rp-marsalek-notes","c-tpa-rp-managers"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard gave the auditor no external documents on the partners' financial stability, the investigators found, but memos by Marsalek as chief operating officer explaining why they had been chosen, and had no formalised assessment of them; for receivables from other debtors not confirmed at the end of 2014 EY also obtained internal memos from Marsalek, while Al Alam (EUR 18.1 million), PayEasy (EUR 62.5 million) and Rising Sun (EUR 47.8 million) confirmed their balances without the slightest deviation. In the 2015 audit, documentation and reconciliations for the business came from senior managers: Bellenhaus as managing director of CardSystems Middle East, the head of Wirecard Sales International, Marsalek, and Stephan von Erffa as executive vice president accounting; Marsalek personally joined the auditor's enquiries."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-2be8e2dffcbe5573781c8113","record":{"id":"display-claim-2be8e2dffcbe5573781c8113","kind":"analysis","text":"ESMA, drawing on Financial Times reporting, names Al Alam Solution Provider FZ LLC of Dubai, Senjo Payment Asia Pte Ltd of Singapore and PayEasy Solution Inc. of the Philippines as the three largest partners in 2018, with their revenue reaching the group through CardSystems Middle East, Wirecard UK & Ireland and Wirecard Technologies; Wirecard itself had stated that neither Wirecard Bank nor other group companies outside the EU held their own acquiring licence in the third countries concerned. Al Alam went into liquidation on 15 May 2020. From 18 May 2020 BaFin's market-abuse team investigated whether the liquidation of CardSystems Middle East and Al Alam was inside information Wirecard should have disclosed; BaFin received documents on Al Alam from a third-country regulator in September 2020, and the investigation was unfinished when ESMA reported.","source_ids":["src-087"],"entity_ids":["al-alam","senjo","payeasy","cardsystems-me","wd-uki","wd-tech","wd-bank","wirecard","esma","ft","bafin","apas"],"premise_claim_ids":["c-tpa-esma-ft-partners","c-tpa-alalam-liquidation"],"qualification":"","response":"","outcome":""},"reading":"Analysis: ESMA, drawing on Financial Times reporting, names Al Alam Solution Provider FZ LLC of Dubai, Senjo Payment Asia Pte Ltd of Singapore and PayEasy Solution Inc. of the Philippines as the three largest partners in 2018, with their revenue reaching the group through CardSystems Middle East, Wirecard UK & Ireland and Wirecard Technologies; Wirecard itself had stated that neither Wirecard Bank nor other group companies outside the EU held their own acquiring licence in the third countries concerned. Al Alam went into liquidation on 15 May 2020. From 18 May 2020 BaFin's market-abuse team investigated whether the liquidation of CardSystems Middle East and Al Alam was inside information Wirecard should have disclosed; BaFin received documents on Al Alam from a third-country regulator in September 2020, and the investigation was unfinished when ESMA reported."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-d16d31b7712216483cbb2898","record":{"id":"display-claim-d16d31b7712216483cbb2898","kind":"analysis","text":"With the switch to IFRS 15 Wirecard concluded new contracts with all partners as of 1 January 2018. According to the investigators' second addendum, CardSystems Middle East bought the e-payment platforms of Senjo Payment Asia (contract of 16 April 2018) and of Al Alam (30 July 2018), each retroactively to 1 January 2018 and for EUR 6.5 million; the two contracts have identical technical specifications, the Al Alam contract names Senjo instead of Al Alam six times, and there is no sign that the systems were integrated. PayEasy's transactions moved to Wirecard's \"Elastic Engine\" platform, a \"liability notice\" was introduced, and Wirecard could withdraw money from the trust accounts without the partners' consent. The investigators conclude that gross accounting and the treatment of trust funds as cash looked formally justified from 2018, but that EY's files contain no evidence that Wirecard actually controlled the business.","source_ids":["src-027"],"entity_ids":["wirecard","cardsystems-me","senjo","al-alam","payeasy"],"premise_claim_ids":["c-tpa-rp-2018-contracts"],"qualification":"","response":"","outcome":""},"reading":"Analysis: With the switch to IFRS 15 Wirecard concluded new contracts with all partners as of 1 January 2018. According to the investigators' second addendum, CardSystems Middle East bought the e-payment platforms of Senjo Payment Asia (contract of 16 April 2018) and of Al Alam (30 July 2018), each retroactively to 1 January 2018 and for EUR 6.5 million; the two contracts have identical technical specifications, the Al Alam contract names Senjo instead of Al Alam six times, and there is no sign that the systems were integrated. PayEasy's transactions moved to Wirecard's \"Elastic Engine\" platform, a \"liability notice\" was introduced, and Wirecard could withdraw money from the trust accounts without the partners' consent. The investigators conclude that gross accounting and the treatment of trust funds as cash looked formally justified from 2018, but that EY's files contain no evidence that Wirecard actually controlled the business."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-f6385e4f9733c859ebca95ba","record":{"id":"display-claim-f6385e4f9733c859ebca95ba","kind":"analysis","text":"In the 2018 audit EY could not perform the prescribed test of ten cash transactions at CardSystems Middle East because TPA transactions could not be traced individually. To test whether the business existed it made five test purchases with Wirecard cards at the partners' merchants, on websites that Bellenhaus proposed on 16 February 2019; EY's files do not say how the merchants were chosen. The confirmation e-mail for one purchase came from an unrelated hosting address hours before the purchase recorded in the auditor's screenshots, which the investigators note may have been altered, and Bellenhaus supplied screenshots of a bitcoin purchase only on 8 April 2019.","source_ids":["src-027"],"entity_ids":["ey","cardsystems-me","bellenhaus","wirecard"],"premise_claim_ids":["c-tpa-rp-2018-tests"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In the 2018 audit EY could not perform the prescribed test of ten cash transactions at CardSystems Middle East because TPA transactions could not be traced individually. To test whether the business existed it made five test purchases with Wirecard cards at the partners' merchants, on websites that Bellenhaus proposed on 16 February 2019; EY's files do not say how the merchants were chosen. The confirmation e-mail for one purchase came from an unrelated hosting address hours before the purchase recorded in the auditor's screenshots, which the investigators note may have been altered, and Bellenhaus supplied screenshots of a bitcoin purchase only on 8 April 2019."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-ef90c1bbb608439459cdb6e9","record":{"id":"display-claim-ef90c1bbb608439459cdb6e9","kind":"analysis","text":"After trust (escrow) accounts were set up in 2015, Citadelle Corporate Services Pte. Ltd. of Singapore acted as trustee. According to the special investigators the trust agreement gave Wirecard no information rights such as monthly statements, bank balance confirmations or proof that the accounts had been opened, and EY requested balance confirmations from the trustee for 2015–2017. The investigators list the evidence EY obtained on the business: Wirecard Bank statements of the group companies concerned, balance confirmations from the partners, unsigned Excel or PDF lists of transaction volumes, screenshots of test purchases and, from 2015, trust agreements and trustee confirmations, together with site visits to Al Alam in Dubai (2015), PayEasy in Manila (2016) and Senjo in Singapore (2017).","source_ids":["src-027"],"entity_ids":["citadelle","wirecard","ey","wd-bank","al-alam","payeasy","senjo","bundestag"],"premise_claim_ids":["c-tpa-rp-citadelle","c-aud-tpa-evidence"],"qualification":"","response":"","outcome":""},"reading":"Analysis: After trust (escrow) accounts were set up in 2015, Citadelle Corporate Services Pte. Ltd. of Singapore acted as trustee. According to the special investigators the trust agreement gave Wirecard no information rights such as monthly statements, bank balance confirmations or proof that the accounts had been opened, and EY requested balance confirmations from the trustee for 2015–2017. The investigators list the evidence EY obtained on the business: Wirecard Bank statements of the group companies concerned, balance confirmations from the partners, unsigned Excel or PDF lists of transaction volumes, screenshots of test purchases and, from 2015, trust agreements and trustee confirmations, together with site visits to Al Alam in Dubai (2015), PayEasy in Manila (2016) and Senjo in Singapore (2017)."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-5249d760e9b6fa825d081054","record":{"id":"display-claim-5249d760e9b6fa825d081054","kind":"analysis","text":"The investigators list inconsistencies in the 2015–2016 confirmations that EY did not follow up: one named Wirecard Technologies GmbH as beneficiary of account 6508 4162 0001 although CardSystems Middle East had concluded the trust agreement with Al Alam; Citadelle's e-mail addresses and contact names varied; on 25 May 2016 a balance of EUR 41,500,000 was confirmed on Senjo's account for Al Alam with Wirecard UK & Ireland as beneficiary; and at the end of 2016 Al Alam paid EUR 80,000,000 into an escrow account. EY's 2016 files contain two Citadelle confirmations dated 2 December 2016, for EUR 97,533,053.84 on account 6508 4162 0001 addressed to Wirecard UK & Ireland and for EUR 84,009,703.83 on account 6010 9797 5201 addressed to CardSystems Middle East; in both PDFs, the investigators found, signature and seal were inserted electronically and the stamp properties name the author \"Oliver\", whose identity the report does not establish. There is no confirmation at the end of 2016 for account 6010 9797 5201, which from the end of 2017 was no longer used as an escrow account, and EY's files contain no documents on the transfer of its funds. Whether the confirmations reflected real balances is the subject of the later records below.","source_ids":["src-027"],"entity_ids":["citadelle","wd-tech","cardsystems-me","al-alam","rajaratnam","senjo","wd-uki","ey","wirecard"],"premise_claim_ids":["c-tpa-rp-confirmations-2016","c-tpa-rp-confirmations-pdf","c-tpa-rp-account-6010"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The investigators list inconsistencies in the 2015–2016 confirmations that EY did not follow up: one named Wirecard Technologies GmbH as beneficiary of account 6508 4162 0001 although CardSystems Middle East had concluded the trust agreement with Al Alam; Citadelle's e-mail addresses and contact names varied; on 25 May 2016 a balance of EUR 41,500,000 was confirmed on Senjo's account for Al Alam with Wirecard UK & Ireland as beneficiary; and at the end of 2016 Al Alam paid EUR 80,000,000 into an escrow account. EY's 2016 files contain two Citadelle confirmations dated 2 December 2016, for EUR 97,533,053.84 on account 6508 4162 0001 addressed to Wirecard UK & Ireland and for EUR 84,009,703.83 on account 6010 9797 5201 addressed to CardSystems Middle East; in both PDFs, the investigators found, signature and seal were inserted electronically and the stamp properties name the author \"Oliver\", whose identity the report does not establish. There is no confirmation at the end of 2016 for account 6010 9797 5201, which from the end of 2017 was no longer used as an escrow account, and EY's files contain no documents on the transfer of its funds. Whether the confirmations reflected real balances is the subject of the later records below."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-016ca486462f8017f3dd8048","record":{"id":"display-claim-016ca486462f8017f3dd8048","kind":"analysis","text":"For the 2018 audit the trustee was still Citadelle. EY inspected bank statements during the trustee's visit to Aschheim on 26 March 2019 without receiving copies, and Citadelle's confirmation of 12 April 2019 named neither the account numbers nor the bank and carried a different stamp from earlier ones. In the investigators' evaluation, the auditor did not test the plausibility of trust balances of about EUR 976 million at OCBC Bank in Singapore, sent no confirmation requests to merchants and did not test the transaction chain, so that the confirmation of TPA revenue and cash rested only indirectly on the partners and the trustee. EY's 2019 audit file very probably contains confirmations from Banco de Oro (BDO Unibank) of 16 March 2020 and from Bank of the Philippine Islands of 17 March 2020 for 31 December 2019, a management board decision of 20 February 2020 replacing Citadelle with M. K. Tolentino as trustee, EY's letter of 16 June 2020 to the supervisory board chairman Thomas Eichelmann about possible irregularities, and EY's refusal of an opinion on the 2019 consolidated accounts. The insolvency administrator, Dr. Michael Jaffé, later sent the Bundestag committee a statement on the existence and possible size of the business, whose annexes include a 2016 Citadelle confirmation with \"obviously forged signatures\".","source_ids":["src-027"],"entity_ids":["citadelle","ey","ocbc","wirecard","bdo","bpi","tolentino","eichelmann","jaffe","bundestag"],"premise_claim_ids":["c-tpa-rp-2018-trustee","c-tpa-rp-2019-file","c-tpa-rp-jaffe-report"],"qualification":"","response":"","outcome":""},"reading":"Analysis: For the 2018 audit the trustee was still Citadelle. EY inspected bank statements during the trustee's visit to Aschheim on 26 March 2019 without receiving copies, and Citadelle's confirmation of 12 April 2019 named neither the account numbers nor the bank and carried a different stamp from earlier ones. In the investigators' evaluation, the auditor did not test the plausibility of trust balances of about EUR 976 million at OCBC Bank in Singapore, sent no confirmation requests to merchants and did not test the transaction chain, so that the confirmation of TPA revenue and cash rested only indirectly on the partners and the trustee. EY's 2019 audit file very probably contains confirmations from Banco de Oro (BDO Unibank) of 16 March 2020 and from Bank of the Philippine Islands of 17 March 2020 for 31 December 2019, a management board decision of 20 February 2020 replacing Citadelle with M. K. Tolentino as trustee, EY's letter of 16 June 2020 to the supervisory board chairman Thomas Eichelmann about possible irregularities, and EY's refusal of an opinion on the 2019 consolidated accounts. The insolvency administrator, Dr. Michael Jaffé, later sent the Bundestag committee a statement on the existence and possible size of the business, whose annexes include a 2016 Citadelle confirmation with \"obviously forged signatures\"."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-fb04ba01afa1ff62a4521f3f","record":{"id":"display-claim-fb04ba01afa1ff62a4521f3f","kind":"analysis","text":"From March 2019 the Financial Times reported, as ESMA summarises, that half of Wirecard's worldwide revenue and almost all its profit came from three opaque partners, which in 2016 produced 95% of EBITDA and more than half of revenue, that profits were channelled mainly through CardSystems Middle East in Dubai, and that the accounts disclosed none of this. In October 2019 it reported that in 2016–2017 Wirecard had routed billions of euros of payments for 34 clients through Al Alam, eight of which had ceased trading and 15 of which said they had never heard of Al Alam, and in December 2019 that EUR 334 million linked to Al Alam on trust accounts in 2017 had been wrongly classified as cash. Wirecard systematically rejected such allegations at the time; on 22 June 2020 it stated that the trust balances of EUR 1.9 billion probably did not exist.","source_ids":["src-087","src-025"],"entity_ids":["wirecard","cardsystems-me","al-alam","esma","ft"],"premise_claim_ids":["c-tpa-ft-2019"],"qualification":"","response":"","outcome":""},"reading":"Analysis: From March 2019 the Financial Times reported, as ESMA summarises, that half of Wirecard's worldwide revenue and almost all its profit came from three opaque partners, which in 2016 produced 95% of EBITDA and more than half of revenue, that profits were channelled mainly through CardSystems Middle East in Dubai, and that the accounts disclosed none of this. In October 2019 it reported that in 2016–2017 Wirecard had routed billions of euros of payments for 34 clients through Al Alam, eight of which had ceased trading and 15 of which said they had never heard of Al Alam, and in December 2019 that EUR 334 million linked to Al Alam on trust accounts in 2017 had been wrongly classified as cash. Wirecard systematically rejected such allegations at the time; on 22 June 2020 it stated that the trust balances of EUR 1.9 billion probably did not exist."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-961bfdae03a661dc6f472d31","record":{"id":"display-claim-961bfdae03a661dc6f472d31","kind":"analysis","text":"KPMG began an independent special investigation on 31 October 2019 and reported on 27 April 2020. The next day Wirecard announced that KPMG had found no incriminating evidence of balance-sheet manipulation and, in the four areas examined (third-party acquiring, merchant cash advance and digital lending, India and Singapore), no findings requiring adjustment of the 2016–2018 accounts; it also said that not all the data needed to prove TPA revenue could be obtained because third parties held it, that KPMG had identified documentation and organisational weaknesses, and that publication of the annual accounts on 30 April was cancelled pending coordination with EY. ESMA's chronology states that the report itself found the evidence insufficient to conclude either that the TPA revenue existed and was accurate or that it did not.","source_ids":["src-025","src-059","src-087"],"entity_ids":["kpmg","wirecard","europarl","ey","esma"],"premise_claim_ids":["c-aud-kpmg-timeline","c-aud-kpmg-adhoc","c-aud-kpmg-esma"],"qualification":"","response":"","outcome":""},"reading":"Analysis: KPMG began an independent special investigation on 31 October 2019 and reported on 27 April 2020. The next day Wirecard announced that KPMG had found no incriminating evidence of balance-sheet manipulation and, in the four areas examined (third-party acquiring, merchant cash advance and digital lending, India and Singapore), no findings requiring adjustment of the 2016–2018 accounts; it also said that not all the data needed to prove TPA revenue could be obtained because third parties held it, that KPMG had identified documentation and organisational weaknesses, and that publication of the annual accounts on 30 April was cancelled pending coordination with EY. ESMA's chronology states that the report itself found the evidence insufficient to conclude either that the TPA revenue existed and was accurate or that it did not."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-702a194b4dd1bd7ec7636213","record":{"id":"display-claim-702a194b4dd1bd7ec7636213","kind":"analysis","text":"ESMA, citing the report, states that KPMG could confirm only payments of EUR 85 million by two partners to accounts of Wirecard Technologies and CardSystems Middle East at Wirecard Bank, while Wirecard could not produce trustee statements to verify a final balance of about EUR 1 billion; unsecured credit lines of EUR 250 million ran in the opposite direction, and the subsidiaries had undertaken to compensate the partners for losses, secured by withholdings or escrow accounts at the trustee. Statements and confirmations from the bank managing the trust accounts were not provided because \"Trustee 1\" had ended its relationships with the Wirecard companies and did not answer enquiries.","source_ids":["src-087"],"entity_ids":["wirecard","kpmg","esma","wd-tech","cardsystems-me","wd-bank"],"premise_claim_ids":["c-tpa-kpmg-esma","c-tpa-kpmg-trustee1"],"qualification":"","response":"","outcome":""},"reading":"Analysis: ESMA, citing the report, states that KPMG could confirm only payments of EUR 85 million by two partners to accounts of Wirecard Technologies and CardSystems Middle East at Wirecard Bank, while Wirecard could not produce trustee statements to verify a final balance of about EUR 1 billion; unsecured credit lines of EUR 250 million ran in the opposite direction, and the subsidiaries had undertaken to compensate the partners for losses, secured by withholdings or escrow accounts at the trustee. Statements and confirmations from the bank managing the trust accounts were not provided because \"Trustee 1\" had ended its relationships with the Wirecard companies and did not answer enquiries."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-c48f3d45d456aebbfb6fee70","record":{"id":"display-claim-c48f3d45d456aebbfb6fee70","kind":"analysis","text":"According to ESMA's chronology, EY informed Wirecard on 16 June 2020 that the banks said to hold the accounts had stated that Wirecard had presented forged balance confirmations for trust accounts of EUR 1.9 billion in the 2019 audit. The same day EY informed BaFin, which says KPMG's report had until then contained only red flags without a finding of fraud; BaFin notified the public prosecutor on 18 June. That day Wirecard announced that EY could not obtain sufficient audit evidence for the EUR 1.9 billion, about a quarter of the consolidated balance sheet total, that there were indications that the trustee or the banks keeping the trust accounts had presented false balance confirmations to deceive the auditor, and that publication of the 2019 accounts was postponed.","source_ids":["src-087","src-024"],"entity_ids":["ey","wirecard","bafin","esma","kpmg"],"premise_claim_ids":["c-tpa-ey-informs","c-tpa-adhoc-2020-06-18"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to ESMA's chronology, EY informed Wirecard on 16 June 2020 that the banks said to hold the accounts had stated that Wirecard had presented forged balance confirmations for trust accounts of EUR 1.9 billion in the 2019 audit. The same day EY informed BaFin, which says KPMG's report had until then contained only red flags without a finding of fraud; BaFin notified the public prosecutor on 18 June. That day Wirecard announced that EY could not obtain sufficient audit evidence for the EUR 1.9 billion, about a quarter of the consolidated balance sheet total, that there were indications that the trustee or the banks keeping the trust accounts had presented false balance confirmations to deceive the auditor, and that publication of the 2019 accounts was postponed."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-8df2e2c50646c2823e11a07f","record":{"id":"display-claim-8df2e2c50646c2823e11a07f","kind":"analysis","text":"On 22 June 2020 Wirecard announced a prevailing likelihood that the balances did not exist; ESMA records its statement that the EUR 1.9 billion supposedly held on escrow accounts in the Philippines did not exist, and a European Parliament briefing recalls that on 3 May Wirecard had said KPMG's report confirmed none of the allegations. The day before, according to press reports, the governor of the Philippine central bank, Benjamin Diokno, said initial information showed that the missing funds, put at US$2.1 billion, had not entered the Philippine financial system and that BDO Unibank and Bank of the Philippine Islands had suffered no losses, their names having been used to cover the perpetrators' tracks; both banks said Wirecard was not their client and they had no business relationship with it. The briefing describes as the key question of KPMG's audit whether EUR 1.9 billion supposedly held in an escrow account at OCBC Bank in Singapore existed, noting that the report did not clarify all questions. According to a later press report citing a newspaper, OCBC told the insolvency administrator that it had never held significant sums on behalf of the trustee and that some of the accounts had never existed; no document of the bank itself is in the record.","source_ids":["src-025","src-087","src-031","src-067"],"entity_ids":["wirecard","esma","europarl","kpmg","bdo","bpi","ocbc","jaffe"],"premise_claim_ids":["c-tpa-2020-06-22","c-tpa-philippines","c-tpa-ocbc"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 22 June 2020 Wirecard announced a prevailing likelihood that the balances did not exist; ESMA records its statement that the EUR 1.9 billion supposedly held on escrow accounts in the Philippines did not exist, and a European Parliament briefing recalls that on 3 May Wirecard had said KPMG's report confirmed none of the allegations. The day before, according to press reports, the governor of the Philippine central bank, Benjamin Diokno, said initial information showed that the missing funds, put at US$2.1 billion, had not entered the Philippine financial system and that BDO Unibank and Bank of the Philippine Islands had suffered no losses, their names having been used to cover the perpetrators' tracks; both banks said Wirecard was not their client and they had no business relationship with it. The briefing describes as the key question of KPMG's audit whether EUR 1.9 billion supposedly held in an escrow account at OCBC Bank in Singapore existed, noting that the report did not clarify all questions. According to a later press report citing a newspaper, OCBC told the insolvency administrator that it had never held significant sums on behalf of the trustee and that some of the accounts had never existed; no document of the bank itself is in the record."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-5e23ef543799133c7f7afb1a","record":{"id":"display-claim-5e23ef543799133c7f7afb1a","kind":"analysis","text":"According to the Munich I prosecutor's investigation as summarised in the Federal Criminal Police Office's wanted notice, Marsalek and Braun inflated Wirecard's balance sheet total and revenue from no later than 2015, including fictitious revenue from payment transactions with the third-party acquirers; in the 2019 audit the auditor found the trust-account confirmations forged or not genuine, and assets of EUR 1.9 billion, a quarter of the balance sheet total, did not exist. This is a suspicion stated in a wanted notice: Braun denies the charges in the pending trial, and Marsalek has not been tried.","source_ids":["src-003"],"entity_ids":["marsalek","braun","wirecard","bka","sta-muenchen"],"premise_claim_ids":["c-tpa-bka"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to the Munich I prosecutor's investigation as summarised in the Federal Criminal Police Office's wanted notice, Marsalek and Braun inflated Wirecard's balance sheet total and revenue from no later than 2015, including fictitious revenue from payment transactions with the third-party acquirers; in the 2019 audit the auditor found the trust-account confirmations forged or not genuine, and assets of EUR 1.9 billion, a quarter of the balance sheet total, did not exist. This is a suspicion stated in a wanted notice: Braun denies the charges in the pending trial, and Marsalek has not been tried."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-214dff2d69ca3d22f5972cf6","record":{"id":"display-claim-214dff2d69ca3d22f5972cf6","kind":"analysis","text":"RP Richter GmbH and Ernst & Young GmbH were appointed joint auditors of Wirecard AG and the group for 2010 and issued an unqualified opinion on the 2010 individual and consolidated accounts, for fees of EUR 455,000 (Ernst & Young) and EUR 481,000 (RP Richter). Wirecard's 2018 report says that EY had audited the company jointly with RP Richter from the 2009 financial year and alone from 2011, and EY's 2018 opinion states that it had served as group auditor without interruption since 2009; it was elected by the shareholders' meeting of 21 June 2018 and engaged by the supervisory board on 25 June. A European Parliament briefing notes that EY had itself been tasked with a special investigation into allegations of accounting manipulation, a mandate that enabled it to replace Wirecard's former external auditor in 2010. The briefing reproduces a company statement that the investor protection association SdK had sued to challenge the 2008 annual general meeting's discharge of the boards and to have the 2007 accounts declared void, and that in autumn 2008 the supervisory board had EY prepare an expert opinion, which saw no need for corrections; the outcome of that action is not in the record.","source_ids":["src-023","src-005","src-025"],"entity_ids":["wirecard","rp-richter","ey","europarl","sdk"],"premise_claim_ids":["c-aud-2010-joint","c-aud-ey-tenure","c-aud-2008-mandate"],"qualification":"","response":"","outcome":""},"reading":"Analysis: RP Richter GmbH and Ernst & Young GmbH were appointed joint auditors of Wirecard AG and the group for 2010 and issued an unqualified opinion on the 2010 individual and consolidated accounts, for fees of EUR 455,000 (Ernst & Young) and EUR 481,000 (RP Richter). Wirecard's 2018 report says that EY had audited the company jointly with RP Richter from the 2009 financial year and alone from 2011, and EY's 2018 opinion states that it had served as group auditor without interruption since 2009; it was elected by the shareholders' meeting of 21 June 2018 and engaged by the supervisory board on 25 June. A European Parliament briefing notes that EY had itself been tasked with a special investigation into allegations of accounting manipulation, a mandate that enabled it to replace Wirecard's former external auditor in 2010. The briefing reproduces a company statement that the investor protection association SdK had sued to challenge the 2008 annual general meeting's discharge of the boards and to have the 2007 accounts declared void, and that in autumn 2008 the supervisory board had EY prepare an expert opinion, which saw no need for corrections; the outcome of that action is not in the record."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-788299b0d0b6e293d9611ce5","record":{"id":"display-claim-788299b0d0b6e293d9611ce5","kind":"analysis","text":"EY issued unqualified opinions on the 2011 accounts, signed in Munich on 16 April 2012, and on the 2016 accounts, which the supervisory board approved on 5 April 2017. The Finance Ministry's report to the Bundestag finance committee of July 2020 states that the company and the group presented accounts for every year from 2009 to 2018 with EY's unqualified opinion, that none of the audits led to objections and that the 2018 opinion discussed the Singapore whistleblower allegations. The 2018 opinion was signed by Martin Dahmen, responsible auditor from 2018 who had first signed for 2016, and by Andreas Budde; EY's fees were EUR 2.3 million for 2018 and EUR 2.2 million for 2017. According to FREP information in ESMA's report, EY set its materiality limit at EUR 20 million for 2018 and EUR 28.7 million for 2019.","source_ids":["src-010","src-032","src-050","src-069","src-005","src-087"],"entity_ids":["ey","wirecard","bmf","dpr","esma"],"premise_claim_ids":["c-aud-opinions-2011-2016","c-aud-unqualified-2009-2018","c-aud-2018-signatories","c-aud-materiality"],"qualification":"","response":"","outcome":""},"reading":"Analysis: EY issued unqualified opinions on the 2011 accounts, signed in Munich on 16 April 2012, and on the 2016 accounts, which the supervisory board approved on 5 April 2017. The Finance Ministry's report to the Bundestag finance committee of July 2020 states that the company and the group presented accounts for every year from 2009 to 2018 with EY's unqualified opinion, that none of the audits led to objections and that the 2018 opinion discussed the Singapore whistleblower allegations. The 2018 opinion was signed by Martin Dahmen, responsible auditor from 2018 who had first signed for 2016, and by Andreas Budde; EY's fees were EUR 2.3 million for 2018 and EUR 2.2 million for 2017. According to FREP information in ESMA's report, EY set its materiality limit at EUR 20 million for 2018 and EUR 28.7 million for 2019."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-63d5c7ce84fa7535cea87018","record":{"id":"display-claim-63d5c7ce84fa7535cea87018","kind":"analysis","text":"The special investigators found that EY had the chief financial officer Burkhard Ley and the executive vice president accounting Stephan von Erffa confirm by signature, in a \"concurrence memorandum\" of 3 March 2016, EY's understanding of Wirecard's role in the business. The memorandum was prepared by an EY senior manager, approved the same day by a partner and signed by ten EY auditors including the quality-control partner; it recorded that no receivable from Al Alam, PayEasy or Rising Sun had gone unpaid in 2011–2013 and that management saw no liability risks in 2014. The working papers contain no contracts between the partners and the merchants or banks to support what management described, and the auditor did not consider whether the extensive collateral Wirecard gave the partners was usual in the market.","source_ids":["src-027"],"entity_ids":["ey","ley","von-erffa","wirecard","al-alam","payeasy","senjo"],"premise_claim_ids":["c-aud-rp-concurrence","c-aud-rp-concurrence-signers"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The special investigators found that EY had the chief financial officer Burkhard Ley and the executive vice president accounting Stephan von Erffa confirm by signature, in a \"concurrence memorandum\" of 3 March 2016, EY's understanding of Wirecard's role in the business. The memorandum was prepared by an EY senior manager, approved the same day by a partner and signed by ten EY auditors including the quality-control partner; it recorded that no receivable from Al Alam, PayEasy or Rising Sun had gone unpaid in 2011–2013 and that management saw no liability risks in 2014. The working papers contain no contracts between the partners and the merchants or banks to support what management described, and the auditor did not consider whether the extensive collateral Wirecard gave the partners was usual in the market."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-a09c4a937ff77ffedd9c5dc7","record":{"id":"display-claim-a09c4a937ff77ffedd9c5dc7","kind":"analysis","text":"EY's 2015 working papers first classified the escrow accounts as restricted cash and then, in a memorandum, reclassified them as cash on the argument that Wirecard could replace them with a bank guarantee obtainable within three months with the partners' agreement; the investigators found no evidence that such a guarantee existed or could be obtained. In the 2015–2016 audits EY listed external fraud risk factors such as capital-market pressure, share-price-linked pay, EBIT covenants and money laundering at Wirecard Bank, but in the investigators' evaluation did not include the standard risk of management override, documented no analysis of fraud indicators under IDW PS 210 and did not assess whether the partners were service providers whose internal controls needed testing, although it obtained such reports for Wirecard Bank's provider SIX Payment Services.","source_ids":["src-027"],"entity_ids":["ey","wirecard","wd-bank","six"],"premise_claim_ids":["c-aud-rp-escrow-cash","c-aud-rp-fraud-risk"],"qualification":"","response":"","outcome":""},"reading":"Analysis: EY's 2015 working papers first classified the escrow accounts as restricted cash and then, in a memorandum, reclassified them as cash on the argument that Wirecard could replace them with a bank guarantee obtainable within three months with the partners' agreement; the investigators found no evidence that such a guarantee existed or could be obtained. In the 2015–2016 audits EY listed external fraud risk factors such as capital-market pressure, share-price-linked pay, EBIT covenants and money laundering at Wirecard Bank, but in the investigators' evaluation did not include the standard risk of management override, documented no analysis of fraud indicators under IDW PS 210 and did not assess whether the partners were service providers whose internal controls needed testing, although it obtained such reports for Wirecard Bank's provider SIX Payment Services."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-aa3abbe96072684e5112e01d","record":{"id":"display-claim-aa3abbe96072684e5112e01d","kind":"analysis","text":"Overdue trade receivables stood at EUR 55.3 million at the end of 2016 before allowances, against total trade receivables of about EUR 190 million after allowances; the investigators note that the ageing analysis required by IFRS 7.37a was not disclosed in the 2016 notes and that EY considered the omission immaterial. In their view the business bore the features of a measure designed to shape the balance sheet within the meaning of section 321(2) of the Commercial Code, yet EY's long-form report on the 2015 consolidated accounts contains no explicit section on it, only partial descriptions, a remark on the high volume of unsecured receivables from the partners and Wirecard's intention to monitor them more closely. EY's position on this evaluation is not in the record.","source_ids":["src-027"],"entity_ids":["wirecard","ey"],"premise_claim_ids":["c-aud-rp-receivables","c-aud-rp-2015-report"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Overdue trade receivables stood at EUR 55.3 million at the end of 2016 before allowances, against total trade receivables of about EUR 190 million after allowances; the investigators note that the ageing analysis required by IFRS 7.37a was not disclosed in the 2016 notes and that EY considered the omission immaterial. In their view the business bore the features of a measure designed to shape the balance sheet within the meaning of section 321(2) of the Commercial Code, yet EY's long-form report on the 2015 consolidated accounts contains no explicit section on it, only partial descriptions, a remark on the high volume of unsecured receivables from the partners and Wirecard's intention to monitor them more closely. EY's position on this evaluation is not in the record."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-847253d3980dd8c3b1276523","record":{"id":"display-claim-847253d3980dd8c3b1276523","kind":"analysis","text":"For 2018 EY named the valuation of receivables and the recognition of revenue from acquiring partners as a key audit matter: the receivables arose from fees and commissions on transactions processed through the partners and from prefinancing of merchant payouts, and Wirecard was treated as principal under IFRS 15, so revenue was shown gross. EY states that it obtained confirmations from the partners, traced their payments, reconciled their settlements with transaction data and had no objections. An emphasis-of-matter paragraph addressed the Singapore whistleblower's allegations and claims for damages over allegedly incorrect or late disclosures; EY states that it compared the findings with work by independent third parties and the internal compliance department, interviewed managers, suppliers, customers and lawyers with its own forensic specialists, and again had no objections.","source_ids":["src-005"],"entity_ids":["ey","wirecard"],"premise_claim_ids":["c-aud-2018-kam","c-aud-2018-emphasis"],"qualification":"","response":"","outcome":""},"reading":"Analysis: For 2018 EY named the valuation of receivables and the recognition of revenue from acquiring partners as a key audit matter: the receivables arose from fees and commissions on transactions processed through the partners and from prefinancing of merchant payouts, and Wirecard was treated as principal under IFRS 15, so revenue was shown gross. EY states that it obtained confirmations from the partners, traced their payments, reconciled their settlements with transaction data and had no objections. An emphasis-of-matter paragraph addressed the Singapore whistleblower's allegations and claims for damages over allegedly incorrect or late disclosures; EY states that it compared the findings with work by independent third parties and the internal compliance department, interviewed managers, suppliers, customers and lawyers with its own forensic specialists, and again had no objections."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-541ded527bd336cb85ab6680","record":{"id":"display-claim-541ded527bd336cb85ab6680","kind":"analysis","text":"According to the special investigators, Wirecard had known since March–April 2018 of the whistleblower information the Financial Times published on 30 January 2019 and had engaged Rajah & Tann, then Fieldfisher, which brought in Control Risks. From February 2019 EY's forensic department joined the audit, identified more than 20 issues from the allegations and kept a file \"Wirecard AG Project Tiger 2018\" of more than 1,100 documents. The significance of the emphasis of matter was not discussed with the boards; the meeting to approve the accounts on 24 April 2019 was interrupted at 6 p.m. because of a new Financial Times article, which the auditor discussed with the supervisory board's lawyers, the supervisory board and Markus Braun before concluding that it changed nothing in the opinion.","source_ids":["src-027"],"entity_ids":["wirecard","rajah-tann","fieldfisher","control-risks","ey","ft","braun"],"premise_claim_ids":["c-aud-rp-2018-audit","c-aud-rp-2018-meeting"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to the special investigators, Wirecard had known since March–April 2018 of the whistleblower information the Financial Times published on 30 January 2019 and had engaged Rajah & Tann, then Fieldfisher, which brought in Control Risks. From February 2019 EY's forensic department joined the audit, identified more than 20 issues from the allegations and kept a file \"Wirecard AG Project Tiger 2018\" of more than 1,100 documents. The significance of the emphasis of matter was not discussed with the boards; the meeting to approve the accounts on 24 April 2019 was interrupted at 6 p.m. because of a new Financial Times article, which the auditor discussed with the supervisory board's lawyers, the supervisory board and Markus Braun before concluding that it changed nothing in the opinion."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-771cf7b78cde382a9bb1c558","record":{"id":"display-claim-771cf7b78cde382a9bb1c558","kind":"analysis","text":"The Federal Court of Justice records that Wirecard's auditor since 2009, which also audited Wirecard Technologies GmbH from 2014 to 2019, issued unqualified opinions on both companies' accounts for 2014–2018 and refused an opinion for 2019; Wirecard Technologies filed for insolvency on 1 July 2020. When FREP concluded on 20 July 2020 that the 2018 accounts were erroneous, it notified the auditor oversight body of a possible breach of professional requirements by EY and on 22 July sent it KPMG's full report.","source_ids":["src-057","src-087"],"entity_ids":["ey","wirecard","wd-tech","bgh","dpr","apas","kpmg","esma"],"premise_claim_ids":["c-aud-2019-refusal","c-aud-frep-aob"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The Federal Court of Justice records that Wirecard's auditor since 2009, which also audited Wirecard Technologies GmbH from 2014 to 2019, issued unqualified opinions on both companies' accounts for 2014–2018 and refused an opinion for 2019; Wirecard Technologies filed for insolvency on 1 July 2020. When FREP concluded on 20 July 2020 that the 2018 accounts were erroneous, it notified the auditor oversight body of a possible breach of professional requirements by EY and on 22 July sent it KPMG's full report."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-1e4c9be29877306ed4f9f7e5","record":{"id":"display-claim-1e4c9be29877306ed4f9f7e5","kind":"analysis","text":"The special investigators concluded on 16 April 2021 that there were indications that EY had not fully applied the IDW standards in planning and performing the audit, that a systematic analysis of fraud indicators could have led to greater professional scepticism and further procedures on the business, and that the audit evidence often consisted of internal documents and oral statements by the management board rather than third-party confirmations; they gave no overall assessment of whether the audit was properly performed, and their conclusion is not a disciplinary or court finding. EY had said in June 2020, as quoted from a news agency in a European Parliament briefing, that there were clear indications of an elaborate and sophisticated fraud involving multiple parties around the world in different institutions with a deliberate aim of deception. The auditor oversight body later found breaches of professional duties in the 2016–2018 audits, and the Federal Court of Justice largely upheld the administrator's claims to the working files, as set out below.","source_ids":["src-027","src-025","src-030","src-057"],"entity_ids":["ey","wirecard","bundestag"],"premise_claim_ids":["c-aud-rp-conclusion"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The special investigators concluded on 16 April 2021 that there were indications that EY had not fully applied the IDW standards in planning and performing the audit, that a systematic analysis of fraud indicators could have led to greater professional scepticism and further procedures on the business, and that the audit evidence often consisted of internal documents and oral statements by the management board rather than third-party confirmations; they gave no overall assessment of whether the audit was properly performed, and their conclusion is not a disciplinary or court finding. EY had said in June 2020, as quoted from a news agency in a European Parliament briefing, that there were clear indications of an elaborate and sophisticated fraud involving multiple parties around the world in different institutions with a deliberate aim of deception. The auditor oversight body later found breaches of professional duties in the 2016–2018 audits, and the Federal Court of Justice largely upheld the administrator's claims to the working files, as set out below."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-e04c1683496b2a5a568885d1","record":{"id":"display-claim-e04c1683496b2a5a568885d1","kind":"analysis","text":"Germany's auditor oversight body APAS announced on 3 April 2023 that its decision chamber had found on 31 March 2023 that professional duties were breached in the audits of Wirecard AG and Wirecard Bank AG for 2016 to 2018, and imposed sanctions on the audit firm and five auditors, while proceedings against seven others ended because they gave up their auditor status. The fines ranged from EUR 23,000 to EUR 300,000 for individuals and were EUR 500,000 for the firm, which was also barred for two years from accepting new statutory audits of public-interest entities; no breaches were found for 2019. The announcement does not name the firm, which was Wirecard's auditor, EY. On 11 December 2025 the Federal Court of Justice upheld claims of the insolvency administrator of Wirecard AG and Wirecard Technologies against the audit firm for information about and access to its working files for 2016 to 2019, including the 2016 consolidated audit and the \"Projekt Ring\" special investigation; claims concerning 2014 and 2015 were time-barred.","source_ids":["src-030","src-057"],"entity_ids":["apas","wirecard","wd-bank","ey","bgh","jaffe","wd-tech"],"premise_claim_ids":["c-aud-apas","c-aud-bgh-files"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Germany's auditor oversight body APAS announced on 3 April 2023 that its decision chamber had found on 31 March 2023 that professional duties were breached in the audits of Wirecard AG and Wirecard Bank AG for 2016 to 2018, and imposed sanctions on the audit firm and five auditors, while proceedings against seven others ended because they gave up their auditor status. The fines ranged from EUR 23,000 to EUR 300,000 for individuals and were EUR 500,000 for the firm, which was also barred for two years from accepting new statutory audits of public-interest entities; no breaches were found for 2019. The announcement does not name the firm, which was Wirecard's auditor, EY. On 11 December 2025 the Federal Court of Justice upheld claims of the insolvency administrator of Wirecard AG and Wirecard Technologies against the audit firm for information about and access to its working files for 2016 to 2019, including the 2016 consolidated audit and the \"Projekt Ring\" special investigation; claims concerning 2014 and 2015 were time-barred."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-ad33bd19e2daf3ede262c6c8","record":{"id":"display-claim-ad33bd19e2daf3ede262c6c8","kind":"analysis","text":"According to the Finance Ministry's report of 16 July 2020 to the Bundestag finance committee, Wirecard AG itself provided no banking or payment services and was not supervised by BaFin as a credit, payment or e-money institution, nor classified as a financial holding company; BaFin supervised only Wirecard Bank AG, and the UK Financial Conduct Authority supervised the British subsidiary Wirecard Card Solutions. ESMA records that on 1 February 2017 BaFin's banking supervision and the Bundesbank concluded that Wirecard was not a financial holding company under EU law, so that supervisors had no powers over the group as a whole, and that the ECB later agreed. Anti-money- laundering supervision of Wirecard AG was unresolved: the Lower Bavaria district government approached BaFin as the competent authority in February and May 2020, Wirecard regarded itself as a \"financial undertaking\" supervised by Bavaria, and in July 2020 the Bavarian interior minister said he did not regard the district government as competent.","source_ids":["src-069","src-087"],"entity_ids":["wirecard","bafin","wd-bank","wd-card-solutions","fca","bmf","esma"],"premise_claim_ids":["c-sup-scope","c-sup-holding","c-sup-aml-gap"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to the Finance Ministry's report of 16 July 2020 to the Bundestag finance committee, Wirecard AG itself provided no banking or payment services and was not supervised by BaFin as a credit, payment or e-money institution, nor classified as a financial holding company; BaFin supervised only Wirecard Bank AG, and the UK Financial Conduct Authority supervised the British subsidiary Wirecard Card Solutions. ESMA records that on 1 February 2017 BaFin's banking supervision and the Bundesbank concluded that Wirecard was not a financial holding company under EU law, so that supervisors had no powers over the group as a whole, and that the ECB later agreed. Anti-money- laundering supervision of Wirecard AG was unresolved: the Lower Bavaria district government approached BaFin as the competent authority in February and May 2020, Wirecard regarded itself as a \"financial undertaking\" supervised by Bavaria, and in July 2020 the Bavarian interior minister said he did not regard the district government as competent."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-f796b26d3ed1c1297a7ec8c8","record":{"id":"display-claim-f796b26d3ed1c1297a7ec8c8","kind":"analysis","text":"BaFin investigated market participants betting on falls in Wirecard's share price: after the Zatarra report (from 21 March 2016, with a criminal complaint to the Munich prosecutor on 12 May 2016), after a report by the short-seller SIRF (18 February to 24 May 2018) and after Financial Times publications (from 1 February 2019, with a complaint on 10 April 2019). ESMA records that in February 2019 BaFin filed a complaint against market participants and two journalists on suspicion of market manipulation, and that month BaFin imposed a temporary ban on short selling of Wirecard shares with ESMA's positive opinion, which Wirecard's prospectus presented as a response to several short-selling attacks. In March 2019 Wirecard sued the Financial Times and its journalist in the Munich regional court over the use and misrepresentation of trade secrets; according to the company's prospectus, the Munich prosecutor was investigating the journalist Dan McCrum for market manipulation. The action was interrupted by Wirecard's insolvency in September 2020 and withdrawn on 28 October 2020.","source_ids":["src-069","src-087","src-012","src-025"],"entity_ids":["bafin","wirecard","sta-muenchen","ft","esma","bmf","europarl","mccrum"],"premise_claim_ids":["c-sup-market-manipulation-probes","c-sup-short-ban","c-sup-ft-suit-2019"],"qualification":"","response":"","outcome":""},"reading":"Analysis: BaFin investigated market participants betting on falls in Wirecard's share price: after the Zatarra report (from 21 March 2016, with a criminal complaint to the Munich prosecutor on 12 May 2016), after a report by the short-seller SIRF (18 February to 24 May 2018) and after Financial Times publications (from 1 February 2019, with a complaint on 10 April 2019). ESMA records that in February 2019 BaFin filed a complaint against market participants and two journalists on suspicion of market manipulation, and that month BaFin imposed a temporary ban on short selling of Wirecard shares with ESMA's positive opinion, which Wirecard's prospectus presented as a response to several short-selling attacks. In March 2019 Wirecard sued the Financial Times and its journalist in the Munich regional court over the use and misrepresentation of trade secrets; according to the company's prospectus, the Munich prosecutor was investigating the journalist Dan McCrum for market manipulation. The action was interrupted by Wirecard's insolvency in September 2020 and withdrawn on 28 October 2020."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-7cb51e6628e3e8caf2e8ca0f","record":{"id":"display-claim-7cb51e6628e3e8caf2e8ca0f","kind":"analysis","text":"On 15 April 2019 BaFin fined Wirecard AG EUR 1.52 million for breaches of financial reporting obligations, partly for late publication of the 2018 half-year report and the related notice; Wirecard accepted the fine but contested its publication, which followed a decision of the Hessian administrative court in September 2019. ESMA found that BaFin sent the Finance Ministry at least 17 reports on Wirecard between 2016 and 2020 on its market-abuse examinations and transparency proceedings. State Secretary Dr. Jörg Kukies met Markus Braun on 5 November 2019 without minutes being taken; according to the ministry the topics included the suspicion of market manipulation and the KPMG special audit that had begun.","source_ids":["src-069","src-087"],"entity_ids":["bafin","wirecard","bmf","esma","braun","kpmg"],"premise_claim_ids":["c-sup-fine-2019","c-sup-mof-reports","c-sup-kukies"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 15 April 2019 BaFin fined Wirecard AG EUR 1.52 million for breaches of financial reporting obligations, partly for late publication of the 2018 half-year report and the related notice; Wirecard accepted the fine but contested its publication, which followed a decision of the Hessian administrative court in September 2019. ESMA found that BaFin sent the Finance Ministry at least 17 reports on Wirecard between 2016 and 2020 on its market-abuse examinations and transparency proceedings. State Secretary Dr. Jörg Kukies met Markus Braun on 5 November 2019 without minutes being taken; according to the ministry the topics included the suspicion of market manipulation and the KPMG special audit that had begun."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-8bc9af876851e708f3052b41","record":{"id":"display-claim-8bc9af876851e708f3052b41","kind":"analysis","text":"ESMA records that in 15 years FREP fully examined Wirecard's accounts four times (2005, 2011 and 2014 by sample, 2018 on risk grounds) and found an error in the 2005 accounts. In 2008 it began examining the 2007 accounts after public allegations by the head of a German shareholders' association, suspended the examination because of an action to annul those accounts, which the Munich regional court rejected, and ended it in June 2012 for lack of public interest; the examination of the 2011 accounts found no errors. FREP selected the 2014 annual report by random sampling on 15 December 2014 and closed the examination without findings on 1 December 2016; ESMA rated it only partially compliant, citing serious shortcomings, unaddressed material risks, insufficient scepticism and a duration of 19.5 months against an average of eight. The 2015 accounts were not examined, and from 2015 to 2018 Wirecard was not selected on concrete risk grounds.","source_ids":["src-087"],"entity_ids":["dpr","wirecard","esma"],"premise_claim_ids":["c-sup-frep-history","c-sup-frep-2014"],"qualification":"","response":"","outcome":""},"reading":"Analysis: ESMA records that in 15 years FREP fully examined Wirecard's accounts four times (2005, 2011 and 2014 by sample, 2018 on risk grounds) and found an error in the 2005 accounts. In 2008 it began examining the 2007 accounts after public allegations by the head of a German shareholders' association, suspended the examination because of an action to annul those accounts, which the Munich regional court rejected, and ended it in June 2012 for lack of public interest; the examination of the 2011 accounts found no errors. FREP selected the 2014 annual report by random sampling on 15 December 2014 and closed the examination without findings on 1 December 2016; ESMA rated it only partially compliant, citing serious shortcomings, unaddressed material risks, insufficient scepticism and a duration of 19.5 months against an average of eight. The 2015 accounts were not examined, and from 2015 to 2018 Wirecard was not selected on concrete risk grounds."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-0a9f8227abbdf2ae4f874eb4","record":{"id":"display-claim-0a9f8227abbdf2ae4f874eb4","kind":"analysis","text":"BaFin learned of the Zatarra report in February 2016 and in April asked FREP to include Wirecard in its risk group. On 29 September 2016 a whistleblower told FREP that the acquiring receivables and payables in the 2015 balance sheet were doubtful, which FREP's committee considered evidently unfounded; at a working meeting on 11 October 2016 EY confirmed it had looked into the Zatarra allegations and the related Financial Times reports, and FREP considered the matter resolved because the 2015 accounts carried a clean opinion, which ESMA criticised as reliance solely on the auditor. On 1 December 2016 Wirecard gave FREP a one-page interim report by an external party, without addressee or signature, and FREP closed its examination the same day. On 28 February 2017 FREP's committee decided that a magazine article about a \"EUR 250 million puzzle\" gave no sufficiently concrete indications of accounting breaches, although rolling security reserve receivables of EUR 250 million remained unexplained, and BaFin concluded on 15 March 2017 that a lack of clarity was not a breach, a view ESMA strongly disagreed with. ESMA's review also records that Wirecard published its 2015 accounts with an unqualified opinion on 6 April 2016, the day a Financial Times article again questioned its Indian acquisition.","source_ids":["src-087"],"entity_ids":["bafin","dpr","wirecard","esma","ey","ft"],"premise_claim_ids":["c-sup-frep-whistleblower","c-sup-frep-ey-2016","c-sup-frep-250m","c-sup-esma-disclosure"],"qualification":"","response":"","outcome":""},"reading":"Analysis: BaFin learned of the Zatarra report in February 2016 and in April asked FREP to include Wirecard in its risk group. On 29 September 2016 a whistleblower told FREP that the acquiring receivables and payables in the 2015 balance sheet were doubtful, which FREP's committee considered evidently unfounded; at a working meeting on 11 October 2016 EY confirmed it had looked into the Zatarra allegations and the related Financial Times reports, and FREP considered the matter resolved because the 2015 accounts carried a clean opinion, which ESMA criticised as reliance solely on the auditor. On 1 December 2016 Wirecard gave FREP a one-page interim report by an external party, without addressee or signature, and FREP closed its examination the same day. On 28 February 2017 FREP's committee decided that a magazine article about a \"EUR 250 million puzzle\" gave no sufficiently concrete indications of accounting breaches, although rolling security reserve receivables of EUR 250 million remained unexplained, and BaFin concluded on 15 March 2017 that a lack of clarity was not a breach, a view ESMA strongly disagreed with. ESMA's review also records that Wirecard published its 2015 accounts with an unqualified opinion on 6 April 2016, the day a Financial Times article again questioned its Indian acquisition."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-10826dac657f0d3243c855db","record":{"id":"display-claim-10826dac657f0d3243c855db","kind":"analysis","text":"In 2019 FREP placed Wirecard in an abstract risk pool because of unusual transactions, above-average growth, sector risks and weak governance, signs that ESMA notes had been visible earlier. BaFin required FREP to examine the condensed half-year accounts at 30 June 2018 on 15 February 2019, and on 30 October 2019 FREP, in agreement with BaFin, extended its examination to the amount and existence of TPA revenue, the classification of escrow accounts as cash and a possible \"Indian round-tripping\", deciding to await KPMG's results. In early 2019 BaFin received the preliminary Rajah & Tann report from an anonymous whistleblower but, citing professional secrecy, did not pass it to FREP, which obtained it from Wirecard in mid-2019; BaFin's market-abuse and financial-reporting teams said they were unaware of the Financial Times articles of early 2019 on the partners. Wirecard did not release EY or KPMG from confidentiality towards FREP, and supplied the KPMG contract requested in mid-December 2019 only at the end of January 2020. On 10 December 2019 it published a statement on how it processed and accounted for payments via routing partners, which ESMA's review committee considered could have been more detailed and transparent.","source_ids":["src-087","src-069"],"entity_ids":["dpr","bafin","wirecard","esma","kpmg","bmf","rajah-tann","ft","ey"],"premise_claim_ids":["c-sup-frep-2019","c-sup-bafin-requests","c-sup-frep-ft-unaware","c-sup-frep-no-access","c-sup-esma-disclosure"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In 2019 FREP placed Wirecard in an abstract risk pool because of unusual transactions, above-average growth, sector risks and weak governance, signs that ESMA notes had been visible earlier. BaFin required FREP to examine the condensed half-year accounts at 30 June 2018 on 15 February 2019, and on 30 October 2019 FREP, in agreement with BaFin, extended its examination to the amount and existence of TPA revenue, the classification of escrow accounts as cash and a possible \"Indian round-tripping\", deciding to await KPMG's results. In early 2019 BaFin received the preliminary Rajah & Tann report from an anonymous whistleblower but, citing professional secrecy, did not pass it to FREP, which obtained it from Wirecard in mid-2019; BaFin's market-abuse and financial-reporting teams said they were unaware of the Financial Times articles of early 2019 on the partners. Wirecard did not release EY or KPMG from confidentiality towards FREP, and supplied the KPMG contract requested in mid-December 2019 only at the end of January 2020. On 10 December 2019 it published a statement on how it processed and accounted for payments via routing partners, which ESMA's review committee considered could have been more detailed and transparent."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-39e60dcd0d96fe2f495872cf","record":{"id":"display-claim-39e60dcd0d96fe2f495872cf","kind":"analysis","text":"On 30 April 2020 BaFin required FREP to examine the 2018 consolidated accounts, expressly citing KPMG's report as concrete indications of material breaches concerning TPA revenue, the presentation of the escrow accounts and the reporting of TPA risks; it added the half-year accounts at 30 June 2019 on 24 June and the 2017 accounts on 25 June 2020. On 17 June 2020 FREP received from BaFin the auditor's report on possibly incorrect balance confirmations, and on 29 June Wirecard's management board told FREP that the reliability of earlier information, especially on \"third-party transactions\", was in doubt. FREP finalised on 6 July 2020 its findings that the 2018 half-year and annual reports were erroneous, concluding that significant assets, revenue and expenses had not been properly accounted for; Wirecard disagreed and refused to take part in the examinations of the 2017 accounts and the first half of 2019; FREP ended its examinations on 20 July and BaFin took them over on 24 July 2020. On 4 August 2020 BaFin for the first time published notice of such examinations in the Federal Gazette.","source_ids":["src-069","src-087"],"entity_ids":["bafin","dpr","wirecard","kpmg","esma","bmf","ey"],"premise_claim_ids":["c-sup-bafin-requests","c-sup-frep-2020","c-sup-frep-error","c-sup-bundesanzeiger"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 30 April 2020 BaFin required FREP to examine the 2018 consolidated accounts, expressly citing KPMG's report as concrete indications of material breaches concerning TPA revenue, the presentation of the escrow accounts and the reporting of TPA risks; it added the half-year accounts at 30 June 2019 on 24 June and the 2017 accounts on 25 June 2020. On 17 June 2020 FREP received from BaFin the auditor's report on possibly incorrect balance confirmations, and on 29 June Wirecard's management board told FREP that the reliability of earlier information, especially on \"third-party transactions\", was in doubt. FREP finalised on 6 July 2020 its findings that the 2018 half-year and annual reports were erroneous, concluding that significant assets, revenue and expenses had not been properly accounted for; Wirecard disagreed and refused to take part in the examinations of the 2017 accounts and the first half of 2019; FREP ended its examinations on 20 July and BaFin took them over on 24 July 2020. On 4 August 2020 BaFin for the first time published notice of such examinations in the Federal Gazette."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-94f311d448c5267e0a4d6713","record":{"id":"display-claim-94f311d448c5267e0a4d6713","kind":"analysis","text":"On 2 June 2020 BaFin filed a criminal complaint against Wirecard with the Munich prosecutor for market manipulation through misleading ad hoc announcements on the interim results of KPMG's special investigation, on the basis of which the prosecutor searched Wirecard's premises on 5 June. On 18 June it filed a further complaint on suspicion of misrepresentation and market manipulation through false information in the 2016–2018 accounts, and on 20 June opened a market-abuse analysis of recent ad hoc announcements. On 3 June it had opened a market-abuse analysis of purchases of Wirecard shares by Braun through MB Beteiligungsgesellschaft, having reported to the Finance Ministry on his share transactions on 29 May; ESMA records that on 29 April BaFin had opened a market-manipulation examination of Wirecard's statements that KPMG had found nothing material. On 22 June 2020 BaFin required Wirecard Bank to report its liquidity daily, appointed a special representative to oversee all significant payments with group companies, placed the bank under special observation and asked foreign supervisors for assistance.","source_ids":["src-069","src-087"],"entity_ids":["bafin","wirecard","sta-muenchen","kpmg","esma","braun","mb-beteiligung","bmf","wd-bank"],"premise_claim_ids":["c-sup-2020-complaints","c-sup-braun-shares","c-sup-bank-measures-2020"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 2 June 2020 BaFin filed a criminal complaint against Wirecard with the Munich prosecutor for market manipulation through misleading ad hoc announcements on the interim results of KPMG's special investigation, on the basis of which the prosecutor searched Wirecard's premises on 5 June. On 18 June it filed a further complaint on suspicion of misrepresentation and market manipulation through false information in the 2016–2018 accounts, and on 20 June opened a market-abuse analysis of recent ad hoc announcements. On 3 June it had opened a market-abuse analysis of purchases of Wirecard shares by Braun through MB Beteiligungsgesellschaft, having reported to the Finance Ministry on his share transactions on 29 May; ESMA records that on 29 April BaFin had opened a market-manipulation examination of Wirecard's statements that KPMG had found nothing material. On 22 June 2020 BaFin required Wirecard Bank to report its liquidity daily, appointed a special representative to oversee all significant payments with group companies, placed the bank under special observation and asked foreign supervisors for assistance."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-23633ca38d092e5398746989","record":{"id":"display-claim-23633ca38d092e5398746989","kind":"analysis","text":"On 25 June 2020 the European Commission asked ESMA to analyse the events leading to Wirecard's collapse and the German supervisors' response; ESMA launched a fast-track peer review of BaFin and FREP and approved its mandate on 25 August 2020. The review, covering 1 January 2015 to 25 August 2020 and published on 3 November 2020, found a heightened risk of Finance Ministry influence on BaFin because of the frequency and detail of its reporting, that BaFin had no information on staff shareholdings and that some staff in its market-abuse team had traded Wirecard shares, and that FREP did not select the 2015–2017 accounts for examination nor did BaFin request it.","source_ids":["src-087"],"entity_ids":["esma","bafin","dpr","wirecard","bmf"],"premise_claim_ids":["c-sup-esma-mandate","c-sup-esma-findings"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 25 June 2020 the European Commission asked ESMA to analyse the events leading to Wirecard's collapse and the German supervisors' response; ESMA launched a fast-track peer review of BaFin and FREP and approved its mandate on 25 August 2020. The review, covering 1 January 2015 to 25 August 2020 and published on 3 November 2020, found a heightened risk of Finance Ministry influence on BaFin because of the frequency and detail of its reporting, that BaFin had no information on staff shareholdings and that some staff in its market-abuse team had traded Wirecard shares, and that FREP did not select the 2015–2017 accounts for examination nor did BaFin request it."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-f150810790f6c3211f08d813","record":{"id":"display-claim-f150810790f6c3211f08d813","kind":"analysis","text":"ESMA's report summarises the public allegations: FT Alphaville blog posts in 2015 raised the first doubts about the accounting for the partners; a whistleblower raised concerns with FREP in 2016 about acquiring receivables at subsidiaries in jurisdictions without a licence; in early 2016 Zatarra accused Wirecard of money laundering, mainly on information from 2006–2010, of facilitating circumvention of US online-gambling restrictions, of deceiving Visa and Mastercard on customer checks and of overpaying for acquisitions; and in June 2019 the Financial Times reported that a long-standing customer had settled US allegations of defrauding customers of more than USD 110 million. Wirecard systematically rejected these allegations at the time. Allegations were not new: the supervisory board's report for 2010 records that in April 2010 it discussed allegations against the group published, among other places, on the gomoPa website, and the necessary countermeasures, without describing them.","source_ids":["src-087","src-023"],"entity_ids":["esma","wirecard","ft","dpr","gomopa"],"premise_claim_ids":["c-sup-esma-allegations","c-sup-gomopa-2010"],"qualification":"","response":"","outcome":""},"reading":"Analysis: ESMA's report summarises the public allegations: FT Alphaville blog posts in 2015 raised the first doubts about the accounting for the partners; a whistleblower raised concerns with FREP in 2016 about acquiring receivables at subsidiaries in jurisdictions without a licence; in early 2016 Zatarra accused Wirecard of money laundering, mainly on information from 2006–2010, of facilitating circumvention of US online-gambling restrictions, of deceiving Visa and Mastercard on customer checks and of overpaying for acquisitions; and in June 2019 the Financial Times reported that a long-standing customer had settled US allegations of defrauding customers of more than USD 110 million. Wirecard systematically rejected these allegations at the time. Allegations were not new: the supervisory board's report for 2010 records that in April 2010 it discussed allegations against the group published, among other places, on the gomoPa website, and the necessary countermeasures, without describing them."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-70ad5e02fa20663fd5916959","record":{"id":"display-claim-70ad5e02fa20663fd5916959","kind":"analysis","text":"On 26 June 2020 the UK Financial Conduct Authority required Wirecard's British e-money firm not to dispose of assets or funds or carry on regulated activities, citing events around the parent company, which it did not supervise; after it allowed e-money activity to resume on 29 June, restrictions on where customer funds could be held and on transfers of the firm's own assets remained. Wirecard reported that the lifting of the restrictions on 30 June reopened several hundred thousand accounts, and Estonia's e-Residency programme reported that the firm's Holvi and Payoneer Mastercard cards were frozen and later partly restored. The Monetary Authority of Singapore lists Wirecard Asia Holding Pte. Ltd. and Wirecard Singapore Pte. Ltd. among entities that previously held a temporary exemption from licensing under the Payment Services Act but no longer do. Ireland's audit supervisor IAASA concluded settlements with the auditors of Wirecard UK and Ireland's financial statements: severe reprimands and fines of EUR 19,500 for Tony Kelly and EUR 10,500 for Alison Gray.","source_ids":["src-068","src-025","src-048","src-088","src-077","src-070"],"entity_ids":["fca","wd-card-solutions","wirecard","holvi","payoneer","mas","wd-asia-holding","wd-singapore","iaasa","wd-uki","kelly","gray"],"premise_claim_ids":["c-sup-fca","c-sup-fca-cards","c-sup-mas","c-aud-iaasa"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 26 June 2020 the UK Financial Conduct Authority required Wirecard's British e-money firm not to dispose of assets or funds or carry on regulated activities, citing events around the parent company, which it did not supervise; after it allowed e-money activity to resume on 29 June, restrictions on where customer funds could be held and on transfers of the firm's own assets remained. Wirecard reported that the lifting of the restrictions on 30 June reopened several hundred thousand accounts, and Estonia's e-Residency programme reported that the firm's Holvi and Payoneer Mastercard cards were frozen and later partly restored. The Monetary Authority of Singapore lists Wirecard Asia Holding Pte. Ltd. and Wirecard Singapore Pte. Ltd. among entities that previously held a temporary exemption from licensing under the Payment Services Act but no longer do. Ireland's audit supervisor IAASA concluded settlements with the auditors of Wirecard UK and Ireland's financial statements: severe reprimands and fines of EUR 19,500 for Tony Kelly and EUR 10,500 for Alison Gray."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-65481cbd58685b290b3812cd","record":{"id":"display-claim-65481cbd58685b290b3812cd","kind":"analysis","text":"On 27 October 2015 Wirecard AG signed agreements to acquire the payment business of the Great Indian (GI) Retail Group: all of Hermes I Tickets Pte. Ltd., GI Philippines Corp. and Star Global Currency Exchange Pte. Ltd. and 60% of GI Technology Private Limited, for EUR 230 million in cash plus up to EUR 110 million depending on 2015–2017 results. It consolidated the three wholly owned companies from 30 December 2015 because a trust arrangement already gave it control, and acquired GI Technology at 60% from 1 March 2016. ESMA, summarising press reports, states that the key assets had been valued at EUR 46 million a year earlier and that a fund, EMIF1A, had paid USD 37 million for Hermes only six weeks before bundling it into the transaction; according to a magazine cited by ESMA the price of up to EUR 340 million was 49 times pre-tax earnings, and FREP told ESMA it included a EUR 110 million earn-out. Wirecard disputed critical reporting at the time, and no court has ruled on the price. Former minority shareholders of Hermes later sued their former co-shareholders and Wirecard AG in the United Kingdom, claiming they had received too little, and an Indian company also sued Wirecard in March 2019.","source_ids":["src-032","src-087","src-005"],"entity_ids":["wirecard","gi-retail","hermes","gi-philippines","wd-forex-india","gi-technology","emerging-fund","esma","ft","dpr"],"premise_claim_ids":["c-asia-gi-retail","c-asia-gi-price","c-asia-hermes-litigation"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 27 October 2015 Wirecard AG signed agreements to acquire the payment business of the Great Indian (GI) Retail Group: all of Hermes I Tickets Pte. Ltd., GI Philippines Corp. and Star Global Currency Exchange Pte. Ltd. and 60% of GI Technology Private Limited, for EUR 230 million in cash plus up to EUR 110 million depending on 2015–2017 results. It consolidated the three wholly owned companies from 30 December 2015 because a trust arrangement already gave it control, and acquired GI Technology at 60% from 1 March 2016. ESMA, summarising press reports, states that the key assets had been valued at EUR 46 million a year earlier and that a fund, EMIF1A, had paid USD 37 million for Hermes only six weeks before bundling it into the transaction; according to a magazine cited by ESMA the price of up to EUR 340 million was 49 times pre-tax earnings, and FREP told ESMA it included a EUR 110 million earn-out. Wirecard disputed critical reporting at the time, and no court has ruled on the price. Former minority shareholders of Hermes later sued their former co-shareholders and Wirecard AG in the United Kingdom, claiming they had received too little, and an Indian company also sued Wirecard in March 2019."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-363c424e4bcea6b367e2a8e2","record":{"id":"display-claim-363c424e4bcea6b367e2a8e2","kind":"analysis","text":"In early summer 2016, according to the special investigators, EY learned of a conversation between an EY India audit partner and Hermes' chief financial officer, summarised in a whistleblower memo: the seller, Emerging Fund1A, had itself bought the group a few months before the deal, Wirecard \"senior management\" was directly or indirectly involved in the fund and would receive the EUR 110 million earn-out, revenue would have to be fabricated to meet the targets, and these mechanisms were said to be directed by Stephan von Erffa. The management board stated that it had no interest in Fund1A, and EY accepted these statements; the allegations about von Erffa's role were left unexamined. On 8 September 2016 Burkhard Ley agreed to disclose his personal finances, but on 12 September he told the auditor he would neither do so nor be interviewed, which EY treated as an indicator of possible management involvement. The same day the board instructed EY's forensic service to carry out \"Projekt Ring\", a sample-based check of revenue with a review of e-mails and optionally of personal finances; the working papers show no notable work until February 2017.","source_ids":["src-027"],"entity_ids":["ey","hermes","emerging-fund","wirecard","von-erffa","ley"],"premise_claim_ids":["c-asia-ring-whistleblower","c-asia-ring-mandate"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In early summer 2016, according to the special investigators, EY learned of a conversation between an EY India audit partner and Hermes' chief financial officer, summarised in a whistleblower memo: the seller, Emerging Fund1A, had itself bought the group a few months before the deal, Wirecard \"senior management\" was directly or indirectly involved in the fund and would receive the EUR 110 million earn-out, revenue would have to be fabricated to meet the targets, and these mechanisms were said to be directed by Stephan von Erffa. The management board stated that it had no interest in Fund1A, and EY accepted these statements; the allegations about von Erffa's role were left unexamined. On 8 September 2016 Burkhard Ley agreed to disclose his personal finances, but on 12 September he told the auditor he would neither do so nor be interviewed, which EY treated as an indicator of possible management involvement. The same day the board instructed EY's forensic service to carry out \"Projekt Ring\", a sample-based check of revenue with a review of e-mails and optionally of personal finances; the working papers show no notable work until February 2017."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-425caf1c67f3362a65aa9a72","record":{"id":"display-claim-425caf1c67f3362a65aa9a72","kind":"analysis","text":"On 2 February 2017 EY proposed a simplified procedure because Wirecard had failed to provide a reliable transaction database, and Marsalek and Ley agreed. On 16 March EY wrote to Ley that revenue booked in 2015 and 2016 at Hermes was not adequately evidenced as to amount, substance and timing, that it significantly affected the earn-outs, and for the first time raised a possible qualification of the opinion. On 29 March 2017 it told Braun, Ley, Marsalek and the supervisory board chairman Wulf Matthias that it would qualify its opinions on the 2016 accounts unless it received evidence on more than 20 open questions, mainly about the whistleblower's allegations; at a \"Ring Meeting\" the next day Ley said additional questions were not feasible. Around that time the memos and e-mails by which the auditor confirmed the recoverability of disputed receivables were prepared or supplied mainly by Marsalek and Ley. At a meeting with EY on 3 April, according to EY's minutes as the special investigators summarise them, Braun said that interested parties were putting Wirecard under pressure with targeted false reports, that the Indian allegations reflected personal animosity and that additional transactions could affect the earn-out as long as this was in Wirecard's interest; he did not address the other allegations in substance.","source_ids":["src-027"],"entity_ids":["ey","wirecard","marsalek","ley","hermes","braun","matthias"],"premise_claim_ids":["c-asia-ring-2017","c-asia-ring-warning","c-asia-ring-braun"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 2 February 2017 EY proposed a simplified procedure because Wirecard had failed to provide a reliable transaction database, and Marsalek and Ley agreed. On 16 March EY wrote to Ley that revenue booked in 2015 and 2016 at Hermes was not adequately evidenced as to amount, substance and timing, that it significantly affected the earn-outs, and for the first time raised a possible qualification of the opinion. On 29 March 2017 it told Braun, Ley, Marsalek and the supervisory board chairman Wulf Matthias that it would qualify its opinions on the 2016 accounts unless it received evidence on more than 20 open questions, mainly about the whistleblower's allegations; at a \"Ring Meeting\" the next day Ley said additional questions were not feasible. Around that time the memos and e-mails by which the auditor confirmed the recoverability of disputed receivables were prepared or supplied mainly by Marsalek and Ley. At a meeting with EY on 3 April, according to EY's minutes as the special investigators summarise them, Braun said that interested parties were putting Wirecard under pressure with targeted false reports, that the Indian allegations reflected personal animosity and that additional transactions could affect the earn-out as long as this was in Wirecard's interest; he did not address the other allegations in substance."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-6d3d765a732563ef0b0a9305","record":{"id":"display-claim-6d3d765a732563ef0b0a9305","kind":"analysis","text":"On 4 April 2017 EY's forensic service recorded indicators of a targeted increase of EBITDA, that is fictitious revenue, at Hermes, while three allegations, instructions by von Erffa to Hermes' accounting, senior management's involvement in the seller and an attempt to bribe the auditor, remained unexamined; EY put the effect of including interest and tax accounts in Hermes' EBITDA on the earn-out at about EUR 13.6 million but accepted the treatment, citing among other things that the due-diligence provider had not objected. The open allegations were never investigated to a conclusion. The same day, one day before the opinion date, EY received balance confirmations for two receivables of Wirecard Singapore totalling about EUR 6.2 million, whose recoverability EY Singapore had doubted; the confirmation for the debtor Centurion was signed by a person who also held a position at the partner PayEasy. EY nevertheless issued unqualified opinions on the 2016 consolidated accounts on 5 April 2017 and on the individual accounts on 25 April, based mainly on statements by the management board. According to the Federal Court of Justice, Projekt Ring concerned the acquisition of three Indian companies at allegedly or actually inflated prices and was broken off in 2018 at the management board's insistence; an EY working paper of March 2018 records that Marsalek had wanted to end it as early as autumn 2017 and that the forensic team had repeatedly failed to obtain, or obtained only late, the documents it needed.","source_ids":["src-027","src-057"],"entity_ids":["ey","hermes","von-erffa","wirecard","bgh","wd-singapore","payeasy","bundestag","marsalek"],"premise_claim_ids":["c-asia-ring-findings","c-aud-singapore-confirmations","c-asia-ring-opinion","c-asia-ring-marsalek"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 4 April 2017 EY's forensic service recorded indicators of a targeted increase of EBITDA, that is fictitious revenue, at Hermes, while three allegations, instructions by von Erffa to Hermes' accounting, senior management's involvement in the seller and an attempt to bribe the auditor, remained unexamined; EY put the effect of including interest and tax accounts in Hermes' EBITDA on the earn-out at about EUR 13.6 million but accepted the treatment, citing among other things that the due-diligence provider had not objected. The open allegations were never investigated to a conclusion. The same day, one day before the opinion date, EY received balance confirmations for two receivables of Wirecard Singapore totalling about EUR 6.2 million, whose recoverability EY Singapore had doubted; the confirmation for the debtor Centurion was signed by a person who also held a position at the partner PayEasy. EY nevertheless issued unqualified opinions on the 2016 consolidated accounts on 5 April 2017 and on the individual accounts on 25 April, based mainly on statements by the management board. According to the Federal Court of Justice, Projekt Ring concerned the acquisition of three Indian companies at allegedly or actually inflated prices and was broken off in 2018 at the management board's insistence; an EY working paper of March 2018 records that Marsalek had wanted to end it as early as autumn 2017 and that the forensic team had repeatedly failed to obtain, or obtained only late, the documents it needed."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-6d9b10ae8c72af6a291cdc92","record":{"id":"display-claim-6d9b10ae8c72af6a291cdc92","kind":"analysis","text":"In spring 2018 a whistleblower reported irregularities in the local accounting department in Singapore, and Wirecard instructed the law firm Rajah & Tann, whose preliminary report is dated 4 May 2018. According to Wirecard's 2018 annual report, allegations of round-tripping, corruption, money laundering and deceiving regulators were not confirmed, but Singapore authorities were continuing their investigations and individual employees' criminal liability could not be ruled out. The Financial Times reported from 30 January 2019, as ESMA summarises, that a senior executive of the Singapore subsidiary was suspected of using forged and backdated contracts, that the law firm's preliminary report pointed to serious offences of forgery and that USD 37 million appeared to have moved in and out of Wirecard subsidiaries and outside businesses. Wirecard rejected the reports at the time; its 2019 prospectus summarised the firm's updated findings of 26 March 2019, assisted by Control Risks, as limited to EUR 2.5 million of 2017 revenue wrongly recognised under a sham contract and EUR 2.3 million entered in a subsidiary's ledger of old receivables. Singapore police later charged three former employees of Wirecard Asia Holding and a director of another company, and two of the former employees were convicted of criminal breach of trust in June 2023.","source_ids":["src-005","src-012","src-087","src-084","src-095"],"entity_ids":["wirecard","rajah-tann","control-risks","esma","ft","spf","wd-asia-holding"],"premise_claim_ids":["c-asia-sg-whistleblower","c-asia-sg-prospectus","c-asia-sg-ft"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In spring 2018 a whistleblower reported irregularities in the local accounting department in Singapore, and Wirecard instructed the law firm Rajah & Tann, whose preliminary report is dated 4 May 2018. According to Wirecard's 2018 annual report, allegations of round-tripping, corruption, money laundering and deceiving regulators were not confirmed, but Singapore authorities were continuing their investigations and individual employees' criminal liability could not be ruled out. The Financial Times reported from 30 January 2019, as ESMA summarises, that a senior executive of the Singapore subsidiary was suspected of using forged and backdated contracts, that the law firm's preliminary report pointed to serious offences of forgery and that USD 37 million appeared to have moved in and out of Wirecard subsidiaries and outside businesses. Wirecard rejected the reports at the time; its 2019 prospectus summarised the firm's updated findings of 26 March 2019, assisted by Control Risks, as limited to EUR 2.5 million of 2017 revenue wrongly recognised under a sham contract and EUR 2.3 million entered in a subsidiary's ledger of old receivables. Singapore police later charged three former employees of Wirecard Asia Holding and a director of another company, and two of the former employees were convicted of criminal breach of trust in June 2023."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-96866f4612b5088272f31a06","record":{"id":"display-claim-96866f4612b5088272f31a06","kind":"analysis","text":"In note 2.7 of its 2018 accounts Wirecard corrected retrospectively, in connection with the Asian investigations, errors in 2017 revenue recognition: software purchase and sale transactions of about EUR 10.0 million had been recorded in the wrong group units with an intermediary as counterparty, and the net effect on profit after tax was a reduction of EUR 3.6 million. ESMA notes that the adjustments reduced net assets by EUR 8.5 million at the start and EUR 4.8 million at the end of 2017 and that, according to the press, the Singapore transactions concerned totalled EUR 37 million in 2015–2018. The 2019 half-year report moved a software transaction of EUR 2.5 million from 2017 into 2018 and reduced first-half 2018 revenue and costs of Citi portfolios in Asia-Pacific not yet transferred by EUR 21.0 million.","source_ids":["src-005","src-087","src-066"],"entity_ids":["wirecard","esma","citigroup"],"premise_claim_ids":["c-asia-restatement-2018","c-asia-restatement-2019"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In note 2.7 of its 2018 accounts Wirecard corrected retrospectively, in connection with the Asian investigations, errors in 2017 revenue recognition: software purchase and sale transactions of about EUR 10.0 million had been recorded in the wrong group units with an intermediary as counterparty, and the net effect on profit after tax was a reduction of EUR 3.6 million. ESMA notes that the adjustments reduced net assets by EUR 8.5 million at the start and EUR 4.8 million at the end of 2017 and that, according to the press, the Singapore transactions concerned totalled EUR 37 million in 2015–2018. The 2019 half-year report moved a software transaction of EUR 2.5 million from 2017 into 2018 and reduced first-half 2018 revenue and costs of Citi portfolios in Asia-Pacific not yet transferred by EUR 21.0 million."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-59679935133a7674b0bf30af","record":{"id":"display-claim-59679935133a7674b0bf30af","kind":"analysis","text":"The Singapore Police Force announced on 17 August 2022 that, after the Commercial Affairs Department investigated Wirecard Asia Holding Pte Ltd and Wirecard Singapore Pte Ltd, three former employees of Wirecard Asia Holding and a director of another Singapore company were charged with criminal breach of trust for allegedly conspiring between May and December 2018 with Edo Kurniawan, then the company's vice president of controlling and finance, to misappropriate sums of $41,200 to $100,000, the release not naming the currency, and with related offences including the falsification of four invoices; these were charges, not findings. On 20 June 2023 two of them, the international finance process manager James Aga Wardhana and the head of finance Chai Ai Lim, were convicted and sentenced to 21 and 10 months' imprisonment. Kurniawan, who left Singapore before the investigation began, is at large, with a warrant of arrest and an INTERPOL red notice issued against him. A business directory records both Wirecard Asia Holding (UEN 201429281D) and Wirecard Singapore (UEN 199906900E), at 1 Raffles Quay, as dissolved by members' voluntary winding-up.","source_ids":["src-084","src-078","src-095","src-089"],"entity_ids":["spf","cad","wirecard","wd-asia-holding","wd-singapore","kurniawan","rsm"],"premise_claim_ids":["c-asia-sg-charges-2022","c-asia-sg-convictions-2023","c-asia-kurniawan-wanted","c-asia-wah-registry"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The Singapore Police Force announced on 17 August 2022 that, after the Commercial Affairs Department investigated Wirecard Asia Holding Pte Ltd and Wirecard Singapore Pte Ltd, three former employees of Wirecard Asia Holding and a director of another Singapore company were charged with criminal breach of trust for allegedly conspiring between May and December 2018 with Edo Kurniawan, then the company's vice president of controlling and finance, to misappropriate sums of $41,200 to $100,000, the release not naming the currency, and with related offences including the falsification of four invoices; these were charges, not findings. On 20 June 2023 two of them, the international finance process manager James Aga Wardhana and the head of finance Chai Ai Lim, were convicted and sentenced to 21 and 10 months' imprisonment. Kurniawan, who left Singapore before the investigation began, is at large, with a warrant of arrest and an INTERPOL red notice issued against him. A business directory records both Wirecard Asia Holding (UEN 201429281D) and Wirecard Singapore (UEN 199906900E), at 1 Raffles Quay, as dissolved by members' voluntary winding-up."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-568d1eb1e6839d21d0d458d0","record":{"id":"display-claim-568d1eb1e6839d21d0d458d0","kind":"analysis","text":"According to the Munich I prosecutor's indictment of 31 July 2024, OCAP Management Pte Ltd. was chosen as a supposedly neutral third party for the merchant cash advance business although until the end of 2017 it had financed oil transports, had nothing to do with card payments and belonged to the corporate network of another accused; it was renamed OCAP only at the end of 2017, after several formal ownership changes through shell companies, and then applied to Wirecard Bank for financing. The prosecution says Braun personally pressed a Wirecard Bank board member who had refused, that Wirecard AG gave a guarantee and that a loan of EUR 10 million was paid out but not passed on to merchants. These are prosecution allegations; the criminal court decided in February 2025 not to pursue the guarantee counts further, while in a civil case over the OCAP loan and a related bond subscription the Munich I regional court ordered three former board members in September 2024 to pay EUR 140 million, a judgment that was not final. The Federal Government stated in January 2021 that OCAP was formerly called Senjo Trading Pte. Ltd. and that Wirecard Bank's loans to it and to Senjo Group as TPA partners were in the sample of the 2017 MaRisk special audit by BaFin and the Bundesbank.","source_ids":["src-052","src-103","src-073"],"entity_ids":["ocap","wd-bank","braun","wirecard","sta-muenchen","senjo","bafin","bundestag"],"premise_claim_ids":["c-mca-ocap-selection","c-mca-ocap-senjo"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to the Munich I prosecutor's indictment of 31 July 2024, OCAP Management Pte Ltd. was chosen as a supposedly neutral third party for the merchant cash advance business although until the end of 2017 it had financed oil transports, had nothing to do with card payments and belonged to the corporate network of another accused; it was renamed OCAP only at the end of 2017, after several formal ownership changes through shell companies, and then applied to Wirecard Bank for financing. The prosecution says Braun personally pressed a Wirecard Bank board member who had refused, that Wirecard AG gave a guarantee and that a loan of EUR 10 million was paid out but not passed on to merchants. These are prosecution allegations; the criminal court decided in February 2025 not to pursue the guarantee counts further, while in a civil case over the OCAP loan and a related bond subscription the Munich I regional court ordered three former board members in September 2024 to pay EUR 140 million, a judgment that was not final. The Federal Government stated in January 2021 that OCAP was formerly called Senjo Trading Pte. Ltd. and that Wirecard Bank's loans to it and to Senjo Group as TPA partners were in the sample of the 2017 MaRisk special audit by BaFin and the Bundesbank."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-7c12882d2c664ba0e14aa97d","record":{"id":"display-claim-7c12882d2c664ba0e14aa97d","kind":"analysis","text":"In the preamble to a parliamentary question answered on 18 January 2021, opposition deputies citing a magazine stated that OCAP was under the influence of Senjo, received a EUR 115 million loan in 2018 guaranteed by Wirecard AG, had Carlos Häuser as managing director and that the loan was approved by a Wirecard employee identified as \"H.\"; that on 18 November 2018 the management board released EUR 500 million of loans and credit lines for the business; that the Indian travel provider Gomoo received EUR 11 million from Wirecard Bank; and that PayEasy received loans of EUR 270 million in 2018. These are the deputies' statements, not the government's, which replied that it had no information on whether \"H.\" had authority to approve loans. The prosecution states that a Wirecard subsidiary lent OCAP EUR 115 million in September and November 2018, that by autumn 2019 substantial interest arrears had built up, and that on 25 March 2020, during KPMG's special audit, the management board resolved without the supervisory board to lend OCAP a further EUR 100 million, when OCAP had already received about EUR 137 million and was servicing debts in the manner of a \"Ponzi scheme\". The count concerning Wirecard Asia Holding's loans to OCAP of September 2018 was discontinued in the criminal trial on 27 February 2025.","source_ids":["src-073","src-052","src-038","src-055"],"entity_ids":["ocap","senjo","wirecard","c-haeuser","wd-bank","goomo","payeasy","bundestag","sta-muenchen","kpmg","wd-asia-holding","olg-muenchen"],"premise_claim_ids":["c-mca-wd-bank-loans","c-mca-ocap-2018-loans","c-mca-wah-loans"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In the preamble to a parliamentary question answered on 18 January 2021, opposition deputies citing a magazine stated that OCAP was under the influence of Senjo, received a EUR 115 million loan in 2018 guaranteed by Wirecard AG, had Carlos Häuser as managing director and that the loan was approved by a Wirecard employee identified as \"H.\"; that on 18 November 2018 the management board released EUR 500 million of loans and credit lines for the business; that the Indian travel provider Gomoo received EUR 11 million from Wirecard Bank; and that PayEasy received loans of EUR 270 million in 2018. These are the deputies' statements, not the government's, which replied that it had no information on whether \"H.\" had authority to approve loans. The prosecution states that a Wirecard subsidiary lent OCAP EUR 115 million in September and November 2018, that by autumn 2019 substantial interest arrears had built up, and that on 25 March 2020, during KPMG's special audit, the management board resolved without the supervisory board to lend OCAP a further EUR 100 million, when OCAP had already received about EUR 137 million and was servicing debts in the manner of a \"Ponzi scheme\". The count concerning Wirecard Asia Holding's loans to OCAP of September 2018 was discontinued in the criminal trial on 27 February 2025."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-e8205548bd3c8fd0c83aa6d3","record":{"id":"display-claim-e8205548bd3c8fd0c83aa6d3","kind":"analysis","text":"According to the prosecution, the EUR 100 million reached OCAP's account at Wirecard Bank on 27 March 2020 and was transferred the same day in full to an account of Ruprecht Services Pte. Ltd. in Lithuania. From there EUR 35 million went to a separately prosecuted person, \"M.\", who passed it on as repayment of a 2017 loan to the account of Braun's asset-management company; this repaid a EUR 35 million Wirecard Bank loan, cancelled as of 1 April 2020, with which Braun had refinanced a EUR 150 million bank loan to his company. The prosecution puts the damage at several hundred million euros. These are allegations; the court has not ruled on them.","source_ids":["src-038","src-052"],"entity_ids":["ocap","wd-bank","ruprecht","braun","sta-muenchen"],"premise_claim_ids":["c-mca-ocap-flow"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to the prosecution, the EUR 100 million reached OCAP's account at Wirecard Bank on 27 March 2020 and was transferred the same day in full to an account of Ruprecht Services Pte. Ltd. in Lithuania. From there EUR 35 million went to a separately prosecuted person, \"M.\", who passed it on as repayment of a 2017 loan to the account of Braun's asset-management company; this repaid a EUR 35 million Wirecard Bank loan, cancelled as of 1 April 2020, with which Braun had refinanced a EUR 150 million bank loan to his company. The prosecution puts the damage at several hundred million euros. These are allegations; the court has not ruled on them."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-6192b11e8445520b410b7595","record":{"id":"display-claim-6192b11e8445520b410b7595","kind":"analysis","text":"The prosecution states that in December 2019, during KPMG's special investigation, the management board granted Ruprecht Services, which it describes as a penniless and later insolvent shell from the circle of another accused, a \"security deposit\" of EUR 40 million through subsidiaries without any security, supposedly to replace the TPA partner Al Alam. The increase from EUR 10 million to EUR 40 million on 23 December 2019 was approved within half an hour on Marsalek's e-mail proposal, without a formal resolution or the supervisory board; the earlier indictment says Braun agreed immediately and pressed the other board members, and that repayment is not expected. Braun's trial was continuing at the cutoff. Ruprecht Services was incorporated in Singapore on 17 August 2016 with IT consultancy as its stated activity, is in compulsory liquidation after a winding-up order of 25 February 2022, and is listed by the Monetary Authority of Singapore among entities that no longer hold a temporary exemption under the Payment Services Act.","source_ids":["src-052","src-038","src-072","src-077"],"entity_ids":["ruprecht","wirecard","al-alam","marsalek","braun","sta-muenchen","kpmg","mas"],"premise_claim_ids":["c-mca-security-deposit","c-mca-ruprecht-registry"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The prosecution states that in December 2019, during KPMG's special investigation, the management board granted Ruprecht Services, which it describes as a penniless and later insolvent shell from the circle of another accused, a \"security deposit\" of EUR 40 million through subsidiaries without any security, supposedly to replace the TPA partner Al Alam. The increase from EUR 10 million to EUR 40 million on 23 December 2019 was approved within half an hour on Marsalek's e-mail proposal, without a formal resolution or the supervisory board; the earlier indictment says Braun agreed immediately and pressed the other board members, and that repayment is not expected. Braun's trial was continuing at the cutoff. Ruprecht Services was incorporated in Singapore on 17 August 2016 with IT consultancy as its stated activity, is in compulsory liquidation after a winding-up order of 25 February 2022, and is listed by the Monetary Authority of Singapore among entities that no longer hold a temporary exemption under the Payment Services Act."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-6c8a9ee80b931365781f1412","record":{"id":"display-claim-6c8a9ee80b931365781f1412","kind":"analysis","text":"On 5 September 2024 the 5th commercial chamber of the Munich I regional court (case 5 HK O 17452/21) ordered three former management board members to pay EUR 140 million plus interest to the insolvency administrator, jointly and severally. The case concerned an unsecured EUR 100 million loan by a subsidiary, from Wirecard AG funds, to OCAP and a EUR 100 million bond subscribed by a subsidiary on Wirecard AG's instructions. The court's release does not name the three; press reporting identifies them as Braun and the finance and product board members. They argued that they had not breached their duties, or not culpably, and that the decisions were justified in the company's interest. The judgment was not final.","source_ids":["src-103","src-062"],"entity_ids":["wirecard","jaffe","ocap","braun","lg-muenchen"],"premise_claim_ids":["c-mca-civil-judgment"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 5 September 2024 the 5th commercial chamber of the Munich I regional court (case 5 HK O 17452/21) ordered three former management board members to pay EUR 140 million plus interest to the insolvency administrator, jointly and severally. The case concerned an unsecured EUR 100 million loan by a subsidiary, from Wirecard AG funds, to OCAP and a EUR 100 million bond subscribed by a subsidiary on Wirecard AG's instructions. The court's release does not name the three; press reporting identifies them as Braun and the finance and product board members. They argued that they had not breached their duties, or not culpably, and that the decisions were justified in the company's interest. The judgment was not final."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-0da4aad74426caa0a5e0ffbe","record":{"id":"display-claim-0da4aad74426caa0a5e0ffbe","kind":"analysis","text":"The court put the damage from the OCAP loan at EUR 40 million, because EUR 60 million had been repaid from the bond subscription and the borrower was insolvent, and found the loan negligent mainly because of arrears of EUR 2.375 million on another loan and because, after KPMG's special audit, it was uncertain whether the third-party acquiring business closely linked to the loan existed. The bond was subscribed without financial due diligence and against a lawyer's advice, and the full amount was lost because the issuer was insolvent. The court dismissed the claim against the former deputy supervisory board chairman Stefan Klestil: he had neglected his duty of supervision, but the court doubted that proper supervision would have changed the board's conduct, since the board had already disregarded the supervisory board's instructions; no criminal offence is alleged against him.","source_ids":["src-103","src-062"],"entity_ids":["wirecard","ocap","kpmg","lg-muenchen","klestil","jaffe"],"premise_claim_ids":["c-mca-civil-damage","c-mca-civil-klestil"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The court put the damage from the OCAP loan at EUR 40 million, because EUR 60 million had been repaid from the bond subscription and the borrower was insolvent, and found the loan negligent mainly because of arrears of EUR 2.375 million on another loan and because, after KPMG's special audit, it was uncertain whether the third-party acquiring business closely linked to the loan existed. The bond was subscribed without financial due diligence and against a lawyer's advice, and the full amount was lost because the issuer was insolvent. The court dismissed the claim against the former deputy supervisory board chairman Stefan Klestil: he had neglected his duty of supervision, but the court doubted that proper supervision would have changed the board's conduct, since the board had already disregarded the supervisory board's instructions; no criminal offence is alleged against him."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-38f8d849534293509ea2c7e5","record":{"id":"display-claim-38f8d849534293509ea2c7e5","kind":"analysis","text":"According to a Singapore newspaper, Singapore's Commercial Affairs Department seized USD 8.63 million of oCap Management and SGD 290,000 of its subsidiary oCap Asia Pacific Holdings on 20 August 2020 as suspected proceeds of serious crime, and in November 2020 the High Court rejected the company's application to release funds to repay \"loans\" from Wirecard and expenses; the seizure is an investigative measure, not a finding of guilt. A later judgment of the High Court records that German authorities charged Braun on 10 March 2022 with embezzlement involving loans of EUR 210 million from Wirecard companies to oCap, allegedly used to disguise the group's position and divert money, and that at their request the court ordered on 3 November 2023 the restraint of the company's funds in two Citibank N.A. accounts as Germany seeks confiscation of EUR 210 million. The charges are allegations; the Singapore court decided only on the restraint and release of funds.","source_ids":["src-083","src-071"],"entity_ids":["ocap","ocap-asia","cad","wirecard","braun","ag-singapore","citibank-na"],"premise_claim_ids":["c-mca-ocap-singapore-2020","c-mca-ocap-restraint"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to a Singapore newspaper, Singapore's Commercial Affairs Department seized USD 8.63 million of oCap Management and SGD 290,000 of its subsidiary oCap Asia Pacific Holdings on 20 August 2020 as suspected proceeds of serious crime, and in November 2020 the High Court rejected the company's application to release funds to repay \"loans\" from Wirecard and expenses; the seizure is an investigative measure, not a finding of guilt. A later judgment of the High Court records that German authorities charged Braun on 10 March 2022 with embezzlement involving loans of EUR 210 million from Wirecard companies to oCap, allegedly used to disguise the group's position and divert money, and that at their request the court ordered on 3 November 2023 the restraint of the company's funds in two Citibank N.A. accounts as Germany seeks confiscation of EUR 210 million. The charges are allegations; the Singapore court decided only on the restraint and release of funds."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-3f338d76a55ea2f5bf441594","record":{"id":"display-claim-3f338d76a55ea2f5bf441594","kind":"analysis","text":"oCap Management has been in creditors' voluntary liquidation since 10 December 2020 and in court-ordered liquidation since 15 March 2021. Wirecard group companies hold over 97% of its debt; they funded the liquidators' investigation but declined to fund claims against third parties, and recoveries for the group are pursued under the control of the insolvency administrator, Dr. Michael Jaffé. On 13 May 2026 the High Court released fees already incurred of SGD 178,560.25 from the restraint but refused to release about SGD 2,997,500 for future claims, which the liquidators intended to bring against former and possible shadow or de facto directors over a questionable dividend and against a company over a breach of an agreement to assign sale proceeds.","source_ids":["src-071"],"entity_ids":["ocap","wirecard","jaffe"],"premise_claim_ids":["c-mca-ocap-creditors","c-mca-ocap-singapore-2026"],"qualification":"","response":"","outcome":""},"reading":"Analysis: oCap Management has been in creditors' voluntary liquidation since 10 December 2020 and in court-ordered liquidation since 15 March 2021. Wirecard group companies hold over 97% of its debt; they funded the liquidators' investigation but declined to fund claims against third parties, and recoveries for the group are pursued under the control of the insolvency administrator, Dr. Michael Jaffé. On 13 May 2026 the High Court released fees already incurred of SGD 178,560.25 from the restraint but refused to release about SGD 2,997,500 for future claims, which the liquidators intended to bring against former and possible shadow or de facto directors over a questionable dividend and against a company over a breach of an agreement to assign sale proceeds."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-d6cada93fc6742e7585ab7fe","record":{"id":"display-claim-d6cada93fc6742e7585ab7fe","kind":"analysis","text":"Wirecard AG applied on 25 June 2020 to open insolvency proceedings over its assets, citing impending insolvency and over-indebtedness. On 29 June the Munich local court appointed the Munich lawyer Dr. Michael Jaffé as preliminary administrator, made the company's dispositions subject to his consent and prohibited enforcement, confirming an order of 25 June. The court opened the proceedings on 25 August 2020, dissolving the company, and appointed Jaffé administrator of Wirecard AG and of Wirecard Technologies, Wirecard Issuing Technologies, Wirecard Service Technologies, Wirecard Acceptance Technologies, Wirecard Sales International Holding and Wirecard Global Sales; the register shows Wirecard AG in liquidation from 4 September 2020. The Leipzig local court opened proceedings over Wirecard Communication Services on 31 August 2020, and an Irish court ordered Wirecard UK and Ireland Limited to be wound up on 28 October 2020, with liquidator's reports filed up to April 2026.","source_ids":["src-009","src-002","src-025","src-026","src-014","src-018","src-041","src-042","src-043","src-015","src-001","src-019","src-064"],"entity_ids":["wirecard","jaffe","ag-muenchen","wd-tech","wd-issuing-tech","wd-service-tech","wd-acceptance-tech","wd-sih","wd-global-sales","wd-comm-services","holten","goerres","steinhoff","wd-uki"],"premise_claim_ids":["c-ins-petition","c-ins-opening","c-ins-comm-services","c-ins-irish"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard AG applied on 25 June 2020 to open insolvency proceedings over its assets, citing impending insolvency and over-indebtedness. On 29 June the Munich local court appointed the Munich lawyer Dr. Michael Jaffé as preliminary administrator, made the company's dispositions subject to his consent and prohibited enforcement, confirming an order of 25 June. The court opened the proceedings on 25 August 2020, dissolving the company, and appointed Jaffé administrator of Wirecard AG and of Wirecard Technologies, Wirecard Issuing Technologies, Wirecard Service Technologies, Wirecard Acceptance Technologies, Wirecard Sales International Holding and Wirecard Global Sales; the register shows Wirecard AG in liquidation from 4 September 2020. The Leipzig local court opened proceedings over Wirecard Communication Services on 31 August 2020, and an Irish court ordered Wirecard UK and Ireland Limited to be wound up on 28 October 2020, with liquidator's reports filed up to April 2026."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-0ef4deb1e284d75b9675e495","record":{"id":"display-claim-0ef4deb1e284d75b9675e495","kind":"analysis","text":"In early July 2020 Wirecard filed for insolvency of six further German service subsidiaries with 1,270 employees, which the administrator wanted to continue where possible; Wirecard AG itself had 250 employees. After the proceedings opened about 730 jobs were cut, while 570 staff in Aschheim kept their jobs, 350 of them in the insolvent companies and 220 at Wirecard Bank, which remained solvent.","source_ids":["src-076","src-048"],"entity_ids":["wirecard","jaffe","wd-bank"],"premise_claim_ids":["c-ins-staff"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In early July 2020 Wirecard filed for insolvency of six further German service subsidiaries with 1,270 employees, which the administrator wanted to continue where possible; Wirecard AG itself had 250 employees. After the proceedings opened about 730 jobs were cut, while 570 staff in Aschheim kept their jobs, 350 of them in the insolvent companies and 220 at Wirecard Bank, which remained solvent."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-23358c8f1bf614602f7232f3","record":{"id":"display-claim-23358c8f1bf614602f7232f3","kind":"analysis","text":"On 5 July 2020 Wirecard Acquiring & Issuing GmbH, in agreement with Wirecard AG and the preliminary administrator, engaged Moelis & Company to sell Wirecard North America, which went to Syncapay. Wirecard announced an agreement for a PagSeguro subsidiary to acquire Wirecard Brazil, subject to Brazilian approval, and an agreement in principle for Wirecard Card Solutions to sell customer relationships and other assets to Railsbank Technology. On 28 September 2020 the administrator sold Wirecard Romania, held by Wirecard Sales International Holding, with Romcard and Supercard to the payment provider SIBS, while the Indonesian and Vietnamese companies were in advanced auctions; the Austrian Wirecard Central Eastern Europe's business went to AURIN Investment Group with effect from 30 September 2020, according to its own administrator, Dr. Ulla Reisch.","source_ids":["src-048","src-046","src-035","src-029"],"entity_ids":["wd-acq-iss","wirecard","moelis","wd-north-america","wd-brazil","pagseguro","wd-card-solutions","railsbank","wd-romania","wd-sih","sibs","romcard","supercard","prima-vista","wd-indonesia","wd-vietnam","jaffe","wd-cee","aurin","reisch","wd-tech","santander","syncapay"],"premise_claim_ids":["c-ins-moelis","c-ins-brazil-railsbank","c-ins-romania","c-ins-cee","c-ins-santander"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 5 July 2020 Wirecard Acquiring & Issuing GmbH, in agreement with Wirecard AG and the preliminary administrator, engaged Moelis & Company to sell Wirecard North America, which went to Syncapay. Wirecard announced an agreement for a PagSeguro subsidiary to acquire Wirecard Brazil, subject to Brazilian approval, and an agreement in principle for Wirecard Card Solutions to sell customer relationships and other assets to Railsbank Technology. On 28 September 2020 the administrator sold Wirecard Romania, held by Wirecard Sales International Holding, with Romcard and Supercard to the payment provider SIBS, while the Indonesian and Vietnamese companies were in advanced auctions; the Austrian Wirecard Central Eastern Europe's business went to AURIN Investment Group with effect from 30 September 2020, according to its own administrator, Dr. Ulla Reisch."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-1dcc89717d966a1e80d60ff4","record":{"id":"display-claim-1dcc89717d966a1e80d60ff4","kind":"analysis","text":"The sale of the core assets of Wirecard AG and Wirecard Technologies, the European technology platform, to the Santander group closed on 28 January 2021 after signing in mid-November 2020, and about 500 employees moved to Santander's Getnet platform. On 30 March 2021 the administrator announced the sale of the Turkish subsidiary to Nomu Pay, a new Irish company of the investor Finch Capital, and on 16 April 2021 the sale to Nomu Pay of the companies in the Philippines, Malaysia, Thailand and Hong Kong, with assets and licences linked to the Singapore data centre, and of PT Wirecard Technologies Indonesia to an Indonesian group; Wirecard Australia A&I had already been sold. By mid-2021, according to the administrator's law firm, the core business and the valuable foreign subsidiaries had been sold for a total in the \"high three-digit millions\", about 2,700 jobs had been preserved, and claims for damages were being pursued in many jurisdictions.","source_ids":["src-029","src-045","src-026","src-028"],"entity_ids":["wirecard","wd-tech","santander","jaffe","wd-north-america","syncapay","wd-brazil","pagseguro","wd-romania","sibs","wd-turkey","nomu-pay","wd-emoney-ph","wd-ps-malaysia","wd-thailand","wd-ps-hk","wd-asia-holding","wd-singapore","wd-indonesia","wd-australia-ai"],"premise_claim_ids":["c-ins-santander","c-ins-turkey","c-ins-asia-sales","c-ins-status"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The sale of the core assets of Wirecard AG and Wirecard Technologies, the European technology platform, to the Santander group closed on 28 January 2021 after signing in mid-November 2020, and about 500 employees moved to Santander's Getnet platform. On 30 March 2021 the administrator announced the sale of the Turkish subsidiary to Nomu Pay, a new Irish company of the investor Finch Capital, and on 16 April 2021 the sale to Nomu Pay of the companies in the Philippines, Malaysia, Thailand and Hong Kong, with assets and licences linked to the Singapore data centre, and of PT Wirecard Technologies Indonesia to an Indonesian group; Wirecard Australia A&I had already been sold. By mid-2021, according to the administrator's law firm, the core business and the valuable foreign subsidiaries had been sold for a total in the \"high three-digit millions\", about 2,700 jobs had been preserved, and claims for damages were being pursued in many jurisdictions."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-134af0c5c9c72e0040cd0519","record":{"id":"display-claim-134af0c5c9c72e0040cd0519","kind":"analysis","text":"According to the Federal Court of Justice, about 50,000 Wirecard AG shareholders filed damage claims of about EUR 8.5 billion arising from their share purchases, and claims in total amount to about EUR 15.4 billion, including EUR 500 million of bondholders' claims, against an estate of about EUR 650 million. On 13 November 2025 the court (IX ZR 127/24) ruled that shareholders of an insolvent stock corporation cannot share in the distribution of the estate as ordinary insolvency creditors with their capital-market damage claims, setting aside a Munich higher regional court judgment of September 2024 to that extent and restoring the Munich I regional court's dismissal of November 2022.","source_ids":["src-056","src-051"],"entity_ids":["wirecard","bgh","jaffe","lg-muenchen"],"premise_claim_ids":["c-ins-claims","c-ins-bgh-shareholders"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to the Federal Court of Justice, about 50,000 Wirecard AG shareholders filed damage claims of about EUR 8.5 billion arising from their share purchases, and claims in total amount to about EUR 15.4 billion, including EUR 500 million of bondholders' claims, against an estate of about EUR 650 million. On 13 November 2025 the court (IX ZR 127/24) ruled that shareholders of an insolvent stock corporation cannot share in the distribution of the estate as ordinary insolvency creditors with their capital-market damage claims, setting aside a Munich higher regional court judgment of September 2024 to that extent and restoring the Munich I regional court's dismissal of November 2022."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-845f51ff57f34bef405808b6","record":{"id":"display-claim-845f51ff57f34bef405808b6","kind":"analysis","text":"According to a news agency report of 6 July 2020, the Munich prosecutor said it had questioned the chief executive of CardSystems Middle East, Wirecard's Dubai subsidiary, and arrested him on a warrant after he travelled from Dubai and turned himself in, on suspicion of conspiracy to commit fraud, attempted fraud and aiding other offences; the prosecutors did not name him. He was later charged as \"B.\", and a July 2022 press report identifies him as Oliver Bellenhaus, a principal prosecution witness. At the Bundestag inquiry committee's session of 19 November 2020, Braun invoked his right not to incriminate himself, said the courts should establish where the embezzled company funds had gone and announced a detailed statement to the prosecutor; Bellenhaus, joining from prison, also declined to answer but described events as a \"huge catastrophe\" and apologised to those harmed.","source_ids":["src-094","src-038","src-067","src-079"],"entity_ids":["sta-muenchen","cardsystems-me","wirecard","bellenhaus","braun","bundestag"],"premise_claim_ids":["c-crim-dubai-arrest","c-crim-bundestag-witnesses"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to a news agency report of 6 July 2020, the Munich prosecutor said it had questioned the chief executive of CardSystems Middle East, Wirecard's Dubai subsidiary, and arrested him on a warrant after he travelled from Dubai and turned himself in, on suspicion of conspiracy to commit fraud, attempted fraud and aiding other offences; the prosecutors did not name him. He was later charged as \"B.\", and a July 2022 press report identifies him as Oliver Bellenhaus, a principal prosecution witness. At the Bundestag inquiry committee's session of 19 November 2020, Braun invoked his right not to incriminate himself, said the courts should establish where the embezzled company funds had gone and announced a detailed statement to the prosecutor; Bellenhaus, joining from prison, also declined to answer but described events as a \"huge catastrophe\" and apologised to those harmed."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-400802629a10a36ce9f0ae5f","record":{"id":"display-claim-400802629a10a36ce9f0ae5f","kind":"analysis","text":"On 10 March 2022 the Munich I public prosecutor charged \"Dr. B.\" (former chief executive of Wirecard AG), \"von E.\" (former head of accounting) and \"B.\" (former managing director of CardSystems Middle East) before the 4th criminal chamber of the Munich I regional court in a 474-page indictment; two of the three were in pre-trial detention. A later press report names them as Markus Braun, Stephan von Erffa and Oliver Bellenhaus. The indictment states the prosecution's case, which the court has to establish; the trial began on 8 December 2022, hearing dates have been set up to 23 December 2026, and no judgment had been announced by the cutoff.","source_ids":["src-038","src-051","src-054"],"entity_ids":["sta-muenchen","braun","von-erffa","bellenhaus","cardsystems-me","wirecard","lg-muenchen"],"premise_claim_ids":["c-crim-indictment-2022"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 10 March 2022 the Munich I public prosecutor charged \"Dr. B.\" (former chief executive of Wirecard AG), \"von E.\" (former head of accounting) and \"B.\" (former managing director of CardSystems Middle East) before the 4th criminal chamber of the Munich I regional court in a 474-page indictment; two of the three were in pre-trial detention. A later press report names them as Markus Braun, Stephan von Erffa and Oliver Bellenhaus. The indictment states the prosecution's case, which the court has to establish; the trial began on 8 December 2022, hearing dates have been set up to 23 December 2026, and no judgment had been announced by the cutoff."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-3266447386ea271f9ac2b807","record":{"id":"display-claim-3266447386ea271f9ac2b807","kind":"analysis","text":"The prosecution's case is that the consolidated accounts for 2015 to 2018 were false because they included revenue from TPA business with three partners in Dubai, the Philippines and Singapore that did not exist, booked as receivables from the partners or as trust-account balances in Singapore; a balance of almost one billion euros in 2018 supposedly managed by a trustee \"C.\" never existed, and balance confirmations were forged by the trustee or by \"B.\" on the instructions of \"von E.\". It charges six counts of professional gang fraud, because banks lent about EUR 1.7 billion in four loans and two bonds of about EUR 1.4 billion were issued on the basis of those figures, and accuses Braun of 26 counts of market manipulation from 2015 to April 2019, including deciding alone to publish an ad hoc announcement on 22 April 2020 that falsely suggested KPMG's report would clear Wirecard. It notes that part of his pay was linked to the share price and that he held about 7% of the capital, receiving dividends of about EUR 5.5 million. Braun's defence is that the TPA business existed and its proceeds were embezzled by Jan Marsalek's circle, an account the presiding judge called untenable in September 2026. All of these are prosecution allegations on which no verdict had been reached at the cutoff; the release does not name the banks, and the court later dropped the market-manipulation counts.","source_ids":["src-038","src-060"],"entity_ids":["sta-muenchen","wirecard","citadelle","bellenhaus","von-erffa","braun","marsalek","kpmg"],"premise_claim_ids":["c-crim-charges-accounts","c-crim-charges-fraud","c-crim-charges-market"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The prosecution's case is that the consolidated accounts for 2015 to 2018 were false because they included revenue from TPA business with three partners in Dubai, the Philippines and Singapore that did not exist, booked as receivables from the partners or as trust-account balances in Singapore; a balance of almost one billion euros in 2018 supposedly managed by a trustee \"C.\" never existed, and balance confirmations were forged by the trustee or by \"B.\" on the instructions of \"von E.\". It charges six counts of professional gang fraud, because banks lent about EUR 1.7 billion in four loans and two bonds of about EUR 1.4 billion were issued on the basis of those figures, and accuses Braun of 26 counts of market manipulation from 2015 to April 2019, including deciding alone to publish an ad hoc announcement on 22 April 2020 that falsely suggested KPMG's report would clear Wirecard. It notes that part of his pay was linked to the share price and that he held about 7% of the capital, receiving dividends of about EUR 5.5 million. Braun's defence is that the TPA business existed and its proceeds were embezzled by Jan Marsalek's circle, an account the presiding judge called untenable in September 2026. All of these are prosecution allegations on which no verdict had been reached at the cutoff; the release does not name the banks, and the court later dropped the market-manipulation counts."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-89ec72b2b2f83fca3d1bfbf8","record":{"id":"display-claim-89ec72b2b2f83fca3d1bfbf8","kind":"analysis","text":"The main trial before the 4th (grand) criminal chamber (4 KLs 402 Js 108194/22) began on 8 December 2022. On 27 February 2025 the chamber, at its own suggestion and with the prosecutor's agreement, limited the case: the discontinued counts include false 2015 consolidated accounts, Wirecard AG's guarantees for Wirecard Bank loans to OCAP (December 2017 and April 2019), Wirecard Asia Holding's loans to OCAP (September 2018), fraud in extending and increasing the syndicated loan led by \"C. AG\" in 2016 (EUR 725 million) and 2017 (EUR 1 billion), fraud in issuing the EUR 500 million bond and the 26 counts of market manipulation. For the remaining counts of breach of trust and fraud each carries up to ten years and an aggregate sentence up to fifteen. On 26 May 2026 the presiding judge set hearing dates up to 23 December 2026, saying this allowed no conclusion about when the trial would end, and on 19 June 2026 the court published further dates after a move of premises; no judgment had been announced.","source_ids":["src-051","src-055","src-054","src-039"],"entity_ids":["lg-muenchen","braun","sta-muenchen","wirecard","wd-bank","ocap","wd-asia-holding","olg-muenchen"],"premise_claim_ids":["c-crim-trial","c-crim-trial-2026"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The main trial before the 4th (grand) criminal chamber (4 KLs 402 Js 108194/22) began on 8 December 2022. On 27 February 2025 the chamber, at its own suggestion and with the prosecutor's agreement, limited the case: the discontinued counts include false 2015 consolidated accounts, Wirecard AG's guarantees for Wirecard Bank loans to OCAP (December 2017 and April 2019), Wirecard Asia Holding's loans to OCAP (September 2018), fraud in extending and increasing the syndicated loan led by \"C. AG\" in 2016 (EUR 725 million) and 2017 (EUR 1 billion), fraud in issuing the EUR 500 million bond and the 26 counts of market manipulation. For the remaining counts of breach of trust and fraud each carries up to ten years and an aggregate sentence up to fifteen. On 26 May 2026 the presiding judge set hearing dates up to 23 December 2026, saying this allowed no conclusion about when the trial would end, and on 19 June 2026 the court published further dates after a move of premises; no judgment had been announced."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-82dc91a6a76175ad624f9335","record":{"id":"display-claim-82dc91a6a76175ad624f9335","kind":"analysis","text":"According to a press report of 14 September 2026, presiding judge Markus Födisch said there were \"no indications whatsoever\" that the TPA business with partners in Dubai, Singapore and the Philippines existed, and called Braun's account that the profits had been embezzled by Marsalek's circle untenable \"speculation\"; Braun had then been in pre-trial detention without interruption since July 2020. The judge formally warned the three defendants that proceeds could be confiscated if they were convicted: almost EUR 39 million in Braun's case, most of it held by his personal investment company, more than EUR 6 million for Bellenhaus, who had confirmed the indictment in its essential points, and more than EUR 600,000 for von Erffa. These statements during the trial are not a judgment; the defendants are presumed innocent until a final verdict, and Braun maintains that the business existed and its proceeds were embezzled by others.","source_ids":["src-060"],"entity_ids":["lg-muenchen","braun","marsalek","bellenhaus","von-erffa"],"premise_claim_ids":["c-crim-judge-2026"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to a press report of 14 September 2026, presiding judge Markus Födisch said there were \"no indications whatsoever\" that the TPA business with partners in Dubai, Singapore and the Philippines existed, and called Braun's account that the profits had been embezzled by Marsalek's circle untenable \"speculation\"; Braun had then been in pre-trial detention without interruption since July 2020. The judge formally warned the three defendants that proceeds could be confiscated if they were convicted: almost EUR 39 million in Braun's case, most of it held by his personal investment company, more than EUR 6 million for Bellenhaus, who had confirmed the indictment in its essential points, and more than EUR 600,000 for von Erffa. These statements during the trial are not a judgment; the defendants are presumed innocent until a final verdict, and Braun maintains that the business existed and its proceeds were embezzled by others."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-2eb6546967beb654e850df6e","record":{"id":"display-claim-2eb6546967beb654e850df6e","kind":"analysis","text":"According to a July 2022 press report based on another newspaper's information, von Erffa admitted to prosecutors that in early 2020 he had fabricated, after the event, an e-mail and a trustee request form for a EUR 50 million transfer Wirecard received in 2018 supposedly from an Asian trust account, documents that were passed to KPMG and EY, and called the forgery a one-off; according to the prosecutors as reported, the money came from an Asian partner that had borrowed EUR 100 million from Wirecard and returned half through opaque companies. This is a second-hand account, not a court finding.","source_ids":["src-067"],"entity_ids":["von-erffa","kpmg","ey","wirecard","sta-muenchen"],"premise_claim_ids":["c-crim-von-erffa-admission"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to a July 2022 press report based on another newspaper's information, von Erffa admitted to prosecutors that in early 2020 he had fabricated, after the event, an e-mail and a trustee request form for a EUR 50 million transfer Wirecard received in 2018 supposedly from an Asian trust account, documents that were passed to KPMG and EY, and called the forgery a one-off; according to the prosecutors as reported, the money came from an Asian partner that had borrowed EUR 100 million from Wirecard and returned half through opaque companies. This is a second-hand account, not a court finding."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-620cff60ff6851e0b9607a53","record":{"id":"display-claim-620cff60ff6851e0b9607a53","kind":"analysis","text":"On 12 December 2023 the prosecutor indicted the former chief financial officer \"L.\", whose description matches Burkhard Ley, finance director until the end of 2017, for misrepresentation, market manipulation, professional gang fraud, breach of trust and aiding these offences: he is accused of joining Braun, von Erffa, Bellenhaus and \"M.\" in simulating the TPA business, of signing the 2015 and 2016 accounts, of aiding the others with advice after leaving and of breach of trust through Wirecard AG's guarantee of a Wirecard Bank loan to a Singapore company. On 31 July 2024 it indicted \"von K.\" (finance) and \"S.\" (product development), whose posts match Alexander von Knoop and Susanne Steidl, for breach of trust and aiding it over the December 2019 security deposit and the OCAP loans. In both cases the 12th commercial crime chamber was to decide whether to open a trial; no decision is in the record, and the charges are allegations.","source_ids":["src-053","src-052"],"entity_ids":["sta-muenchen","ley","wirecard","braun","wd-bank","von-knoop","steidl","ocap","ruprecht"],"premise_claim_ids":["c-crim-ley","c-crim-knoop-steidl"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 12 December 2023 the prosecutor indicted the former chief financial officer \"L.\", whose description matches Burkhard Ley, finance director until the end of 2017, for misrepresentation, market manipulation, professional gang fraud, breach of trust and aiding these offences: he is accused of joining Braun, von Erffa, Bellenhaus and \"M.\" in simulating the TPA business, of signing the 2015 and 2016 accounts, of aiding the others with advice after leaving and of breach of trust through Wirecard AG's guarantee of a Wirecard Bank loan to a Singapore company. On 31 July 2024 it indicted \"von K.\" (finance) and \"S.\" (product development), whose posts match Alexander von Knoop and Susanne Steidl, for breach of trust and aiding it over the December 2019 security deposit and the OCAP loans. In both cases the 12th commercial crime chamber was to decide whether to open a trial; no decision is in the record, and the charges are allegations."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-d2a0758115dfbb591eef7420","record":{"id":"display-claim-d2a0758115dfbb591eef7420","kind":"analysis","text":"The prosecutor closed its investigation into the former treasurer Thorsten Holten, as his lawyer confirmed in July 2024, saying the accusations had proved entirely false; the legal basis is not given. A newspaper reported in May 2021 that the prosecutor had opened an investigation into the former supervisory board chairman Wulf Matthias, among other former supervisory board members, after investor complaints; Matthias told the Bundestag committee through his lawyer that he would use his right to remain silent, and no charge or outcome is recorded. On 30 March 2026 Singapore extradited Brigitte Häuser-Axtner to Germany, where she was wanted on suspicion of involvement in a criminal organisation, computer fraud and money laundering connected with the Wirecard group, after her arrest in November 2025 and her consent to extradition; Singapore police said she was not accused of offences in Singapore.","source_ids":["src-061","src-074","src-085","src-081"],"entity_ids":["sta-muenchen","holten","wirecard","matthias","bundestag","spf","haeuser-axtner","wd-asia-holding"],"premise_claim_ids":["c-crim-holten","c-crim-matthias","c-crim-haeuser-axtner"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The prosecutor closed its investigation into the former treasurer Thorsten Holten, as his lawyer confirmed in July 2024, saying the accusations had proved entirely false; the legal basis is not given. A newspaper reported in May 2021 that the prosecutor had opened an investigation into the former supervisory board chairman Wulf Matthias, among other former supervisory board members, after investor complaints; Matthias told the Bundestag committee through his lawyer that he would use his right to remain silent, and no charge or outcome is recorded. On 30 March 2026 Singapore extradited Brigitte Häuser-Axtner to Germany, where she was wanted on suspicion of involvement in a criminal organisation, computer fraud and money laundering connected with the Wirecard group, after her arrest in November 2025 and her consent to extradition; Singapore police said she was not accused of offences in Singapore."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-3e34a67417fda6b90088d12b","record":{"id":"display-claim-3e34a67417fda6b90088d12b","kind":"analysis","text":"According to the Munich I regional court, investors began suing the auditor EY for compensation in June 2020; by January 2023, 1,178 such suits had been filed, handled by nine banking chambers. The court reported that 2,251 Wirecard-related cases reached it from mid-2019 to the end of 2022. In March 2022 it initiated an investor model proceeding against EY, conducted by the Bavarian Supreme Regional Court (101 KAP 1/22). An order of that court of 13 May 2024 lists eleven model defendants: Markus Braun; EY; four EY auditors who worked on the 2014–2018 audits, not named in the order; Alexander von Knoop; Jan Marsalek, whose whereabouts are unknown; MB Beteiligungsgesellschaft mbH, now represented by its provisional insolvency administrator; Michael Jaffé as insolvency administrator of Wirecard AG; and Oliver Bellenhaus, who headed Wirecard AG's branch in Dubai.","source_ids":["src-051","src-102"],"entity_ids":["lg-muenchen","ey","bayoblg","wirecard","ft","braun","von-knoop","marsalek","mb-beteiligung","jaffe","bellenhaus"],"premise_claim_ids":["c-civ-ey-suits","c-ins-court-volume","c-civ-kapmug-parties"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to the Munich I regional court, investors began suing the auditor EY for compensation in June 2020; by January 2023, 1,178 such suits had been filed, handled by nine banking chambers. The court reported that 2,251 Wirecard-related cases reached it from mid-2019 to the end of 2022. In March 2022 it initiated an investor model proceeding against EY, conducted by the Bavarian Supreme Regional Court (101 KAP 1/22). An order of that court of 13 May 2024 lists eleven model defendants: Markus Braun; EY; four EY auditors who worked on the 2014–2018 audits, not named in the order; Alexander von Knoop; Jan Marsalek, whose whereabouts are unknown; MB Beteiligungsgesellschaft mbH, now represented by its provisional insolvency administrator; Michael Jaffé as insolvency administrator of Wirecard AG; and Oliver Bellenhaus, who headed Wirecard AG's branch in Dubai."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-f7f97bc7569d0cdfe094e505","record":{"id":"display-claim-f7f97bc7569d0cdfe094e505","kind":"analysis","text":"According to the facts set out in the referral order, as the court summarises the claimants' allegations, Braun is accused of having misinformed the capital market as chief executive through incorrect consolidated statements for 2014–2018, missing disclosures and untrue ad hoc announcements, and EY of issuing false audit opinions and aiding the alleged breaches; EY gave unqualified opinions for each of those years. The court has not ruled on these allegations. On 13 May 2024 it held that the proceeding was interrupted against MB Beteiligungsgesellschaft but not against the other ten defendants, refused to restore EY's former party name after its conversion into EY GmbH & Co. KG Wirtschaftsprüfungsgesellschaft, rejecting the argument that the conversion was void, and refused to sever the proceedings against EY, MB and Braun, which would have created parallel model proceedings.","source_ids":["src-102","src-090"],"entity_ids":["ey","wirecard","braun","bayoblg","mb-beteiligung"],"premise_claim_ids":["c-civ-kapmug-allegations","c-civ-kapmug-may2024"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to the facts set out in the referral order, as the court summarises the claimants' allegations, Braun is accused of having misinformed the capital market as chief executive through incorrect consolidated statements for 2014–2018, missing disclosures and untrue ad hoc announcements, and EY of issuing false audit opinions and aiding the alleged breaches; EY gave unqualified opinions for each of those years. The court has not ruled on these allegations. On 13 May 2024 it held that the proceeding was interrupted against MB Beteiligungsgesellschaft but not against the other ten defendants, refused to restore EY's former party name after its conversion into EY GmbH & Co. KG Wirtschaftsprüfungsgesellschaft, rejecting the argument that the conversion was void, and refused to sever the proceedings against EY, MB and Braun, which would have created parallel model proceedings."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-14e97216e06a722ebc350c11","record":{"id":"display-claim-14e97216e06a722ebc350c11","kind":"analysis","text":"On 5 May 2022 the 5th commercial chamber of the Munich I regional court declared Wirecard AG's annual accounts for 2017 and 2018 void (5 HK O 15710/20). On 29 November 2024 the Frankfurt am Main higher regional court ruled, in a judgment that was not final, that the D&O insurer owed no further cover to Wirecard AG's former director of accounting, who had also been managing director of Wirecard Technologies GmbH: the insured event occurred in 2020, when the EUR 15 million limit had been fully paid out for covered costs, not in 2019 with its limit of EUR 25 million, because the circumstances he cited, critical Financial Times reporting, the Singapore investigations and a US class action, had not been properly notified to the insurer.","source_ids":["src-051","src-058"],"entity_ids":["lg-muenchen","wirecard","olg-frankfurt","wd-tech","ft"],"premise_claim_ids":["c-ins-annulment","c-civ-dno"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 5 May 2022 the 5th commercial chamber of the Munich I regional court declared Wirecard AG's annual accounts for 2017 and 2018 void (5 HK O 15710/20). On 29 November 2024 the Frankfurt am Main higher regional court ruled, in a judgment that was not final, that the D&O insurer owed no further cover to Wirecard AG's former director of accounting, who had also been managing director of Wirecard Technologies GmbH: the insured event occurred in 2020, when the EUR 15 million limit had been fully paid out for covered costs, not in 2019 with its limit of EUR 25 million, because the circumstances he cited, critical Financial Times reporting, the Singapore investigations and a US class action, had not been properly notified to the insurer."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-e228767fd17d41102ad63bca","record":{"id":"display-claim-e228767fd17d41102ad63bca","kind":"analysis","text":"Wirecard's 2011 annual report states that the group pursued damages claims in Great Britain, in particular for fraud, against a customer and persons close to it; after a High Court judgment in London in its favour it began enforcement in 2010 and in 2011 recovered most of the money through the forced sale of a property. The report does not name the defendants. The 2019 prospectus discloses that the insolvency administrator of a former IT service provider was seeking to enforce a claim against a group company based on a 2014 confession of judgment, which Wirecard appealed on the ground that the claim had been settled; parties and outcome are not in the record.","source_ids":["src-010","src-012"],"entity_ids":["wirecard"],"premise_claim_ids":["c-lit-uk-fraud-2010","c-lit-it-provider"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard's 2011 annual report states that the group pursued damages claims in Great Britain, in particular for fraud, against a customer and persons close to it; after a High Court judgment in London in its favour it began enforcement in 2010 and in 2011 recovered most of the money through the forced sale of a property. The report does not name the defendants. The 2019 prospectus discloses that the insolvency administrator of a former IT service provider was seeking to enforce a claim against a group company based on a 2014 confession of judgment, which Wirecard appealed on the ground that the claim had been settled; parties and outcome are not in the record."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-bbbff851936c8d0cfc320a7e","record":{"id":"display-claim-bbbff851936c8d0cfc320a7e","kind":"analysis","text":"According to the Federal Criminal Police Office, Jan Marsalek worked at Wirecard AG from January 2000 as a project manager for payment systems and sat on the management board from February 2010 to June 2020; as chief operating officer he was responsible for all operations including sales and, from at least 2015, chiefly for the Asian business and the third-party acquiring business. A registry aggregator links him in the German register to Wirecard AG, Click2Pay, Wirecard Global Sales, Wirecard Sales International Holding and Wirecard Technologies and to the deleted Trustpay International AG and Wirecard Technologies AG, without naming his role in each. An extract from an EY compliance check reproduced in the special investigators' report records his appointment as a director of E-Credit Plus Pte. Ltd., the later Wirecard Asia Pte. Ltd., on 18 March 2010; the date is legible only in a word-by-word recognition table, and the check's own source for the appointment is not given.","source_ids":["src-003","src-007","src-027"],"entity_ids":["marsalek","wirecard","bka","click2pay","wd-global-sales","wd-sih","wd-tech","wd-asia-pte","ey"],"premise_claim_ids":["c-mar-career","c-mar-registry","c-mar-ecredit"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to the Federal Criminal Police Office, Jan Marsalek worked at Wirecard AG from January 2000 as a project manager for payment systems and sat on the management board from February 2010 to June 2020; as chief operating officer he was responsible for all operations including sales and, from at least 2015, chiefly for the Asian business and the third-party acquiring business. A registry aggregator links him in the German register to Wirecard AG, Click2Pay, Wirecard Global Sales, Wirecard Sales International Holding and Wirecard Technologies and to the deleted Trustpay International AG and Wirecard Technologies AG, without naming his role in each. An extract from an EY compliance check reproduced in the special investigators' report records his appointment as a director of E-Credit Plus Pte. Ltd., the later Wirecard Asia Pte. Ltd., on 18 March 2010; the date is legible only in a word-by-word recognition table, and the check's own source for the appointment is not given."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-5a7e3f8f4951dfdd8b5c9cb5","record":{"id":"display-claim-5a7e3f8f4951dfdd8b5c9cb5","kind":"analysis","text":"Ireland's Corporate Enforcement Authority reports that the liquidators of Wirecard UK & Ireland Limited recommended disqualifying its two remaining directors, Marsalek (spelt \"Marsalak\"), its chief executive and the group's chief operating officer, and Markus-Konrad Fuchs, its sales director and the group's head of sales and acquiring. Because of the grave nature of the allegations the authority declined to offer them undertakings and had the liquidators seek disqualification in the High Court; Fuchs was disqualified for nine years, while the case against Marsalek was adjourned with liberty to re-enter because he could not be served.","source_ids":["src-044"],"entity_ids":["cea-ireland","wd-uki","marsalek","fuchs","wirecard"],"premise_claim_ids":["c-mar-ireland"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Ireland's Corporate Enforcement Authority reports that the liquidators of Wirecard UK & Ireland Limited recommended disqualifying its two remaining directors, Marsalek (spelt \"Marsalak\"), its chief executive and the group's chief operating officer, and Markus-Konrad Fuchs, its sales director and the group's head of sales and acquiring. Because of the grave nature of the allegations the authority declined to offer them undertakings and had the liquidators seek disqualification in the High Court; Fuchs was disqualified for nine years, while the case against Marsalek was adjourned with liberty to re-enter because he could not be served."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-4ab579e6bb821d5e8fbbe978","record":{"id":"display-claim-4ab579e6bb821d5e8fbbe978","kind":"analysis","text":"The Munich I public prosecutor is investigating Marsalek on suspicion of professional gang fraud, aggravated breach of trust and other offences, and the Federal Criminal Police Office and Munich police have issued a public appeal for his arrest and consider it very likely that he is abroad; the office also suspects him of having bought shares in a company at an inflated price, contrary to his duties to the group. These are suspicions, not charges proved in court. A sanctions and wanted-persons database repeats the official notices, including INTERPOL's red notices, with the alternative names Alexander Michaelowitsch Nelidov and German Baschenow recorded in them.","source_ids":["src-003","src-004"],"entity_ids":["sta-muenchen","bka","marsalek","wirecard"],"premise_claim_ids":["c-crim-marsalek-wanted","c-mar-screening"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The Munich I public prosecutor is investigating Marsalek on suspicion of professional gang fraud, aggravated breach of trust and other offences, and the Federal Criminal Police Office and Munich police have issued a public appeal for his arrest and consider it very likely that he is abroad; the office also suspects him of having bought shares in a company at an inflated price, contrary to his duties to the group. These are suspicions, not charges proved in court. A sanctions and wanted-persons database repeats the official notices, including INTERPOL's red notices, with the alternative names Alexander Michaelowitsch Nelidov and German Baschenow recorded in them."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-0d495254124045eb25ba2fde","record":{"id":"display-claim-0d495254124045eb25ba2fde","kind":"analysis","text":"An investigation published on 18 July 2020 by an investigative outlet with two partner media, based on Russian and Belarusian border data, reported that Marsalek entered Belarus by private jet in the first minutes of 19 June 2020 and, according to the records, never left, and that Philippine records of a trip to Manila on 23 June had been a red herring. A second investigation, published on 19 July 2022 with a German newspaper, reported that a request for special handling at Minsk airport attached a copy of a Grenadian diplomatic passport in his name, and that his escape was organised by Martin Weiss, a former head of operations of Austria's BVT intelligence agency, and the former Freedom Party MP Thomas Schellenbacher, who chartered the jet. These are media findings with no official confirmation or response from the persons named in the record. He remains wanted: the Federal Criminal Police Office asks for information on his whereabouts since June 2020, and a 2024 order of the Bavarian Supreme Regional Court lists him as of unknown whereabouts.","source_ids":["src-075","src-003","src-102","src-086"],"entity_ids":["marsalek","bka","bayoblg","weiss","schellenbacher"],"premise_claim_ids":["c-mar-belarus","c-mar-flight"],"qualification":"","response":"","outcome":""},"reading":"Analysis: An investigation published on 18 July 2020 by an investigative outlet with two partner media, based on Russian and Belarusian border data, reported that Marsalek entered Belarus by private jet in the first minutes of 19 June 2020 and, according to the records, never left, and that Philippine records of a trip to Manila on 23 June had been a red herring. A second investigation, published on 19 July 2022 with a German newspaper, reported that a request for special handling at Minsk airport attached a copy of a Grenadian diplomatic passport in his name, and that his escape was organised by Martin Weiss, a former head of operations of Austria's BVT intelligence agency, and the former Freedom Party MP Thomas Schellenbacher, who chartered the jet. These are media findings with no official confirmation or response from the persons named in the record. He remains wanted: the Federal Criminal Police Office asks for information on his whereabouts since June 2020, and a 2024 order of the Bavarian Supreme Regional Court lists him as of unknown whereabouts."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-e3d425da7e82085d5c3e9c50","record":{"id":"display-claim-e3d425da7e82085d5c3e9c50","kind":"analysis","text":"The 2020 investigation reported that Marsalek travelled to Russia more than 60 times in ten years, that the FSB border service refused to let him leave Moscow on a private jet on 15 September 2017 and that an FSB database tracked his international trips from 2015 to 2018, which the outlet interprets as a special interest of the FSB; it also reported that from 2015 he pursued projects in Libya with a Russian adviser whom, according to the outlet, Western intelligence services believe to be a former senior GRU officer; no response from Marsalek to that account is in the record. The 2022 investigation reported that he lives in Moscow under FSB protection, acquired Russian citizenship in 2021 and later took the identity of \"German Bazhenov\", which the outlet could only partly verify; it notes that he has consistently denied any links with Russian intelligence.","source_ids":["src-075","src-086"],"entity_ids":["marsalek","fsb","libya-cement"],"premise_claim_ids":["c-mar-russia-travel","c-mar-libya","c-mar-russia-identity"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The 2020 investigation reported that Marsalek travelled to Russia more than 60 times in ten years, that the FSB border service refused to let him leave Moscow on a private jet on 15 September 2017 and that an FSB database tracked his international trips from 2015 to 2018, which the outlet interprets as a special interest of the FSB; it also reported that from 2015 he pursued projects in Libya with a Russian adviser whom, according to the outlet, Western intelligence services believe to be a former senior GRU officer; no response from Marsalek to that account is in the record. The 2022 investigation reported that he lives in Moscow under FSB protection, acquired Russian citizenship in 2021 and later took the identity of \"German Bazhenov\", which the outlet could only partly verify; it notes that he has consistently denied any links with Russian intelligence."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-adc62ae3e42bdb2021f328c2","record":{"id":"display-claim-adc62ae3e42bdb2021f328c2","kind":"analysis","text":"In sentencing remarks of 12 May 2025 in R v Roussev and others at the Central Criminal Court, a case of conspiracy to spy for Russia, the judge recorded the prosecution's case that the Russian agent using the alias \"Rupert Ticz\" was Marsalek, who had fled Germany to avoid arrest for fraud, and that his messages to Orlin Roussev referred to the GRU, FSB and KGB; Roussev's plea did not accept the identification but agreed it did not matter. The remarks record that in February 2022 Marsalek messaged Roussev about applying for EUR 1 million as a \"search and capture budget\" for a target, evidence of substantial cryptocurrency payments from Marsalek to Roussev, and discussions in 2021 about surveilling the investigative journalist Christo Grozev and kidnapping him to Moscow.","source_ids":["src-037"],"entity_ids":["marsalek","roussev","fsb"],"premise_claim_ids":["c-mar-uk-trial","c-mar-uk-trial-tasks"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In sentencing remarks of 12 May 2025 in R v Roussev and others at the Central Criminal Court, a case of conspiracy to spy for Russia, the judge recorded the prosecution's case that the Russian agent using the alias \"Rupert Ticz\" was Marsalek, who had fled Germany to avoid arrest for fraud, and that his messages to Orlin Roussev referred to the GRU, FSB and KGB; Roussev's plea did not accept the identification but agreed it did not matter. The remarks record that in February 2022 Marsalek messaged Roussev about applying for EUR 1 million as a \"search and capture budget\" for a target, evidence of substantial cryptocurrency payments from Marsalek to Roussev, and discussions in 2021 about surveilling the investigative journalist Christo Grozev and kidnapping him to Moscow."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-4bd9d2b4e98788721327ab18","record":{"id":"display-claim-4bd9d2b4e98788721327ab18","kind":"analysis","text":"Wirecard's 2011 annual report gives 1 October 2004 as the start of Dr. Markus Braun's membership of the management board, where he was chairman and responsible for technology; the supervisory board reappointed him with his colleagues from 2012. His holding company, MB Beteiligungsgesellschaft mbH, was registered in Munich under HRB 152399 on 11 May 2004 with capital of EUR 25,000; it later moved its seat to Limburg an der Lahn, where an aggregator shows it under HRB 6968 with the Legal Entity Identifier 529900W00T44TXFNWF20, and a subsidiary's register page lists it at Wirecard AG's address in Aschheim. The 2011 annual report discloses that Wirecard AG had lent the company, whose sole shareholder was Braun, EUR 235,000 at the end of 2010, rising to EUR 241,000 during 2011 before full repayment that year. Wirecard announced on 30 June 2020 that Braun had resigned from the management board by mutual consent with immediate effect on 19 June 2020 and that his employment contract had been terminated.","source_ids":["src-010","src-017","src-016","src-091","src-048"],"entity_ids":["wirecard","braun","ley","marsalek","mb-beteiligung","click2pay"],"premise_claim_ids":["c-lead-2011-board","c-own-mb-registry","c-own-mb-loan","c-lead-2020-braun-exit"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Wirecard's 2011 annual report gives 1 October 2004 as the start of Dr. Markus Braun's membership of the management board, where he was chairman and responsible for technology; the supervisory board reappointed him with his colleagues from 2012. His holding company, MB Beteiligungsgesellschaft mbH, was registered in Munich under HRB 152399 on 11 May 2004 with capital of EUR 25,000; it later moved its seat to Limburg an der Lahn, where an aggregator shows it under HRB 6968 with the Legal Entity Identifier 529900W00T44TXFNWF20, and a subsidiary's register page lists it at Wirecard AG's address in Aschheim. The 2011 annual report discloses that Wirecard AG had lent the company, whose sole shareholder was Braun, EUR 235,000 at the end of 2010, rising to EUR 241,000 during 2011 before full repayment that year. Wirecard announced on 30 June 2020 that Braun had resigned from the management board by mutual consent with immediate effect on 19 June 2020 and that his employment contract had been terminated."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-abc19d595a8044c428550272","record":{"id":"display-claim-abc19d595a8044c428550272","kind":"analysis","text":"Braun had sold most of his 8% stake on 18 and 19 June 2020 for EUR 155 million, according to a press report of 14 July 2020; a BaFin spokesperson said the authority had filed a criminal complaint against MB Beteiligungsgesellschaft over the sale of shares for EUR 6.6 million on 24 June, the day before the insolvency filing, that sales of EUR 3.4 million two days earlier were under review, and that the June sales would be examined for possible insider trading. It was said at the time that he had to sell to meet lenders' margin calls after the share price collapse. The complaint and examination are not findings, and their outcome is not in the record. Braun had been released from custody on 22 June 2020 on bail of EUR 5 million; a press report of 1 July 2020 stated that he had pledged real estate, including a villa in Kitzbühel worth millions, without saying to whom.","source_ids":["src-063","src-034"],"entity_ids":["bafin","mb-beteiligung","braun","sta-muenchen","wirecard"],"premise_claim_ids":["c-braun-insider","c-braun-kitzbuehel"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Braun had sold most of his 8% stake on 18 and 19 June 2020 for EUR 155 million, according to a press report of 14 July 2020; a BaFin spokesperson said the authority had filed a criminal complaint against MB Beteiligungsgesellschaft over the sale of shares for EUR 6.6 million on 24 June, the day before the insolvency filing, that sales of EUR 3.4 million two days earlier were under review, and that the June sales would be examined for possible insider trading. It was said at the time that he had to sell to meet lenders' margin calls after the share price collapse. The complaint and examination are not findings, and their outcome is not in the record. Braun had been released from custody on 22 June 2020 on bail of EUR 5 million; a press report of 1 July 2020 stated that he had pledged real estate, including a villa in Kitzbühel worth millions, without saying to whom."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-3ec87c843b3df2278d548df2","record":{"id":"display-claim-3ec87c843b3df2278d548df2","kind":"analysis","text":"A technology news site, citing a newspaper, reported in July 2020 that Wirecard Bank had granted Braun a loan early in 2020, reportedly of EUR 35 million, approved according to the newspaper by the supervisory board on which Stefan Klestil sat; the supervisory board said it had not known of the loan. The record contains no bank or court document on it. The prosecution's account of the OCAP payments describes a EUR 35 million Wirecard Bank loan, cancelled as of 1 April 2020, with which Braun had refinanced a bank loan to his company and which was repaid with money from the March 2020 OCAP payment; this is an allegation the court has not ruled on.","source_ids":["src-082","src-038","src-052"],"entity_ids":["wd-bank","braun","klestil","ft","wirecard","ocap","ruprecht","sta-muenchen"],"premise_claim_ids":["c-bank-braun-loan","c-mca-ocap-flow"],"qualification":"","response":"","outcome":""},"reading":"Analysis: A technology news site, citing a newspaper, reported in July 2020 that Wirecard Bank had granted Braun a loan early in 2020, reportedly of EUR 35 million, approved according to the newspaper by the supervisory board on which Stefan Klestil sat; the supervisory board said it had not known of the loan. The record contains no bank or court document on it. The prosecution's account of the OCAP payments describes a EUR 35 million Wirecard Bank loan, cancelled as of 1 April 2020, with which Braun had refinanced a bank loan to his company and which was repaid with money from the March 2020 OCAP payment; this is an allegation the court has not ruled on."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-08be494bc7004cdc0d3e3a51","record":{"id":"display-claim-08be494bc7004cdc0d3e3a51","kind":"analysis","text":"On 9 June 2022 the Munich I regional court confirmed an attachment order of EUR 140 million against Braun (5 HK O 17659/21); the related main action (5 HK O 17452/21), which by January 2023 ran to more than 1,000 pages, ended at first instance on 5 September 2024 with an order against three former board members, identified in press reporting as Braun and the finance and product board members, to pay EUR 140 million to the insolvency administrator; the former board members argued that they had not breached their duties, or not culpably, and the judgment was not final. MB Beteiligungsgesellschaft secured loans with Braun's private assets; on 21 February 2024 the Limburg local court placed it under provisional insolvency administration with the lawyer Carsten Koch as administrator. In the suspended suits against it, claimants allege that, acting through Braun as managing director, it unlawfully helped to put his assets beyond his creditors' reach; the court has summarised this as their allegation. A registry aggregator records a liquidation entry of 25 June 2024.","source_ids":["src-051","src-102","src-091","src-103","src-062"],"entity_ids":["lg-muenchen","braun","mb-beteiligung","ag-limburg","wirecard","jaffe","ocap"],"premise_claim_ids":["c-braun-arrest","c-civ-mb-insolvency","c-mca-civil-judgment"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 9 June 2022 the Munich I regional court confirmed an attachment order of EUR 140 million against Braun (5 HK O 17659/21); the related main action (5 HK O 17452/21), which by January 2023 ran to more than 1,000 pages, ended at first instance on 5 September 2024 with an order against three former board members, identified in press reporting as Braun and the finance and product board members, to pay EUR 140 million to the insolvency administrator; the former board members argued that they had not breached their duties, or not culpably, and the judgment was not final. MB Beteiligungsgesellschaft secured loans with Braun's private assets; on 21 February 2024 the Limburg local court placed it under provisional insolvency administration with the lawyer Carsten Koch as administrator. In the suspended suits against it, claimants allege that, acting through Braun as managing director, it unlawfully helped to put his assets beyond his creditors' reach; the court has summarised this as their allegation. A registry aggregator records a liquidation entry of 25 June 2024."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-60c2730d3b946f1f67c03ba3","record":{"id":"display-claim-60c2730d3b946f1f67c03ba3","kind":"analysis","text":"In March 2022 the Munich I prosecutor charged Braun, abbreviated as \"Dr. B.\", together with the former head of accounting and the former head of the Dubai subsidiary; the indictment states the prosecution's case, which the court has to establish. The trial began on 8 December 2022, hearing dates have been set up to 23 December 2026, and no judgment had been announced by the cutoff.","source_ids":["src-038","src-051","src-054"],"entity_ids":["sta-muenchen","braun","von-erffa","bellenhaus","cardsystems-me","wirecard","lg-muenchen"],"premise_claim_ids":["c-crim-indictment-2022"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In March 2022 the Munich I prosecutor charged Braun, abbreviated as \"Dr. B.\", together with the former head of accounting and the former head of the Dubai subsidiary; the indictment states the prosecution's case, which the court has to establish. The trial began on 8 December 2022, hearing dates have been set up to 23 December 2026, and no judgment had been announced by the cutoff."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-2bae7d3bcd6dd51c2b687560","record":{"id":"display-claim-2bae7d3bcd6dd51c2b687560","kind":"analysis","text":"According to ESMA's chronology, Wirecard bought XCOM in 2006 and renamed it Wirecard Bank, obtaining Visa and Mastercard licences to issue credit cards and handle money for merchants; a European Parliament briefing describes it as holding a full German banking licence under BaFin's supervision and as a member of the private banks' deposit protection fund. The 2011 annual report calls it a principal member of MasterCard and Visa and a member of JCB, with licences for card issuing and merchant acquiring and online-acquiring licences for China UnionPay and Discover/Diners Club; the 2019 prospectus adds American Express. In the 2019 half-year report the Acquiring & Issuing segment comprised Wirecard Bank AG, Wirecard Acquiring & Issuing GmbH and the group's Turkish, Brazilian, British and North American card companies.","source_ids":["src-087","src-025","src-010","src-012","src-066"],"entity_ids":["wirecard","wd-bank","xcom","esma","europarl","bafin","unionpay","wd-acq-iss","wd-turkey","wd-brazil","wd-card-solutions","wd-north-america"],"premise_claim_ids":["c-bank-origin","c-bank-licences"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to ESMA's chronology, Wirecard bought XCOM in 2006 and renamed it Wirecard Bank, obtaining Visa and Mastercard licences to issue credit cards and handle money for merchants; a European Parliament briefing describes it as holding a full German banking licence under BaFin's supervision and as a member of the private banks' deposit protection fund. The 2011 annual report calls it a principal member of MasterCard and Visa and a member of JCB, with licences for card issuing and merchant acquiring and online-acquiring licences for China UnionPay and Discover/Diners Club; the 2019 prospectus adds American Express. In the 2019 half-year report the Acquiring & Issuing segment comprised Wirecard Bank AG, Wirecard Acquiring & Issuing GmbH and the group's Turkish, Brazilian, British and North American card companies."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-91a7db15172fee45988bf8ea","record":{"id":"display-claim-91a7db15172fee45988bf8ea","kind":"analysis","text":"On 8 May 2018 the bank applied to BaFin for approval of a restructuring that would make it a direct subsidiary of Wirecard AG, starting an owner-control procedure with the Bundesbank and the European Central Bank; approval came in January 2019, but because Wirecard missed the deadline it had to apply again in January 2020. A 2017 special audit under the minimum requirements for risk management found weaknesses in lending: no risk classification procedure for strategic loans, weaknesses in assessing collateral and debt-service capacity, incomplete financial statements for risk-relevant exposures and no evidence of regular impairment tests on collateral. The Finance Ministry's timeline lists several special audits between 2010 and 2019, including one of the lending organisation from 3 June to 21 July 2017.","source_ids":["src-069","src-073"],"entity_ids":["wd-bank","wirecard","bafin","bundesbank","ecb","bmf","bundestag"],"premise_claim_ids":["c-bank-restructuring","c-bank-marisk"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 8 May 2018 the bank applied to BaFin for approval of a restructuring that would make it a direct subsidiary of Wirecard AG, starting an owner-control procedure with the Bundesbank and the European Central Bank; approval came in January 2019, but because Wirecard missed the deadline it had to apply again in January 2020. A 2017 special audit under the minimum requirements for risk management found weaknesses in lending: no risk classification procedure for strategic loans, weaknesses in assessing collateral and debt-service capacity, incomplete financial statements for risk-relevant exposures and no evidence of regular impairment tests on collateral. The Finance Ministry's timeline lists several special audits between 2010 and 2019, including one of the lending organisation from 3 June to 21 July 2017."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-a0afa1d0692ccf2d45b9cc36","record":{"id":"display-claim-a0afa1d0692ccf2d45b9cc36","kind":"analysis","text":"On 3 June 2019, after press reports that the bank processed payments for operators of fraudulent trading sites, BaFin asked the prosecutor and the Financial Intelligence Unit (FIU) for further information; after a special anti-money-laundering audit in early July it placed the bank under intensive anti-money-laundering supervision on 15 July 2019, a classification the ministry says resulted from a differentiated risk analysis unrelated to the allegations against the parent. The FIU had received more than 500 suspicious-transaction reports from the bank about its customers and held more than 1,000 items with links to Wirecard, of which 72 were, as of 9 July 2020, possibly connected with the allegations against Wirecard AG. By decision of 13 January 2021 BaFin fined the bank EUR 60,000 under the Banking Act, final on 2 February 2021.","source_ids":["src-069","src-047"],"entity_ids":["bafin","wd-bank","fiu","bmf","wirecard"],"premise_claim_ids":["c-bank-aml","c-bank-fiu","c-bank-fine"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On 3 June 2019, after press reports that the bank processed payments for operators of fraudulent trading sites, BaFin asked the prosecutor and the Financial Intelligence Unit (FIU) for further information; after a special anti-money-laundering audit in early July it placed the bank under intensive anti-money-laundering supervision on 15 July 2019, a classification the ministry says resulted from a differentiated risk analysis unrelated to the allegations against the parent. The FIU had received more than 500 suspicious-transaction reports from the bank about its customers and held more than 1,000 items with links to Wirecard, of which 72 were, as of 9 July 2020, possibly connected with the allegations against Wirecard AG. By decision of 13 January 2021 BaFin fined the bank EUR 60,000 under the Banking Act, final on 2 February 2021."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"claims","id":"display-claim-3c7a6106ea1ae12c6cfe50d9","record":{"id":"display-claim-3c7a6106ea1ae12c6cfe50d9","kind":"analysis","text":"According to the company's statement of 25 June 2020, Wirecard Bank was not part of the insolvency proceedings and BaFin had appointed a special representative for it; the bank assured customers that their deposits were protected up to EUR 19.7 million each, and the service provider Xolo stopped opening new Wirecard Bank accounts for Estonian e-residents. A news report of 2 July 2020 citing insiders said Deutsche Bank intended to help the still solvent bank and was positioning itself for a possible takeover, that the Bundesbank had been installed as special representative to ensure that no funds flowed to the parent, and that Aldi Süd had moved its customers' card payments to Payone; no statement by Deutsche Bank is in the record. No takeover by Deutsche Bank followed, and the bank was later renamed WDB Abwicklungs AG.","source_ids":["src-088","src-025","src-076","src-065"],"entity_ids":["wd-bank","bafin","europarl","xolo","wirecard","deutsche-bank","bundesbank","aldi-sued","payone"],"premise_claim_ids":["c-bank-after-insolvency","c-bank-customers-2020"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to the company's statement of 25 June 2020, Wirecard Bank was not part of the insolvency proceedings and BaFin had appointed a special representative for it; the bank assured customers that their deposits were protected up to EUR 19.7 million each, and the service provider Xolo stopped opening new Wirecard Bank accounts for Estonian e-residents. A news report of 2 July 2020 citing insiders said Deutsche Bank intended to help the still solvent bank and was positioning itself for a possible takeover, that the Bundesbank had been installed as special representative to ensure that no funds flowed to the parent, and that Aldi Süd had moved its customers' card payments to Payone; no statement by Deutsche Bank is in the record. No takeover by Deutsche Bank followed, and the bank was later renamed WDB Abwicklungs AG."}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"wirecard","record":{"id":"wirecard","name":"Wirecard AG","type":"organization","group":"subject","claim_ids":["c-id-registration","c-id-guarantor-leis","c-id-identifiers","c-id-names","c-id-purpose","c-id-addresses-capital","c-id-capital-2011","c-id-mergers","c-id-dax","c-id-same-address","c-str-2010-list","c-str-2010-mergers","c-str-2011-list","c-str-2011-holdings","c-str-2011-functions","c-str-2014-count","c-str-2016-list","c-str-2017-list","c-str-2017-founded","c-str-2018-list-1","c-str-2018-list-2","c-str-2018-founded","c-str-2019-list","c-str-2019-halfyear","c-str-registry-profile","c-str-wsih-owner","c-str-wsih-control","c-str-wpsh","c-str-wuki-owner","c-str-wdtech-holding","c-str-wdtech-agreements","c-str-cardsystems-owner","c-str-processing","c-str-acq-iss-control","c-str-click2pay","c-lead-2007-board","c-lead-2010-marsalek","c-lead-2010-board","c-lead-2011-board","c-lead-pay-2010-2011","c-lead-2016-boards","c-lead-2017-boards","c-lead-2018-change","c-lead-2018-boards","c-lead-2019-boards","c-lead-2019-sb-mandates","c-lead-2011-sb","c-lead-2018-bank-sb","c-lead-sb-later","c-lead-kleingarn","c-lead-quintana","c-lead-lauterbach","c-lead-2020-suspension","c-lead-2020-braun-exit","c-lead-2020-register","c-lead-prokura-end","c-lead-other-prokura","c-own-2010","c-own-2011","c-own-mb-loan","c-own-2016-2017","c-own-2018","c-own-2019","c-own-mb-registry","c-fin-2011-loans","c-fin-syndicated-2017-2018","c-fin-rcf-2018","c-fin-2018-bank-loans","c-fin-2019-liabilities","c-fin-bond-2019","c-fin-bond-banks","c-fin-softbank","c-fin-wd-invest","c-fin-cash-pool","c-fin-2010-figures","c-fin-2016-figures","c-fin-2018-cash","c-fin-2019-halfyear","c-fin-2019-cash-composition","c-fin-2019-other","c-fin-dividend-2018","c-fin-loans-lost","c-fin-loans-callable","c-fin-creditors-committee","c-tpa-company-2017","c-tpa-company-2018","c-tpa-company-2018-segment","c-tpa-rp-scope","c-tpa-rp-two-models","c-tpa-rp-reasons","c-tpa-rp-reseller","c-tpa-rp-practice","c-tpa-rp-business-reason","c-tpa-rp-gross","c-tpa-rp-figures","c-tpa-rp-2014-2015-share","c-tpa-rp-2018-total","c-tpa-rp-collateral","c-tpa-rp-payers","c-tpa-rp-alalam-cheques","c-tpa-rp-2018-payment","c-tpa-rp-margins","c-tpa-rp-payeasy-2014","c-tpa-rp-payeasy-existence","c-tpa-rp-payeasy-figures","c-tpa-rp-payeasy-terms","c-tpa-rp-escalion","c-tpa-rp-alalam","c-tpa-rp-senjo","c-tpa-rp-kalixa","c-tpa-rp-marsalek-notes","c-tpa-rp-managers","c-tpa-rp-citadelle","c-tpa-rp-account-6010","c-tpa-rp-2018-trustee","c-tpa-rp-2019-file","c-tpa-rp-jaffe-report","c-tpa-rp-2018-contracts","c-tpa-rp-2018-tests","c-tpa-kpmg-esma","c-tpa-kpmg-trustee1","c-tpa-esma-ft-partners","c-tpa-ft-2019","c-tpa-freq-balances","c-tpa-2014-deposits","c-tpa-adhoc-2020-06-18","c-tpa-ey-informs","c-tpa-2020-06-22","c-tpa-philippines","c-tpa-ocbc","c-tpa-bka","c-tpa-alalam-liquidation","c-aud-2010-joint","c-aud-ey-tenure","c-aud-2008-mandate","c-aud-opinions-2011-2016","c-aud-unqualified-2009-2018","c-aud-2018-signatories","c-aud-2018-kam","c-aud-2018-emphasis","c-aud-materiality","c-aud-2019-refusal","c-aud-rp-concurrence","c-aud-rp-concurrence-signers","c-aud-rp-escrow-cash","c-aud-rp-fraud-risk","c-aud-rp-receivables","c-aud-rp-2015-report","c-aud-rp-2018-audit","c-aud-rp-2018-meeting","c-aud-rp-conclusion","c-aud-kpmg-timeline","c-aud-kpmg-adhoc","c-aud-kpmg-esma","c-aud-apas","c-aud-frep-aob","c-aud-bgh-files","c-sup-scope","c-sup-holding","c-sup-aml-gap","c-sup-short-ban","c-sup-fine-2019","c-sup-market-manipulation-probes","c-sup-ft-suit-2019","c-sup-mof-reports","c-sup-2020-complaints","c-sup-braun-shares","c-sup-frep-history","c-sup-frep-2014","c-sup-frep-whistleblower","c-sup-frep-ey-2016","c-sup-frep-250m","c-sup-frep-2019","c-sup-bafin-requests","c-sup-frep-ft-unaware","c-sup-frep-no-access","c-sup-frep-2020","c-sup-frep-error","c-sup-bundesanzeiger","c-sup-esma-mandate","c-sup-esma-findings","c-sup-esma-allegations","c-sup-fca","c-sup-fca-cards","c-asia-gi-retail","c-asia-gi-price","c-asia-hermes-litigation","c-asia-ring-whistleblower","c-asia-ring-mandate","c-asia-ring-2017","c-asia-ring-warning","c-asia-ring-braun","c-asia-ring-findings","c-asia-ring-opinion","c-asia-ring-marsalek","c-asia-sg-whistleblower","c-asia-sg-prospectus","c-asia-sg-ft","c-asia-restatement-2018","c-asia-restatement-2019","c-asia-sg-charges-2022","c-mca-ocap-selection","c-mca-ocap-2018-loans","c-mca-security-deposit","c-mca-wd-bank-loans","c-mca-ocap-singapore-2020","c-mca-ocap-singapore-2026","c-mca-ocap-restraint","c-mca-ocap-creditors","c-mca-civil-judgment","c-mca-civil-damage","c-mca-civil-klestil","c-ins-petition","c-ins-opening","c-ins-staff","c-ins-moelis","c-ins-santander","c-ins-brazil-railsbank","c-ins-romania","c-ins-turkey","c-ins-asia-sales","c-ins-status","c-ins-claims","c-ins-bgh-shareholders","c-ins-annulment","c-ins-court-volume","c-crim-indictment-2022","c-crim-charges-accounts","c-crim-charges-market","c-crim-charges-fraud","c-crim-trial","c-crim-ley","c-crim-knoop-steidl","c-crim-marsalek-wanted","c-crim-von-erffa-admission","c-crim-holten","c-crim-matthias","c-crim-haeuser-axtner","c-mar-career","c-mar-registry","c-mar-ireland","c-civ-kapmug-parties","c-civ-kapmug-allegations","c-braun-insider","c-civ-dno","c-bank-origin","c-bank-licences","c-bank-restructuring","c-bank-aml","c-bank-fiu","c-bank-after-insolvency","c-acq-ecredit","c-acq-2011","c-acq-newcastle","c-acq-2017","c-acq-citi-asia","c-acq-partnerships-2018","c-str-2012-control-agreements","c-str-parent-guarantees-2018","c-fin-2015-balance","c-sup-gomopa-2010","c-lit-uk-fraud-2010","c-lit-it-provider","c-aud-tpa-evidence","c-sup-esma-disclosure","c-crim-dubai-arrest","c-lead-klestil","c-bank-braun-loan"],"badges":[{"label":"Insolvency proceedings opened by the Munich court (25 August 2020)","claim_ids":["c-ins-opening"],"code":"A1","category":"FINANCIAL_DISTRESS","subject_id":"wirecard"},{"label":"EUR 1.9 billion of reported trust balances most likely did not exist (June 2020)","claim_ids":["c-tpa-adhoc-2020-06-18","c-tpa-2020-06-22"],"code":"A9","category":"FINANCIAL_DISTRESS","subject_id":"wirecard"},{"label":"BaFin criminal complaints for market manipulation; premises searched on 5 June 2020","claim_ids":["c-sup-2020-complaints"],"code":"A20","category":"CRIMINAL_PROCEEDINGS","subject_id":"wirecard"},{"label":"Annual accounts for 2017 and 2018 declared void (5 May 2022)","claim_ids":["c-ins-annulment"],"code":"A24","category":"CIVIL_LITIGATION","subject_id":"wirecard"},{"label":"BaFin fine of EUR 1.52 million for reporting breaches (15 April 2019)","claim_ids":["c-sup-fine-2019"],"code":"A25","category":"REGULATORY_ACTION","subject_id":"wirecard"},{"label":"Press reports on suspected forgery in Singapore and on opaque TPA partners (2019)","claim_ids":["c-asia-sg-ft","c-tpa-ft-2019"],"code":"A34","category":"ADVERSE_MEDIA","subject_id":"wirecard"}],"subtype":"company","jurisdiction":"de","aliases":["Wire Card AG","InfoGenie Europe AG"],"identifiers":[{"scheme":"lei","value":"529900A8LX4KL0YUTH71"},{"scheme":"company_register","value":"HRB 169227","issuer":"Amtsgericht München (commercial register)"},{"scheme":"other","value":"DE0007472060","issuer":"International Securities Identification Number (ordinary shares)"}],"role":"","period":""},"reading":"Wirecard AG (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"wd-acq-iss","record":{"id":"wd-acq-iss","name":"Wirecard Acquiring & Issuing GmbH","type":"organization","group":"group_companies","claim_ids":["c-id-same-address","c-str-2010-list","c-str-2011-list","c-str-2011-holdings","c-str-2018-list-2","c-str-acq-iss-history","c-str-acq-iss-control","c-lead-acqiss-2005","c-lead-acqiss-officers","c-ins-moelis","c-bank-licences","c-str-2012-control-agreements"],"subtype":"company","jurisdiction":"de","aliases":["Wire Card Beteiligungs GmbH","Blitz 05-059 GmbH"],"identifiers":[{"scheme":"company_register","value":"HRB 156848","issuer":"Amtsgericht München (commercial register)"}],"role":"","period":""},"reading":"Wirecard Acquiring & Issuing GmbH (organization)"}
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{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"ing-diba","record":{"id":"ing-diba","name":"ING-DiBa AG","type":"organization","group":"counterparties","claim_ids":["c-fin-rcf-2018","c-fin-loans-callable"],"subtype":"company","jurisdiction":"de","role":"","period":""},"reading":"ING-DiBa AG (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"ing","record":{"id":"ing","name":"ING","type":"organization","group":"counterparties","claim_ids":["c-fin-bond-banks","c-fin-creditors-committee"],"subtype":"company","role":"","period":""},"reading":"ING (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"lbbw","record":{"id":"lbbw","name":"Landesbank Baden-Württemberg","type":"organization","group":"counterparties","claim_ids":["c-fin-rcf-2018","c-fin-loans-callable","c-fin-creditors-committee"],"subtype":"company","jurisdiction":"de","aliases":["LBBW"],"role":"","period":""},"reading":"Landesbank Baden-Württemberg (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"cacib","record":{"id":"cacib","name":"Crédit Agricole Corporate and Investment Bank","type":"organization","group":"counterparties","claim_ids":["c-fin-bond-banks"],"subtype":"company","jurisdiction":"fr","role":"","period":""},"reading":"Crédit Agricole Corporate and Investment Bank (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"credit-suisse","record":{"id":"credit-suisse","name":"Credit Suisse","type":"organization","group":"counterparties","claim_ids":["c-fin-bond-banks"],"subtype":"company","role":"","period":""},"reading":"Credit Suisse (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"deutsche-bank","record":{"id":"deutsche-bank","name":"Deutsche Bank AG","type":"organization","group":"counterparties","claim_ids":["c-fin-bond-banks","c-bank-customers-2020"],"subtype":"company","jurisdiction":"de","role":"","period":""},"reading":"Deutsche Bank AG (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"lloyds-cm","record":{"id":"lloyds-cm","name":"Lloyds Bank Corporate Markets Wertpapierhandelsbank","type":"organization","group":"counterparties","claim_ids":["c-fin-bond-banks"],"subtype":"company","jurisdiction":"de","role":"","period":""},"reading":"Lloyds Bank Corporate Markets Wertpapierhandelsbank (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"bank-sarasin","record":{"id":"bank-sarasin","name":"Bank Sarasin AG","type":"organization","group":"counterparties","claim_ids":["c-lead-2011-sb"],"subtype":"company","jurisdiction":"ch","role":"","period":""},"reading":"Bank Sarasin AG (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"ocbc","record":{"id":"ocbc","name":"Oversea-Chinese Banking Corporation","type":"organization","group":"counterparties","claim_ids":["c-tpa-rp-2018-trustee","c-tpa-ocbc"],"subtype":"company","jurisdiction":"sg","role":"","period":""},"reading":"Oversea-Chinese Banking Corporation (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"bdo","record":{"id":"bdo","name":"BDO Unibank, Inc.","type":"organization","group":"counterparties","claim_ids":["c-tpa-rp-2019-file","c-tpa-philippines"],"subtype":"company","jurisdiction":"ph","role":"","period":""},"reading":"BDO Unibank, Inc. (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"bpi","record":{"id":"bpi","name":"Bank of the Philippine Islands","type":"organization","group":"counterparties","claim_ids":["c-tpa-rp-2019-file","c-tpa-philippines"],"subtype":"company","jurisdiction":"ph","role":"","period":""},"reading":"Bank of the Philippine Islands (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"alken","record":{"id":"alken","name":"Alken Luxembourg S.A.","type":"organization","group":"counterparties","claim_ids":["c-own-2016-2017"],"subtype":"company","jurisdiction":"lu","role":"","period":""},"reading":"Alken Luxembourg S.A. (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"intertrust-lux","record":{"id":"intertrust-lux","name":"Intertrust (Luxembourg) S.à r.l.","type":"organization","group":"counterparties","claim_ids":["c-fin-wd-invest-managers"],"subtype":"company","jurisdiction":"lu","role":"","period":""},"reading":"Intertrust (Luxembourg) S.à r.l. (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"rcs-mgmt","record":{"id":"rcs-mgmt","name":"RCS Management (Luxembourg) S.à r.l.","type":"organization","group":"counterparties","claim_ids":["c-fin-wd-invest-managers"],"subtype":"company","jurisdiction":"lu","role":"","period":""},"reading":"RCS Management (Luxembourg) S.à r.l. (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"bundesbank","record":{"id":"bundesbank","name":"Deutsche Bundesbank","type":"organization","group":"other","claim_ids":["c-bank-restructuring","c-bank-marisk","c-bank-customers-2020"],"subtype":"company","jurisdiction":"de","role":"","period":""},"reading":"Deutsche Bundesbank (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"ecb","record":{"id":"ecb","name":"European Central Bank","type":"organization","group":"other","claim_ids":["c-bank-restructuring"],"subtype":"other","role":"","period":""},"reading":"European Central Bank (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"al-alam","record":{"id":"al-alam","name":"Al Alam Solution Provider","type":"organization","group":"counterparties","claim_ids":["c-tpa-rp-two-models","c-tpa-rp-reseller","c-tpa-rp-2018-total","c-tpa-rp-collateral","c-tpa-rp-alalam-cheques","c-tpa-rp-payeasy-terms","c-tpa-rp-alalam","c-tpa-rp-no-accounts","c-tpa-rp-cqc","c-tpa-rp-marsalek-notes","c-tpa-rp-confirmations-2016","c-tpa-rp-2018-contracts","c-tpa-esma-ft-partners","c-tpa-ft-2019","c-tpa-alalam-liquidation","c-aud-rp-concurrence-signers","c-mca-security-deposit","c-aud-tpa-evidence"],"badges":[{"label":"In liquidation from 15 May 2020","claim_ids":["c-tpa-alalam-liquidation"],"code":"A8","category":"FINANCIAL_DISTRESS","subject_id":"al-alam"}],"subtype":"company","jurisdiction":"ae","aliases":["Al Alam Solution Provider Inc.","Al Alam Solutions Provider FZ-LLC"],"role":"","period":""},"reading":"Al Alam Solution Provider (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"payeasy","record":{"id":"payeasy","name":"PayEasy Solutions Inc.","type":"organization","group":"counterparties","claim_ids":["c-tpa-rp-two-models","c-tpa-rp-reseller","c-tpa-rp-2018-total","c-tpa-rp-collateral","c-tpa-rp-payers","c-tpa-rp-2018-payment","c-tpa-rp-payeasy-2014","c-tpa-rp-payeasy-existence","c-tpa-rp-payeasy-figures","c-tpa-rp-payeasy-terms","c-tpa-rp-escalion","c-tpa-rp-no-accounts","c-tpa-rp-cqc","c-tpa-rp-marsalek-notes","c-tpa-rp-2018-contracts","c-tpa-esma-ft-partners","c-aud-rp-concurrence-signers","c-mca-wd-bank-loans","c-aud-tpa-evidence","c-aud-singapore-confirmations"],"subtype":"company","jurisdiction":"ph","aliases":["PayEasy"],"role":"","period":""},"reading":"PayEasy Solutions Inc. (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"senjo","record":{"id":"senjo","name":"Senjo Group","type":"organization","group":"counterparties","claim_ids":["c-tpa-rp-two-models","c-tpa-rp-reseller","c-tpa-rp-2018-total","c-tpa-rp-payers","c-tpa-rp-no-accounts","c-tpa-rp-cqc","c-tpa-rp-senjo","c-tpa-rp-senjo-email","c-tpa-rp-kalixa","c-tpa-rp-marsalek-notes","c-tpa-rp-confirmations-2016","c-tpa-rp-2018-contracts","c-tpa-esma-ft-partners","c-aud-rp-concurrence-signers","c-mca-wd-bank-loans","c-mca-ocap-senjo","c-aud-tpa-evidence"],"subtype":"company","jurisdiction":"sg","aliases":["Senjo"],"role":"","period":""},"reading":"Senjo Group (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"citadelle","record":{"id":"citadelle","name":"Citadelle Corporate Services Pte. Ltd.","type":"organization","group":"counterparties","claim_ids":["c-tpa-rp-senjo","c-tpa-rp-citadelle","c-tpa-rp-confirmations-2016","c-tpa-rp-confirmations-pdf","c-tpa-rp-2018-trustee","c-tpa-rp-2019-file","c-tpa-rp-jaffe-report","c-crim-charges-accounts","c-aud-tpa-evidence"],"subtype":"company","jurisdiction":"sg","role":"","period":""},"reading":"Citadelle Corporate Services Pte. Ltd. (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"ocap","record":{"id":"ocap","name":"OCAP Management Pte. Ltd.","type":"organization","group":"counterparties","claim_ids":["c-mca-ocap-selection","c-mca-ocap-2018-loans","c-mca-ocap-flow","c-mca-wd-bank-loans","c-mca-ocap-senjo","c-mca-ocap-singapore-2020","c-mca-ocap-singapore-2026","c-mca-ocap-restraint","c-mca-ocap-creditors","c-mca-civil-judgment","c-mca-civil-damage","c-mca-wah-loans","c-crim-trial","c-crim-knoop-steidl"],"badges":[{"label":"In liquidation in Singapore since December 2020","claim_ids":["c-mca-ocap-singapore-2026"],"code":"A6","category":"FINANCIAL_DISTRESS","subject_id":"ocap"},{"label":"Funds frozen in Singapore (2020) and restrained by court order (3 November 2023)","claim_ids":["c-mca-ocap-singapore-2020","c-mca-ocap-restraint"],"code":"A32","category":"ENFORCEMENT","subject_id":"ocap"}],"subtype":"company","jurisdiction":"sg","aliases":["Senjo Trading Pte. Ltd."],"role":"","period":""},"reading":"OCAP Management Pte. Ltd. (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"ocap-asia","record":{"id":"ocap-asia","name":"oCap Asia Pacific Holdings","type":"organization","group":"counterparties","claim_ids":["c-mca-ocap-singapore-2020"],"subtype":"company","role":"","period":""},"reading":"oCap Asia Pacific Holdings (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"ruprecht","record":{"id":"ruprecht","name":"Ruprecht Services Pte. Ltd.","type":"organization","group":"counterparties","claim_ids":["c-mca-ocap-flow","c-mca-security-deposit","c-mca-ruprecht-registry","c-crim-knoop-steidl"],"badges":[{"label":"Compulsory liquidation in Singapore (winding-up order of 25 February 2022)","claim_ids":["c-mca-ruprecht-registry"],"code":"A7","category":"FINANCIAL_DISTRESS","subject_id":"ruprecht"}],"subtype":"company","jurisdiction":"sg","role":"","period":""},"reading":"Ruprecht Services Pte. Ltd. (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"ressource","record":{"id":"ressource","name":"Ressource Management Systems Pte.","type":"organization","group":"counterparties","claim_ids":["c-tpa-rp-payers"],"subtype":"company","jurisdiction":"sg","role":"","period":""},"reading":"Ressource Management Systems Pte. (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"tuscany","record":{"id":"tuscany","name":"Tuscany Capital Advisors Pte. Ltd.","type":"organization","group":"counterparties","claim_ids":["c-tpa-rp-payers"],"subtype":"company","jurisdiction":"sg","role":"","period":""},"reading":"Tuscany Capital Advisors Pte. Ltd. (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"hamesh","record":{"id":"hamesh","name":"Hamesh Ltd","type":"organization","group":"counterparties","claim_ids":["c-tpa-rp-cqc"],"subtype":"company","role":"","period":""},"reading":"Hamesh Ltd (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"bonatal","record":{"id":"bonatal","name":"Bonatal Trading Industries Ltd.","type":"organization","group":"counterparties","claim_ids":["c-tpa-rp-cqc"],"subtype":"company","role":"","period":""},"reading":"Bonatal Trading Industries Ltd. (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"kalixa","record":{"id":"kalixa","name":"Kalixa Payments Group Pte. Ltd.","type":"organization","group":"counterparties","claim_ids":["c-tpa-rp-kalixa"],"subtype":"company","jurisdiction":"sg","role":"","period":""},"reading":"Kalixa Payments Group Pte. Ltd. (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"goomo","record":{"id":"goomo","name":"Goomo Holdings Pte. Ltd.","type":"organization","group":"counterparties","claim_ids":["c-mca-wd-bank-loans"],"subtype":"company","jurisdiction":"sg","aliases":["Gomoo"],"role":"","period":""},"reading":"Goomo Holdings Pte. Ltd. (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"emerging-fund","record":{"id":"emerging-fund","name":"Emerging Fund1A","type":"organization","group":"counterparties","claim_ids":["c-asia-gi-price","c-asia-ring-whistleblower"],"subtype":"company","role":"","period":""},"reading":"Emerging Fund1A (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"gi-retail","record":{"id":"gi-retail","name":"Great Indian Retail Group","type":"organization","group":"counterparties","claim_ids":["c-asia-gi-retail"],"subtype":"company","jurisdiction":"in","role":"","period":""},"reading":"Great Indian Retail Group (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"unionpay","record":{"id":"unionpay","name":"China UnionPay","type":"organization","group":"counterparties","claim_ids":["c-fin-2010-figures","c-bank-licences","c-acq-newcastle"],"subtype":"company","jurisdiction":"cn","role":"","period":""},"reading":"China UnionPay (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"newcastle-bs","record":{"id":"newcastle-bs","name":"Newcastle Building Society","type":"organization","group":"counterparties","claim_ids":["c-acq-newcastle"],"subtype":"company","jurisdiction":"gb","role":"","period":""},"reading":"Newcastle Building Society (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"caps","record":{"id":"caps","name":"Crédit Agricole Payment Services","type":"organization","group":"counterparties","claim_ids":["c-acq-partnerships-2018"],"subtype":"company","jurisdiction":"fr","role":"","period":""},"reading":"Crédit Agricole Payment Services (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"mizuho","record":{"id":"mizuho","name":"Mizuho Bank","type":"organization","group":"counterparties","claim_ids":["c-acq-partnerships-2018"],"subtype":"company","jurisdiction":"jp","role":"","period":""},"reading":"Mizuho Bank (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"six","record":{"id":"six","name":"SIX Payment Services","type":"organization","group":"counterparties","claim_ids":["c-aud-rp-fraud-risk"],"subtype":"company","role":"","period":""},"reading":"SIX Payment Services (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"payoneer","record":{"id":"payoneer","name":"Payoneer","type":"organization","group":"counterparties","claim_ids":["c-sup-fca-cards"],"subtype":"company","role":"","period":""},"reading":"Payoneer (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"holvi","record":{"id":"holvi","name":"Holvi Payment Services Oy","type":"organization","group":"counterparties","claim_ids":["c-sup-fca-cards"],"subtype":"company","jurisdiction":"fi","role":"","period":""},"reading":"Holvi Payment Services Oy (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"xolo","record":{"id":"xolo","name":"Xolo","type":"organization","group":"counterparties","claim_ids":["c-bank-after-insolvency"],"subtype":"company","jurisdiction":"ee","role":"","period":""},"reading":"Xolo (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"aldi-sued","record":{"id":"aldi-sued","name":"Aldi Süd","type":"organization","group":"counterparties","claim_ids":["c-bank-customers-2020"],"subtype":"company","jurisdiction":"de","role":"","period":""},"reading":"Aldi Süd (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"payone","record":{"id":"payone","name":"Payone","type":"organization","group":"counterparties","claim_ids":["c-bank-customers-2020"],"subtype":"company","role":"","period":""},"reading":"Payone (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"santander","record":{"id":"santander","name":"Banco Santander","type":"organization","group":"counterparties","claim_ids":["c-ins-santander"],"subtype":"company","jurisdiction":"es","role":"","period":""},"reading":"Banco Santander (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"syncapay","record":{"id":"syncapay","name":"Syncapay, Inc.","type":"organization","group":"counterparties","claim_ids":["c-ins-santander"],"subtype":"company","role":"","period":""},"reading":"Syncapay, Inc. (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"pagseguro","record":{"id":"pagseguro","name":"PagSeguro Digital Ltd.","type":"organization","group":"counterparties","claim_ids":["c-ins-santander","c-ins-brazil-railsbank"],"subtype":"company","aliases":["PagSeguro"],"role":"","period":""},"reading":"PagSeguro Digital Ltd. (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"sibs","record":{"id":"sibs","name":"SIBS","type":"organization","group":"counterparties","claim_ids":["c-ins-santander","c-ins-romania"],"subtype":"company","role":"","period":""},"reading":"SIBS (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"nomu-pay","record":{"id":"nomu-pay","name":"Nomu Pay Ltd","type":"organization","group":"counterparties","claim_ids":["c-ins-turkey","c-ins-asia-sales"],"subtype":"company","jurisdiction":"ie","role":"","period":""},"reading":"Nomu Pay Ltd (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"aurin","record":{"id":"aurin","name":"AURIN Investment Group GmbH","type":"organization","group":"counterparties","claim_ids":["c-ins-cee"],"subtype":"company","jurisdiction":"de","role":"","period":""},"reading":"AURIN Investment Group GmbH (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"railsbank","record":{"id":"railsbank","name":"Railsbank Technology Limited","type":"organization","group":"counterparties","claim_ids":["c-ins-brazil-railsbank"],"subtype":"company","role":"","period":""},"reading":"Railsbank Technology Limited (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"moelis","record":{"id":"moelis","name":"Moelis & Company","type":"organization","group":"counterparties","claim_ids":["c-ins-moelis"],"subtype":"company","jurisdiction":"us","role":"","period":""},"reading":"Moelis & Company (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"deufol","record":{"id":"deufol","name":"Deufol SE","type":"organization","group":"other","claim_ids":["c-lead-2019-sb-mandates","c-lead-2011-sb"],"subtype":"company","jurisdiction":"de","role":"","period":""},"reading":"Deufol SE (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"diamos","record":{"id":"diamos","name":"Diamos AG","type":"organization","group":"other","claim_ids":["c-lead-2011-sb"],"subtype":"company","role":"","period":""},"reading":"Diamos AG (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"belview","record":{"id":"belview","name":"Belview Partners GmbH","type":"organization","group":"other","claim_ids":["c-lead-2019-sb-mandates","c-lead-2011-sb"],"subtype":"company","role":"","period":""},"reading":"Belview Partners GmbH (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"speedinvest","record":{"id":"speedinvest","name":"Speedinvest GmbH","type":"organization","group":"other","claim_ids":["c-lead-2019-sb-mandates","c-lead-klestil"],"subtype":"company","jurisdiction":"at","role":"","period":""},"reading":"Speedinvest GmbH (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"easyjet","record":{"id":"easyjet","name":"easyJet plc","type":"organization","group":"other","claim_ids":["c-lead-lauterbach"],"subtype":"company","jurisdiction":"gb","role":"","period":""},"reading":"easyJet plc (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"dun-bradstreet","record":{"id":"dun-bradstreet","name":"The Dun & Bradstreet Corp.","type":"organization","group":"other","claim_ids":["c-lead-lauterbach"],"subtype":"company","jurisdiction":"us","role":"","period":""},"reading":"The Dun & Bradstreet Corp. (organization)"}
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{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"gomopa","record":{"id":"gomopa","name":"gomoPa","type":"organization","group":"other","claim_ids":["c-sup-gomopa-2010"],"subtype":"other","role":"","period":""},"reading":"gomoPa (organization)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"roussev","record":{"id":"roussev","name":"Orlin Roussev","type":"person","group":"other","claim_ids":["c-mar-uk-trial","c-mar-uk-trial-tasks"],"subtype":"person","role":"","period":""},"reading":"Orlin Roussev (person)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"weiss","record":{"id":"weiss","name":"Martin Weiss","type":"person","group":"other","claim_ids":["c-mar-flight"],"subtype":"person","role":"","period":""},"reading":"Martin Weiss (person)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"schellenbacher","record":{"id":"schellenbacher","name":"Thomas Schellenbacher","type":"person","group":"other","claim_ids":["c-mar-flight"],"subtype":"person","role":"","period":""},"reading":"Thomas Schellenbacher (person)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"rajaratnam","record":{"id":"rajaratnam","name":"Shan Rajaratnam","type":"person","group":"other","claim_ids":["c-tpa-rp-senjo","c-tpa-rp-confirmations-2016"],"subtype":"person","aliases":["R. Shanmugaratnam"],"role":"","period":""},"reading":"Shan Rajaratnam (person)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"tolentino","record":{"id":"tolentino","name":"M. K. Tolentino","type":"person","group":"other","claim_ids":["c-tpa-rp-2019-file"],"subtype":"person","role":"","period":""},"reading":"M. K. Tolentino (person)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"kurniawan","record":{"id":"kurniawan","name":"Edo Kurniawan","type":"person","group":"other","claim_ids":["c-asia-sg-charges-2022","c-asia-sg-convictions-2023","c-asia-kurniawan-wanted"],"badges":[{"label":"Wanted in Singapore (arrest warrant and INTERPOL red notice, 2023)","claim_ids":["c-asia-kurniawan-wanted"],"code":"A15","category":"CRIMINAL_PROCEEDINGS","subject_id":"kurniawan"}],"subtype":"person","role":"","period":""},"reading":"Edo Kurniawan (person)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"gray","record":{"id":"gray","name":"Alison Gray","type":"person","group":"other","claim_ids":["c-aud-iaasa"],"badges":[{"label":"IAASA settlement: severe reprimand and fine for the audit of Wirecard UK and Ireland","claim_ids":["c-aud-iaasa"],"code":"A29","category":"REGULATORY_ACTION","subject_id":"gray"}],"subtype":"person","role":"","period":""},"reading":"Alison Gray (person)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"entities","id":"kelly","record":{"id":"kelly","name":"Tony Kelly","type":"person","group":"other","claim_ids":["c-aud-iaasa"],"badges":[{"label":"IAASA settlement: severe reprimand and fine for the audit of Wirecard UK and Ireland","claim_ids":["c-aud-iaasa"],"code":"A29","category":"REGULATORY_ACTION","subject_id":"kelly"}],"subtype":"person","role":"","period":""},"reading":"Tony Kelly (person)"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-ey-wirecard","record":{"id":"r-ey-wirecard","from":"ey","to":"wirecard","status":"documented","role":"Auditor of the annual and consolidated financial statements","period":"Financial years 2009 to 2019 (joint auditor with RP Richter for 2010; opinion on 2019 refused)","claim_ids":["c-aud-ey-tenure","c-aud-2018-signatories","c-aud-2018-emphasis","c-aud-opinions-2011-2016","c-aud-2018-kam","c-tpa-adhoc-2020-06-18","c-aud-2008-mandate","c-aud-rp-concurrence","c-tpa-rp-2019-file","c-asia-ring-warning","c-asia-ring-opinion","c-asia-ring-findings","c-aud-rp-fraud-risk","c-aud-rp-receivables","c-aud-rp-escrow-cash","c-aud-rp-2015-report","c-tpa-rp-scope","c-aud-rp-conclusion","c-aud-2010-joint","c-aud-kpmg-adhoc","c-aud-rp-2018-audit","c-aud-unqualified-2009-2018","c-aud-apas","c-sup-frep-ey-2016","c-civ-kapmug-allegations","c-sup-frep-2020","c-sup-frep-no-access","c-aud-materiality","c-tpa-ey-informs","c-aud-frep-aob"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"ey → wirecard: Auditor of the annual and consolidated financial statements [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-ey-claims","record":{"id":"r-wirecard-ey-claims","from":"wirecard","to":"ey","status":"documented","role":"Claimant against its former auditor, through the insolvency administrator","period":"Decided by the Federal Court of Justice on 11 December 2025","claim_ids":["c-aud-bgh-files"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"wirecard → ey: Claimant against its former auditor, through the insolvency administrator [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-payeasy","record":{"id":"r-wirecard-payeasy","from":"wirecard","to":"payeasy","status":"documented","role":"Third-party acquiring (TPA) partner in Manila; debtor and recipient of collateral in the TPA accounts","period":"Business recorded from 2014 to 2019","claim_ids":["c-tpa-rp-two-models","c-tpa-rp-reseller","c-tpa-rp-2018-total","c-aud-tpa-evidence","c-aud-rp-concurrence-signers","c-tpa-rp-collateral","c-tpa-rp-marsalek-notes","c-tpa-rp-payers","c-tpa-rp-payeasy-2014","c-tpa-rp-payeasy-existence","c-tpa-rp-payeasy-figures","c-tpa-rp-payeasy-terms","c-tpa-rp-2018-contracts","c-tpa-rp-2018-payment","c-tpa-rp-escalion","c-tpa-esma-ft-partners"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → payeasy: Third-party acquiring (TPA) partner in Manila; debtor and recipient of collateral in the TPA accounts [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-payeasy-loans","record":{"id":"r-wirecard-payeasy-loans","from":"wirecard","to":"payeasy","status":"reported","role":"Lender of loans of EUR 270 million (as stated by opposition deputies)","period":"2018","claim_ids":["c-mca-wd-bank-loans"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → payeasy: Lender of loans of EUR 270 million (as stated by opposition deputies) [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-alalam","record":{"id":"r-wirecard-alalam","from":"wirecard","to":"al-alam","status":"documented","role":"Third-party acquiring (TPA) partner in Dubai","period":"Business recorded from 2015 until the partner went into liquidation on 15 May 2020","claim_ids":["c-tpa-rp-two-models","c-tpa-rp-reseller","c-tpa-rp-2018-total","c-aud-tpa-evidence","c-tpa-rp-alalam","c-aud-rp-concurrence-signers","c-tpa-rp-alalam-cheques","c-tpa-rp-marsalek-notes","c-tpa-rp-collateral","c-tpa-rp-payeasy-terms","c-tpa-rp-2018-contracts","c-tpa-esma-ft-partners","c-tpa-ft-2019","c-tpa-alalam-liquidation"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → al-alam: Third-party acquiring (TPA) partner in Dubai [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-senjo","record":{"id":"r-wirecard-senjo","from":"wirecard","to":"senjo","status":"documented","role":"Third-party acquiring (TPA) partner in Singapore","period":"Business recorded from 2016 to 2019","claim_ids":["c-tpa-rp-two-models","c-tpa-rp-reseller","c-tpa-rp-2018-total","c-aud-tpa-evidence","c-aud-rp-concurrence-signers","c-tpa-rp-marsalek-notes","c-tpa-rp-payers","c-tpa-rp-2018-contracts","c-tpa-rp-kalixa","c-tpa-esma-ft-partners"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → senjo: Third-party acquiring (TPA) partner in Singapore [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-citadelle","record":{"id":"r-wirecard-citadelle","from":"wirecard","to":"citadelle","status":"documented","role":"Trustee of the trust accounts for the TPA business","period":"From 2015 to 20 February 2020","claim_ids":["c-tpa-rp-citadelle","c-tpa-rp-2019-file","c-tpa-rp-2018-trustee","c-crim-charges-accounts"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → citadelle: Trustee of the trust accounts for the TPA business [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-braun-wirecard","record":{"id":"r-braun-wirecard","from":"braun","to":"wirecard","status":"documented","role":"Chief executive officer (chairman of the management board) and chief technology officer","period":"From 1 October 2004 to his resignation on 19 June 2020","claim_ids":["c-lead-2020-register","c-tpa-bka","c-lead-2018-boards","c-lead-2007-board","c-lead-2011-board","c-lead-pay-2010-2011","c-lead-2019-boards","c-lead-2010-board","c-asia-ring-braun","c-lead-2020-braun-exit","c-mca-ocap-selection","c-aud-rp-2018-meeting","c-sup-braun-shares"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"braun → wirecard: Chief executive officer (chairman of the management board) and chief technology officer [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-braun-wirecard-shares","record":{"id":"r-braun-wirecard-shares","from":"braun","to":"wirecard","status":"reported","role":"Indirect shareholder (about 7%, through MB Beteiligungsgesellschaft mbH)","period":"As stated in the 2022 indictment","claim_ids":["c-crim-charges-market"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"braun → wirecard: Indirect shareholder (about 7%, through MB Beteiligungsgesellschaft mbH) [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-marsalek-wirecard","record":{"id":"r-marsalek-wirecard","from":"marsalek","to":"wirecard","status":"documented","role":"Management board member for sales, later chief operating officer","period":"From 1 February 2010 until suspended on 18 June 2020 (removal registered on 1 July 2020)","claim_ids":["c-lead-2020-register","c-mar-career","c-tpa-bka","c-lead-2018-boards","c-lead-2010-marsalek","c-lead-2011-board","c-lead-pay-2010-2011","c-lead-2019-boards","c-tpa-rp-marsalek-notes","c-lead-2010-board","c-asia-ring-marsalek","c-lead-2020-suspension","c-str-2012-control-agreements","c-tpa-rp-payeasy-existence","c-mca-security-deposit"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"marsalek → wirecard: Management board member for sales, later chief operating officer [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-marsalek-wirecard-staff","record":{"id":"r-marsalek-wirecard-staff","from":"marsalek","to":"wirecard","status":"documented","role":"Employee (project manager for payment systems) and holder of joint power of attorney","period":"From January 2000; power of attorney registered on 6 August 2007","claim_ids":["c-lead-2007-board","c-mar-career"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"marsalek → wirecard: Employee (project manager for payment systems) and holder of joint power of attorney [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-ley-wirecard","record":{"id":"r-ley-wirecard","from":"ley","to":"wirecard","status":"documented","role":"Chief financial officer (management board member for finance)","period":"From 1 January 2006 to 31 December 2017 (departure registered on 1 March 2018)","claim_ids":["c-lead-2018-change","c-lead-2011-board","c-lead-pay-2010-2011","c-aud-rp-concurrence","c-lead-2010-board","c-asia-ring-mandate","c-crim-ley"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"ley → wirecard: Chief financial officer (management board member for finance) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-ley-charges","record":{"id":"r-wirecard-ley-charges","from":"wirecard","to":"ley","status":"reported","role":"Alleged injured party in the indictment of its former chief financial officer","period":"Indictment of 12 December 2023","claim_ids":["c-crim-ley"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"wirecard → ley: Alleged injured party in the indictment of its former chief financial officer [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-von-knoop-wirecard","record":{"id":"r-von-knoop-wirecard","from":"von-knoop","to":"wirecard","status":"documented","role":"Chief financial officer (management board member for finance)","period":"From 1 January 2018 (registered on 1 March 2018) to 2020","claim_ids":["c-lead-2018-change","c-lead-2018-boards","c-crim-knoop-steidl","c-lead-2019-boards"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"von-knoop → wirecard: Chief financial officer (management board member for finance) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-steidl-wirecard","record":{"id":"r-steidl-wirecard","from":"steidl","to":"wirecard","status":"documented","role":"Management board member for products (chief product officer)","period":"From 1 January 2018 (registered on 1 March 2018) to 2020","claim_ids":["c-lead-2018-change","c-lead-2018-boards","c-crim-knoop-steidl","c-lead-2019-boards"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"steidl → wirecard: Management board member for products (chief product officer) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-matthias-wirecard","record":{"id":"r-matthias-wirecard","from":"matthias","to":"wirecard","status":"documented","role":"Chairman of the supervisory board","period":"Recorded from 2011 to 2020","claim_ids":["c-lead-2018-boards","c-lead-2011-sb","c-lead-2019-sb-mandates","c-lead-2016-boards","c-lead-2019-boards","c-crim-matthias","c-lead-2017-boards"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"matthias → wirecard: Chairman of the supervisory board [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-klestil-wirecard","record":{"id":"r-klestil-wirecard","from":"klestil","to":"wirecard","status":"documented","role":"Supervisory board member; deputy chairman from 18 June 2019","period":"Recorded from 2011 to 2020","claim_ids":["c-lead-2018-boards","c-lead-2019-sb-mandates","c-mca-civil-klestil","c-lead-2019-boards","c-lead-2017-boards"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"klestil → wirecard: Supervisory board member; deputy chairman from 18 June 2019 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-jaffe-wirecard","record":{"id":"r-jaffe-wirecard","from":"jaffe","to":"wirecard","status":"documented","role":"Insolvency administrator (preliminary administrator from 25 and 29 June 2020)","period":"From 25 August 2020","claim_ids":["c-ins-petition","c-ins-asia-sales","c-ins-opening","c-tpa-rp-jaffe-report","c-ins-status","c-ins-santander","c-ins-claims","c-mca-civil-judgment"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"jaffe → wirecard: Insolvency administrator (preliminary administrator from 25 and 29 June 2020) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-mb-wirecard","record":{"id":"r-mb-wirecard","from":"mb-beteiligung","to":"wirecard","status":"documented","role":"Largest shareholder (about 7 to 8% of the votes)","period":"Recorded from 2010 to 2019","claim_ids":["c-own-2018","c-own-2011","c-own-2019","c-own-2016-2017","c-own-2010"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"mb-beteiligung → wirecard: Largest shareholder (about 7 to 8% of the votes) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-mb-loan","record":{"id":"r-wirecard-mb-loan","from":"wirecard","to":"mb-beteiligung","status":"documented","role":"Lender of a loan (EUR 235,000 at 31 December 2010)","period":"2010 to 2011","claim_ids":["c-own-mb-loan"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → mb-beteiligung: Lender of a loan (EUR 235,000 at 31 December 2010) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-braun-mb","record":{"id":"r-braun-mb","from":"braun","to":"mb-beteiligung","status":"documented","role":"Sole shareholder; his private assets secured the company's loans","period":"Recorded from 2010 to 2024","claim_ids":["c-own-mb-loan","c-own-2019","c-braun-insider","c-sup-braun-shares","c-civ-mb-insolvency"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"braun → mb-beteiligung: Sole shareholder; his private assets secured the company's loans [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-braun-mb-md","record":{"id":"r-braun-mb-md","from":"braun","to":"mb-beteiligung","status":"documented","role":"Managing director","period":"Recorded in 2010; former managing director by 2024","claim_ids":["c-own-2010","c-civ-mb-insolvency"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"braun → mb-beteiligung: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-citigroup-wirecard","record":{"id":"r-citigroup-wirecard","from":"citigroup","to":"wirecard","status":"documented","role":"Shareholder (about 5% of the votes)","period":"Recorded from 2016 to 2019","claim_ids":["c-own-2018","c-own-2019","c-own-2016-2017"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"citigroup → wirecard: Shareholder (about 5% of the votes) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-citigroup-deals","record":{"id":"r-wirecard-citigroup-deals","from":"wirecard","to":"citigroup","status":"documented","role":"Buyer of Citi Prepaid Card Services (2017) and of Citi card-acceptance customer portfolios in Asia-Pacific (2018)","period":"2017 to 2018","claim_ids":["c-acq-citi-asia","c-acq-2017"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → citigroup: Buyer of Citi Prepaid Card Services (2017) and of Citi card-acceptance customer portfolios in Asia-Pacific (2018) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-citigroup-wirecard-bond","record":{"id":"r-citigroup-wirecard-bond","from":"citigroup","to":"wirecard","status":"documented","role":"Joint bookrunner of the 2019 bond","period":"September 2019","claim_ids":["c-fin-bond-banks"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"citigroup → wirecard: Joint bookrunner of the 2019 bond [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-ocap","record":{"id":"r-wirecard-ocap","from":"wirecard","to":"ocap","status":"documented","role":"Lender of merchant cash advance loans through Wirecard Bank AG and a subsidiary; OCAP owed the group more than 97% of its debt","period":"2018 to 2020","claim_ids":["c-mca-ocap-selection","c-mca-ocap-2018-loans","c-crim-knoop-steidl","c-mca-civil-judgment","c-mca-civil-damage","c-mca-ocap-restraint","c-mca-ocap-creditors","c-mca-ocap-singapore-2020"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → ocap: Lender of merchant cash advance loans through Wirecard Bank AG and a subsidiary; OCAP owed the group more than 97% of its debt [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-bafin-wirecard","record":{"id":"r-bafin-wirecard","from":"bafin","to":"wirecard","status":"documented","role":"Securities supervisor of the listed company (market abuse, short-selling ban); not the consolidating supervisor of the group","period":"Recorded from 2016 to 2020","claim_ids":["c-sup-short-ban","c-sup-scope","c-sup-bafin-requests","c-sup-bundesanzeiger","c-sup-esma-mandate","c-sup-mof-reports","c-sup-market-manipulation-probes","c-sup-frep-ft-unaware","c-sup-frep-250m","c-sup-holding"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"bafin → wirecard: Securities supervisor of the listed company (market abuse, short-selling ban); not the consolidating supervisor of the group [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-bafin-wirecard-enforcement","record":{"id":"r-bafin-wirecard-enforcement","from":"bafin","to":"wirecard","status":"documented","role":"Imposed a fine of EUR 1.52 million (2019) and filed criminal complaints (June 2020)","period":"15 April 2019 to 18 June 2020","claim_ids":["c-sup-fine-2019","c-sup-2020-complaints"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"bafin → wirecard: Imposed a fine of EUR 1.52 million (2019) and filed criminal complaints (June 2020) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-dpr-wirecard","record":{"id":"r-dpr-wirecard","from":"dpr","to":"wirecard","status":"documented","role":"Financial reporting enforcement examinations","period":"Recorded from 2016 to 2020","claim_ids":["c-sup-bafin-requests","c-sup-frep-2014","c-sup-frep-250m","c-sup-frep-history","c-sup-frep-2019","c-sup-frep-no-access"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"dpr → wirecard: Financial reporting enforcement examinations [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-bafin-wdbank","record":{"id":"r-bafin-wdbank","from":"bafin","to":"wd-bank","status":"documented","role":"Banking supervisor (special audits; intensive anti-money-laundering supervision from 15 July 2019; fines of EUR 60,000 in 2021)","period":"From 2006","claim_ids":["c-bank-origin","c-bank-fine","c-bank-aml","c-bank-marisk"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"unknown"},"reading":"bafin → wd-bank: Banking supervisor (special audits; intensive anti-money-laundering supervision from 15 July 2019; fines of EUR 60,000 in 2021) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdbank","record":{"id":"r-wirecard-wdbank","from":"wirecard","to":"wd-bank","status":"documented","role":"Parent company (100%)","period":"From 2006 (purchase of XCOM)","claim_ids":["c-str-2018-list-2","c-fin-2018-cash","c-bank-licences","c-str-2019-list","c-bank-origin","c-ins-staff","c-tpa-rp-business-reason","c-tpa-rp-margins","c-mca-ocap-selection","c-sup-scope","c-bank-restructuring","c-fin-2019-cash-composition","c-tpa-kpmg-esma","c-tpa-2014-deposits"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-bank: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdsih","record":{"id":"r-wirecard-wdsih","from":"wirecard","to":"wd-sih","status":"documented","role":"Parent company (100%); control and profit-transfer agreement","period":"Agreement from 10 May 2012 to 20 August 2020","claim_ids":["c-str-wsih-control","c-str-2018-list-1","c-str-2011-list","c-str-2011-holdings","c-str-wsih-owner","c-str-2010-list","c-str-registry-profile"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-sih: Parent company (100%); control and profit-transfer agreement [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdsih-wirecard-guarantee","record":{"id":"r-wdsih-wirecard-guarantee","from":"wd-sih","to":"wirecard","status":"documented","role":"Guarantor of the 2019 bond","period":"September 2019","claim_ids":["c-fin-bond-2019","c-id-guarantor-leis"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wd-sih → wirecard: Guarantor of the 2019 bond [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-acqiss","record":{"id":"r-wirecard-acqiss","from":"wirecard","to":"wd-acq-iss","status":"documented","role":"Parent company (100%); control and profit-transfer agreement","period":"Agreement from 10 May 2012 to 20 August 2020","claim_ids":["c-str-acq-iss-control","c-str-2018-list-2","c-str-2011-list","c-str-2010-list","c-ins-moelis","c-bank-licences"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-acq-iss: Parent company (100%); control and profit-transfer agreement [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-cardsystems","record":{"id":"r-wirecard-cardsystems","from":"wirecard","to":"cardsystems-me","status":"documented","role":"Indirect parent company (100%, held through Wirecard Technologies GmbH)","period":"Recorded from 2017 to 2020","claim_ids":["c-str-2018-list-2","c-tpa-company-2017","c-tpa-rp-2018-tests","c-tpa-kpmg-esma","c-tpa-ft-2019","c-tpa-alalam-liquidation"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → cardsystems-me: Indirect parent company (100%, held through Wirecard Technologies GmbH) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-cardsystems-wirecard-guarantee","record":{"id":"r-cardsystems-wirecard-guarantee","from":"cardsystems-me","to":"wirecard","status":"documented","role":"Guarantor of the 2019 bond","period":"September 2019","claim_ids":["c-fin-bond-2019","c-id-guarantor-leis"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"cardsystems-me → wirecard: Guarantor of the 2019 bond [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdtech","record":{"id":"r-wirecard-wdtech","from":"wirecard","to":"wd-tech","status":"documented","role":"Parent company (100%); control agreement of 7 May 2008 and profit-transfer agreement","period":"Until 20 August 2020","claim_ids":["c-str-wdtech-agreements","c-str-2018-list-2","c-str-wdtech-holding","c-str-registry-profile","c-tpa-kpmg-esma"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-tech: Parent company (100%); control agreement of 7 May 2008 and profit-transfer agreement [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdtech-wirecard-guarantee","record":{"id":"r-wdtech-wirecard-guarantee","from":"wd-tech","to":"wirecard","status":"documented","role":"Guarantor of the 2019 bond","period":"September 2019","claim_ids":["c-fin-bond-2019","c-id-guarantor-leis"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wd-tech → wirecard: Guarantor of the 2019 bond [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-hermes","record":{"id":"r-wirecard-hermes","from":"wirecard","to":"hermes","status":"documented","role":"Parent company (100%)","period":"From 30 December 2015","claim_ids":["c-str-2018-list-1","c-asia-hermes-litigation","c-asia-gi-retail","c-asia-ring-whistleblower","c-asia-ring-findings","c-asia-gi-price"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → hermes: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdsingapore","record":{"id":"r-wirecard-wdsingapore","from":"wirecard","to":"wd-singapore","status":"documented","role":"Parent company (100%)","period":"From 1 December 2011 (bought as Systems@Work Pte. Ltd.)","claim_ids":["c-str-2018-list-1","c-str-2011-list","c-acq-2011","c-str-2017-list"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-singapore: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdbrazil","record":{"id":"r-wirecard-wdbrazil","from":"wirecard","to":"wd-brazil","status":"documented","role":"Parent company (100%)","period":"From 2016 until the sale to PagSeguro","claim_ids":["c-str-2018-list-2","c-tpa-company-2017","c-ins-santander","c-ins-brazil-railsbank","c-bank-licences"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → wd-brazil: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdna","record":{"id":"r-wirecard-wdna","from":"wirecard","to":"wd-north-america","status":"documented","role":"Parent company (100%)","period":"From 2017 until the sale to Syncapay","claim_ids":["c-str-2018-list-2","c-str-2019-list","c-acq-2017","c-ins-santander","c-bank-licences"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → wd-north-america: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-bellenhaus-cardsystems","record":{"id":"r-bellenhaus-cardsystems","from":"bellenhaus","to":"cardsystems-me","status":"documented","role":"Managing director (director and general manager)","period":"Recorded from 2015 to 2020","claim_ids":["c-lead-cardsystems-directors","c-tpa-rp-managers","c-tpa-rp-2018-tests","c-crim-bundestag-witnesses"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"bellenhaus → cardsystems-me: Managing director (director and general manager) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-marsalek-wdsih","record":{"id":"r-marsalek-wdsih","from":"marsalek","to":"wd-sih","status":"documented","role":"Managing director with sole power of representation","period":"25 August 2010 to 14 July 2020","claim_ids":["c-lead-wsih-officers","c-str-2012-control-agreements"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"marsalek → wd-sih: Managing director with sole power of representation [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-mcwabeni-wirecard","record":{"id":"r-mcwabeni-wirecard","from":"mcwabeni","to":"wirecard","status":"documented","role":"Supervisory board member","period":"Recorded from 2016 to 2020","claim_ids":["c-lead-2018-boards","c-lead-2019-sb-mandates","c-lead-2016-boards","c-lead-2019-boards","c-lead-2017-boards"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"mcwabeni → wirecard: Supervisory board member [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-vonerffa-wdtech","record":{"id":"r-vonerffa-wdtech","from":"von-erffa","to":"wd-tech","status":"documented","role":"Managing director (joint power of attorney from 14 August 2012)","period":"5 December 2012 to 30 June 2020","claim_ids":["c-lead-wdtech-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"von-erffa → wd-tech: Managing director (joint power of attorney from 14 August 2012) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdcs","record":{"id":"r-wirecard-wdcs","from":"wirecard","to":"wd-card-solutions","status":"documented","role":"Parent company (100%)","period":"From 2011","claim_ids":["c-str-2018-list-2","c-acq-newcastle","c-str-2019-list","c-sup-fca","c-bank-licences"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-card-solutions: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdindonesia","record":{"id":"r-wirecard-wdindonesia","from":"wirecard","to":"wd-indonesia","status":"documented","role":"Parent company (100%, directly or indirectly)","period":"Until the sale announced on 16 April 2021","claim_ids":["c-str-2018-list-1","c-str-2019-list","c-ins-asia-sales","c-ins-romania","c-str-2019-halfyear"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → wd-indonesia: Parent company (100%, directly or indirectly) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-artisan-wirecard","record":{"id":"r-artisan-wirecard","from":"artisan","to":"wirecard","status":"documented","role":"Shareholder (3 to 5% of the votes)","period":"Recorded from 2016 to 2019","claim_ids":["c-own-2018","c-own-2019","c-own-2016-2017"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"artisan → wirecard: Shareholder (3 to 5% of the votes) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-click2pay","record":{"id":"r-wirecard-click2pay","from":"wirecard","to":"click2pay","status":"documented","role":"Parent company (100%); control and profit-transfer agreement","period":"Agreement from 28 May 2004 to 2020","claim_ids":["c-str-click2pay","c-str-2018-list-2","c-str-registry-profile","c-id-names"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → click2pay: Parent company (100%); control and profit-transfer agreement [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-fca-wdcs","record":{"id":"r-fca-wdcs","from":"fca","to":"wd-card-solutions","status":"documented","role":"UK regulator of the e-money firm; imposed requirements on 26 June 2020 and eased them from 29-30 June 2020","period":"June 2020","claim_ids":["c-sup-fca","c-sup-fca-cards"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"fca → wd-card-solutions: UK regulator of the e-money firm; imposed requirements on 26 June 2020 and eased them from 29-30 June 2020 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-gitech","record":{"id":"r-wirecard-gitech","from":"wirecard","to":"gi-technology","status":"documented","role":"Shareholder (60%, equity-accounted without control)","period":"From 1 March 2016","claim_ids":["c-str-2018-list-2","c-asia-gi-retail","c-str-2019-list"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → gi-technology: Shareholder (60%, equity-accounted without control) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-kleingarn-wirecard","record":{"id":"r-kleingarn-wirecard","from":"kleingarn","to":"wirecard","status":"documented","role":"Supervisory board member","period":"2016 to 31 December 2017","claim_ids":["c-lead-2017-boards","c-lead-2016-boards","c-lead-kleingarn"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"kleingarn → wirecard: Supervisory board member [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-kpmg-wirecard","record":{"id":"r-kpmg-wirecard","from":"kpmg","to":"wirecard","status":"documented","role":"Special investigator (independent special investigation)","period":"31 October 2019 to 27 April 2020","claim_ids":["c-tpa-ocbc","c-aud-kpmg-timeline","c-aud-kpmg-adhoc","c-sup-bafin-requests"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"kpmg → wirecard: Special investigator (independent special investigation) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-quintana-wirecard","record":{"id":"r-quintana-wirecard","from":"quintana","to":"wirecard","status":"documented","role":"Supervisory board member","period":"Until 6 April 2020","claim_ids":["c-lead-2018-boards","c-lead-2019-sb-mandates","c-lead-2019-boards","c-lead-quintana"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"quintana → wirecard: Supervisory board member [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-rprichter-wirecard","record":{"id":"r-rprichter-wirecard","from":"rp-richter","to":"wirecard","status":"documented","role":"Auditor; joint auditor with EY for 2010","period":"Until financial year 2010","claim_ids":["c-aud-ey-tenure","c-aud-2008-mandate","c-aud-2010-joint"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"rp-richter → wirecard: Auditor; joint auditor with EY for 2010 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-steidl-wdtech","record":{"id":"r-steidl-wdtech","from":"steidl","to":"wd-tech","status":"documented","role":"Managing director","period":"From 7 November 2017; recorded again from 2022","claim_ids":["c-lead-wdtech-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"steidl → wd-tech: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-vonerffa-wirecard","record":{"id":"r-vonerffa-wirecard","from":"von-erffa","to":"wirecard","status":"documented","role":"Head of accounting (Executive Vice President / Director Accounting) and holder of joint power of attorney","period":"Until 1 July 2020 (power of attorney deleted)","claim_ids":["c-lead-2020-register","c-aud-rp-concurrence","c-crim-von-erffa-admission"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"von-erffa → wirecard: Head of accounting (Executive Vice President / Director Accounting) and holder of joint power of attorney [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdcee","record":{"id":"r-wirecard-wdcee","from":"wirecard","to":"wd-cee","status":"documented","role":"Parent company (100%)","period":"Recorded from 2010 to 2020","claim_ids":["c-str-2018-list-1","c-str-2011-functions","c-str-2010-list"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → wd-cee: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdpsh","record":{"id":"r-wirecard-wdpsh","from":"wirecard","to":"wd-psh","status":"documented","role":"Parent company (100%); issued a letter of comfort for its liabilities","period":"Recorded from 2011 to 2019","claim_ids":["c-str-2018-list-1","c-str-parent-guarantees-2018","c-str-2011-functions"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-psh: Parent company (100%); issued a letter of comfort for its liabilities [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdpsh-wirecard-guarantee","record":{"id":"r-wdpsh-wirecard-guarantee","from":"wd-psh","to":"wirecard","status":"documented","role":"Guarantor of the 2019 bond","period":"September 2019","claim_ids":["c-fin-bond-2019","c-id-guarantor-leis"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wd-psh → wirecard: Guarantor of the 2019 bond [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdromania","record":{"id":"r-wirecard-wdromania","from":"wirecard","to":"wd-romania","status":"documented","role":"Parent company (100%, held through Wirecard Sales International Holding GmbH)","period":"Until the sale to SIBS on 28 September 2020","claim_ids":["c-str-2018-list-1","c-str-2016-list","c-str-2017-list","c-ins-santander"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → wd-romania: Parent company (100%, held through Wirecard Sales International Holding GmbH) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wduki","record":{"id":"r-wirecard-wduki","from":"wirecard","to":"wd-uki","status":"documented","role":"Parent company (100%)","period":"Recorded from 2010 to 2020","claim_ids":["c-str-2018-list-1","c-str-2011-functions","c-tpa-company-2017","c-tpa-esma-ft-partners"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-uki: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdvietnam","record":{"id":"r-wirecard-wdvietnam","from":"wirecard","to":"wd-vietnam","status":"documented","role":"Parent company (100%)","period":"Recorded from 2016 to 2020","claim_ids":["c-str-2018-list-1","c-str-2016-list","c-str-2017-list","c-ins-romania"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-vietnam: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-cardsystems-alalam","record":{"id":"r-cardsystems-alalam","from":"cardsystems-me","to":"al-alam","status":"documented","role":"TPA partner of the Dubai subsidiary; buyer of a platform under an agreement of 30 July 2018","period":"Until 2020","claim_ids":["c-tpa-rp-2018-contracts","c-tpa-alalam-liquidation"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"cardsystems-me → al-alam: TPA partner of the Dubai subsidiary; buyer of a platform under an agreement of 30 July 2018 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-beijingwd","record":{"id":"r-wirecard-beijingwd","from":"wirecard","to":"beijing-wd","status":"documented","role":"Parent company (100%, directly or indirectly)","period":"From its founding in 2019","claim_ids":["c-str-2019-list","c-str-2019-halfyear","c-str-2018-founded"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → beijing-wd: Parent company (100%, directly or indirectly) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-blackrock-wirecard","record":{"id":"r-blackrock-wirecard","from":"blackrock","to":"wirecard","status":"documented","role":"Shareholder (about 5 to 7% of the votes)","period":"Recorded from 2017 to 2019","claim_ids":["c-own-2018","c-own-2019"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"blackrock → wirecard: Shareholder (about 5 to 7% of the votes) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-blume-wdcomm","record":{"id":"r-blume-wdcomm","from":"blume","to":"wd-comm-services","status":"documented","role":"Managing director","period":"From May 2018","claim_ids":["c-lead-commservices-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"blume → wd-comm-services: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-braun-acqiss","record":{"id":"r-braun-acqiss","from":"braun","to":"wd-acq-iss","status":"documented","role":"Managing director with sole power of representation","period":"15 June 2005 to 10 April 2013","claim_ids":["c-lead-acqiss-2005","c-lead-acqiss-officers","c-str-2012-control-agreements"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"braun → wd-acq-iss: Managing director with sole power of representation [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-braun-wdcomm","record":{"id":"r-braun-wdcomm","from":"braun","to":"wd-comm-services","status":"documented","role":"Managing director","period":"Until 1 March 2010","claim_ids":["c-lead-commservices-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"braun → wd-comm-services: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-braun-wdtech","record":{"id":"r-braun-wdtech","from":"braun","to":"wd-tech","status":"documented","role":"Managing director","period":"14 August 2012 to 30 June 2020","claim_ids":["c-lead-wdtech-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"braun → wd-tech: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-eichelmann-wirecard","record":{"id":"r-eichelmann-wirecard","from":"eichelmann","to":"wirecard","status":"documented","role":"Supervisory board member","period":"From 18 June 2019","claim_ids":["c-lead-2019-sb-mandates","c-tpa-rp-2019-file","c-lead-2019-boards"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"eichelmann → wirecard: Supervisory board member [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-giphilippines","record":{"id":"r-wirecard-giphilippines","from":"wirecard","to":"gi-philippines","status":"documented","role":"Parent company (100%)","period":"From 30 December 2015","claim_ids":["c-str-2018-list-1","c-asia-gi-retail"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → gi-philippines: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-haeuserax-wdsih","record":{"id":"r-haeuserax-wdsih","from":"haeuser-axtner","to":"wd-sih","status":"documented","role":"Managing director","period":"25 August 2016 to 14 July 2020","claim_ids":["c-lead-wsih-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"haeuser-axtner → wd-sih: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-henseler-wirecard","record":{"id":"r-henseler-wirecard","from":"henseler","to":"wirecard","status":"documented","role":"Deputy chairman of the supervisory board","period":"Until 18 June 2019","claim_ids":["c-lead-2018-boards","c-lead-2019-boards","c-lead-2017-boards"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"henseler → wirecard: Deputy chairman of the supervisory board [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-holten-wdsih","record":{"id":"r-holten-wdsih","from":"holten","to":"wd-sih","status":"documented","role":"Managing director (joint power of attorney from 25 August 2010)","period":"From 25 August 2016","claim_ids":["c-lead-wsih-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"holten → wd-sih: Managing director (joint power of attorney from 25 August 2010) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-jupiter-wirecard","record":{"id":"r-jupiter-wirecard","from":"jupiter-am","to":"wirecard","status":"documented","role":"Shareholder (5 to 6% of the votes)","period":"Recorded from 2016 to 2019","claim_ids":["c-own-2018","c-own-2016-2017","c-own-2019"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"jupiter-am → wirecard: Shareholder (5 to 6% of the votes) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-klestil-wdbank","record":{"id":"r-klestil-wdbank","from":"klestil","to":"wd-bank","status":"documented","role":"Supervisory board member","period":"Recorded from 2018 to 2020","claim_ids":["c-bank-braun-loan","c-lead-klestil","c-lead-sb-later"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"klestil → wd-bank: Supervisory board member [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-kurniawan-wdasia","record":{"id":"r-kurniawan-wdasia","from":"kurniawan","to":"wd-asia-holding","status":"documented","role":"Vice President of Controlling and Finance; bank account signatory","period":"Recorded until 2020","claim_ids":["c-asia-sg-charges-2022","c-asia-kurniawan-wanted"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"kurniawan → wd-asia-holding: Vice President of Controlling and Finance; bank account signatory [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-lauterbach-wirecard","record":{"id":"r-lauterbach-wirecard","from":"lauterbach","to":"wirecard","status":"documented","role":"Supervisory board member","period":"Recorded from 2018 to 2020","claim_ids":["c-lead-2018-boards","c-lead-2019-sb-mandates","c-lead-lauterbach","c-lead-2019-boards"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"lauterbach → wirecard: Supervisory board member [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-lbbw-wirecard","record":{"id":"r-lbbw-wirecard","from":"lbbw","to":"wirecard","status":"documented","role":"Lender (mandated lead arranger of the 2018 revolving credit facility); member of the creditors' committee","period":"From 15 June 2018","claim_ids":["c-fin-rcf-2018","c-fin-loans-callable","c-fin-creditors-committee"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"lbbw → wirecard: Lender (mandated lead arranger of the 2018 revolving credit facility); member of the creditors' committee [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-marsalek-wdglobal","record":{"id":"r-marsalek-wdglobal","from":"marsalek","to":"wd-global-sales","status":"documented","role":"Managing director","period":"27 January 2016 to 30 June 2020","claim_ids":["c-lead-global-sales-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"marsalek → wd-global-sales: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-marsalek-wdtech","record":{"id":"r-marsalek-wdtech","from":"marsalek","to":"wd-tech","status":"documented","role":"Managing director","period":"14 August 2012 to 5 December 2012","claim_ids":["c-lead-wdtech-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"marsalek → wd-tech: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-moeller-wdtech","record":{"id":"r-moeller-wdtech","from":"moeller","to":"wd-tech","status":"documented","role":"Managing director","period":"5 December 2012 to 3 October 2020","claim_ids":["c-lead-wdtech-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"moeller → wd-tech: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-mygate","record":{"id":"r-wirecard-mygate","from":"wirecard","to":"mygate","status":"documented","role":"Parent company (100%)","period":"From 6 March 2017 until its merger in 2019","claim_ids":["c-str-2018-list-2","c-acq-2017","c-str-2019-halfyear"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → mygate: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-ocbc","record":{"id":"r-wirecard-ocbc","from":"wirecard","to":"ocbc","status":"refuted","role":"Bank named as holder of the trust and escrow accounts for the TPA balances; it told the administrator it never held significant sums for the trustee","period":"2018 to 2020","claim_ids":["c-tpa-ocbc","c-tpa-rp-2018-trustee"],"kind":"business","direction":"directed","role_group":"infrastructure","temporal_status":"historical"},"reading":"wirecard → ocbc: Bank named as holder of the trust and escrow accounts for the TPA balances; it told the administrator it never held significant sums for the trustee [refuted]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-procard","record":{"id":"r-wirecard-procard","from":"wirecard","to":"procard","status":"documented","role":"Parent company (100%)","period":"From 13 January 2011","claim_ids":["c-str-2011-list","c-acq-2011"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → procard: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-rajahtann","record":{"id":"r-wirecard-rajahtann","from":"wirecard","to":"rajah-tann","status":"documented","role":"Client that commissioned the law firm's investigation of the Singapore whistleblower allegations","period":"2018 to 2019","claim_ids":["c-asia-sg-whistleblower","c-aud-rp-2018-audit","c-asia-sg-prospectus","c-asia-sg-ft"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → rajah-tann: Client that commissioned the law firm's investigation of the Singapore whistleblower allegations [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-softbank-wirecard","record":{"id":"r-softbank-wirecard","from":"softbank","to":"wirecard","status":"documented","role":"Investor through an affiliate: subscriber of convertible bonds of about EUR 900 million (memorandum of understanding of April 2019)","period":"From 24 April 2019","claim_ids":["c-fin-softbank"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"softbank → wirecard: Investor through an affiliate: subscriber of convertible bonds of about EUR 900 million (memorandum of understanding of April 2019) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-steidl-wdacceptance","record":{"id":"r-steidl-wdacceptance","from":"steidl","to":"wd-acceptance-tech","status":"documented","role":"Managing director","period":"From 10 January 2018; recorded again from 2020","claim_ids":["c-lead-newsubs-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"steidl → wd-acceptance-tech: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-steidl-wdissuing","record":{"id":"r-steidl-wdissuing","from":"steidl","to":"wd-issuing-tech","status":"documented","role":"Managing director","period":"From 2 September 2017; recorded again from 2022","claim_ids":["c-lead-newsubs-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"steidl → wd-issuing-tech: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-steidl-wdservice","record":{"id":"r-steidl-wdservice","from":"steidl","to":"wd-service-tech","status":"documented","role":"Managing director","period":"From 12 January 2018; recorded again from 2022","claim_ids":["c-lead-newsubs-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"steidl → wd-service-tech: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdasiapte","record":{"id":"r-wirecard-wdasiapte","from":"wirecard","to":"wd-asia-pte","status":"documented","role":"Parent company (100%)","period":"From 28 December 2009 (bought as E-Credit Plus Pte. Ltd.)","claim_ids":["c-str-2011-list","c-acq-ecredit"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-asia-pte: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdemoneyph","record":{"id":"r-wirecard-wdemoneyph","from":"wirecard","to":"wd-emoney-ph","status":"documented","role":"Parent company (100%); founded in 2017","period":"From 2017 until the sale announced on 16 April 2021","claim_ids":["c-str-2018-list-2","c-ins-asia-sales","c-str-2017-founded"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → wd-emoney-ph: Parent company (100%); founded in 2017 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdglobal","record":{"id":"r-wirecard-wdglobal","from":"wirecard","to":"wd-global-sales","status":"documented","role":"Parent company (100%)","period":"Recorded from 2016 to 2020","claim_ids":["c-str-2018-list-1"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-global-sales: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdissuing","record":{"id":"r-wirecard-wdissuing","from":"wirecard","to":"wd-issuing-tech","status":"documented","role":"Parent company (100%); founded in 2017","period":"From 2017","claim_ids":["c-str-2018-list-2","c-str-2017-founded"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-issuing-tech: Parent company (100%); founded in 2017 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdllc","record":{"id":"r-wirecard-wdllc","from":"wirecard","to":"wd-llc","status":"documented","role":"Parent company (100%); founded in Moscow in 2018","period":"From 2018","claim_ids":["c-str-2018-list-1","c-str-2018-founded"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-llc: Parent company (100%); founded in Moscow in 2018 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdluxembourg","record":{"id":"r-wirecard-wdluxembourg","from":"wirecard","to":"wd-luxembourg","status":"documented","role":"Parent company (100%); founded in 2018","period":"From 2018","claim_ids":["c-str-2018-list-2","c-str-2018-founded"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-luxembourg: Parent company (100%); founded in 2018 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdnamibia","record":{"id":"r-wirecard-wdnamibia","from":"wirecard","to":"wd-namibia","status":"documented","role":"Parent company (100%); founded in 2018","period":"From 2018","claim_ids":["c-str-2018-list-2","c-str-2018-founded"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-namibia: Parent company (100%); founded in 2018 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdprocessing","record":{"id":"r-wirecard-wdprocessing","from":"wirecard","to":"wd-processing","status":"documented","role":"Parent company (100%, direct)","period":"Recorded from 2018 to 2019","claim_ids":["c-str-2018-list-2","c-str-processing"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-processing: Parent company (100%, direct) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdprocessing-wirecard-guarantee","record":{"id":"r-wdprocessing-wirecard-guarantee","from":"wd-processing","to":"wirecard","status":"documented","role":"Guarantor of the 2019 bond","period":"September 2019","claim_ids":["c-fin-bond-2019","c-id-guarantor-leis"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wd-processing → wirecard: Guarantor of the 2019 bond [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdservice","record":{"id":"r-wirecard-wdservice","from":"wirecard","to":"wd-service-tech","status":"documented","role":"Parent company (100%); founded in 2017","period":"From 2017","claim_ids":["c-str-2018-list-2","c-str-2017-founded"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-service-tech: Parent company (100%); founded in 2017 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdslovakia","record":{"id":"r-wirecard-wdslovakia","from":"wirecard","to":"wd-slovakia","status":"documented","role":"Parent company (100%); founded in 2018","period":"From 2018","claim_ids":["c-str-2018-list-2","c-str-2018-founded"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-slovakia: Parent company (100%); founded in 2018 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdthailand","record":{"id":"r-wirecard-wdthailand","from":"wirecard","to":"wd-thailand","status":"documented","role":"Parent company (100%); founded in 2017","period":"From 2017 until the sale announced on 16 April 2021","claim_ids":["c-str-2018-list-1","c-ins-asia-sales","c-str-2017-founded"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → wd-thailand: Parent company (100%); founded in 2017 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdturkey","record":{"id":"r-wirecard-wdturkey","from":"wirecard","to":"wd-turkey","status":"documented","role":"Indirect parent company (100%)","period":"Until the sale announced on 30 March 2021","claim_ids":["c-str-2018-list-2","c-ins-turkey","c-bank-licences"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → wd-turkey: Indirect parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdusholding","record":{"id":"r-wirecard-wdusholding","from":"wirecard","to":"wd-us-holding","status":"documented","role":"Parent company (100%, directly or indirectly); founded in 2019","period":"From 2019","claim_ids":["c-str-2019-list","c-str-2019-halfyear","c-str-2018-founded"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-us-holding: Parent company (100%, directly or indirectly); founded in 2019 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-amatthias-wdissuing","record":{"id":"r-amatthias-wdissuing","from":"a-matthias","to":"wd-issuing-tech","status":"documented","role":"Managing director (based in Singapore)","period":"28 February 2018 to 25 October 2019","claim_ids":["c-lead-newsubs-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"a-matthias → wd-issuing-tech: Managing director (based in Singapore) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-abnamro-wirecard","record":{"id":"r-abnamro-wirecard","from":"abn-amro","to":"wirecard","status":"documented","role":"Mandated lead arranger of the 2018 revolving credit facility; joint global coordinator of the 2019 bond","period":"2018 to 2019","claim_ids":["c-fin-rcf-2018","c-fin-bond-banks"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"abn-amro → wirecard: Mandated lead arranger of the 2018 revolving credit facility; joint global coordinator of the 2019 bond [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-alalam-wdbank","record":{"id":"r-alalam-wdbank","from":"al-alam","to":"wd-bank","status":"documented","role":"Account holder (accounts 60757 and 59049 at the bank)","period":"Recorded by the special investigators","claim_ids":["c-tpa-rp-alalam-cheques"],"kind":"business","direction":"directed","role_group":"infrastructure","temporal_status":"unknown"},"reading":"al-alam → wd-bank: Account holder (accounts 60757 and 59049 at the bank) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-alken-wirecard","record":{"id":"r-alken-wirecard","from":"alken","to":"wirecard","status":"documented","role":"Shareholder (about 5% of the votes)","period":"2016 to 2017","claim_ids":["c-own-2016-2017"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"alken → wirecard: Shareholder (about 5% of the votes) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-apas-wirecard","record":{"id":"r-apas-wirecard","from":"apas","to":"wirecard","status":"documented","role":"Auditor oversight body that examined the audits of Wirecard's accounts and sanctioned auditors","period":"2020 to 2023","claim_ids":["c-aud-apas"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"apas → wirecard: Auditor oversight body that examined the audits of Wirecard's accounts and sanctioned auditors [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-bdo","record":{"id":"r-wirecard-bdo","from":"wirecard","to":"bdo","status":"refuted","role":"Bank named in the 2019 trust-account balance confirmation; its name was used in false documents and Wirecard was not its client","period":"March 2020","claim_ids":["c-tpa-rp-2019-file","c-tpa-philippines"],"kind":"business","direction":"directed","role_group":"infrastructure","temporal_status":"historical"},"reading":"wirecard → bdo: Bank named in the 2019 trust-account balance confirmation; its name was used in false documents and Wirecard was not its client [refuted]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-bpi","record":{"id":"r-wirecard-bpi","from":"wirecard","to":"bpi","status":"refuted","role":"Bank named in the 2019 trust-account confirmation and statement; its name was used in false documents and Wirecard was not its client","period":"March 2020","claim_ids":["c-tpa-rp-2019-file","c-tpa-philippines"],"kind":"business","direction":"directed","role_group":"infrastructure","temporal_status":"historical"},"reading":"wirecard → bpi: Bank named in the 2019 trust-account confirmation and statement; its name was used in false documents and Wirecard was not its client [refuted]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-bellenhaus-acqiss","record":{"id":"r-bellenhaus-acqiss","from":"bellenhaus","to":"wd-acq-iss","status":"documented","role":"Managing director","period":"10 April 2013 to 20 August 2020","claim_ids":["c-lead-acqiss-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"bellenhaus → wd-acq-iss: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-bellenhaus-wirecard","record":{"id":"r-bellenhaus-wirecard","from":"bellenhaus","to":"wirecard","status":"documented","role":"Head of Wirecard AG's branch in Dubai","period":"As described in the model proceeding (2024)","claim_ids":["c-civ-kapmug-parties"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"bellenhaus → wirecard: Head of Wirecard AG's branch in Dubai [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-braun-ocap","record":{"id":"r-braun-ocap","from":"braun","to":"ocap","status":"reported","role":"Charged with embezzlement through the Wirecard group's loans to the company (EUR 210 million, as recorded by the Singapore court)","period":"Charged on 10 March 2022","claim_ids":["c-mca-ocap-flow","c-mca-ocap-restraint"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"braun → ocap: Charged with embezzlement through the Wirecard group's loans to the company (EUR 210 million, as recorded by the Singapore court) [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-brinkmann-wdcomm","record":{"id":"r-brinkmann-wdcomm","from":"brinkmann","to":"wd-comm-services","status":"documented","role":"Managing director","period":"1 March 2010 to 10-11 August 2020","claim_ids":["c-lead-commservices-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"brinkmann → wd-comm-services: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-brinkmann-wdtech","record":{"id":"r-brinkmann-wdtech","from":"brinkmann","to":"wd-tech","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"14 August 2012 to 28 August 2020","claim_ids":["c-lead-wdtech-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"brinkmann → wd-tech: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-buck-wdacceptance","record":{"id":"r-buck-wdacceptance","from":"buck","to":"wd-acceptance-tech","status":"documented","role":"Managing director","period":"10 January 2018 to 25 October 2019","claim_ids":["c-lead-newsubs-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"buck → wd-acceptance-tech: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-chaeuser-wdtech","record":{"id":"r-chaeuser-wdtech","from":"c-haeuser","to":"wd-tech","status":"documented","role":"Managing director","period":"5 December 2012 to 27 January 2018","claim_ids":["c-lead-wdtech-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"c-haeuser → wd-tech: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-heuser-click2pay","record":{"id":"r-heuser-click2pay","from":"heuser","to":"click2pay","status":"documented","role":"Liquidator","period":"30 October 2019 to 2 March 2021","claim_ids":["c-lead-click2pay-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"heuser → click2pay: Liquidator [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-holten-click2pay","record":{"id":"r-holten-click2pay","from":"holten","to":"click2pay","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"From 8 June 2005","claim_ids":["c-lead-click2pay-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"holten → click2pay: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-marsalek-click2pay","record":{"id":"r-marsalek-click2pay","from":"marsalek","to":"click2pay","status":"documented","role":"Liquidator","period":"30 October 2019 to 18 July 2020","claim_ids":["c-lead-click2pay-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"marsalek → click2pay: Liquidator [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-commerzbank-wirecard","record":{"id":"r-commerzbank-wirecard","from":"commerzbank","to":"wirecard","status":"documented","role":"Mandated lead arranger and agent of the 2018 revolving credit facility","period":"From 15 June 2018","claim_ids":["c-fin-rcf-2018","c-fin-loans-callable"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"commerzbank → wirecard: Mandated lead arranger and agent of the 2018 revolving credit facility [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-controlrisks","record":{"id":"r-wirecard-controlrisks","from":"wirecard","to":"control-risks","status":"documented","role":"Client of the forensic investigation engaged through Fieldfisher","period":"2018 to 2019","claim_ids":["c-aud-rp-2018-audit","c-asia-sg-prospectus"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → control-risks: Client of the forensic investigation engaged through Fieldfisher [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-matthias-deufol","record":{"id":"r-matthias-deufol","from":"matthias","to":"deufol","status":"documented","role":"Supervisory board member","period":"Recorded from 2011; until 24 July 2020","claim_ids":["c-lead-2011-sb"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"matthias → deufol: Supervisory board member [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-emergingfund","record":{"id":"r-wirecard-emergingfund","from":"wirecard","to":"emerging-fund","status":"reported","role":"Buyer of the Hermes group from the fund (acquisition of the Indian business)","period":"2015","claim_ids":["c-asia-ring-whistleblower","c-asia-gi-price"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → emerging-fund: Buyer of the Hermes group from the fund (acquisition of the Indian business) [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-farace-wdcs","record":{"id":"r-farace-wdcs","from":"farace","to":"wd-card-solutions","status":"documented","role":"Director","period":"From 19 August 2020","claim_ids":["c-lead-wcs-directors"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"farace → wd-card-solutions: Director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-freis-wirecard","record":{"id":"r-freis-wirecard","from":"freis","to":"wirecard","status":"documented","role":"Management board member (compliance) with sole power of representation","period":"From 18 June 2020 (registered 1 July 2020)","claim_ids":["c-lead-2020-register","c-lead-2020-suspension"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"freis → wirecard: Management board member (compliance) with sole power of representation [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-ft","record":{"id":"r-wirecard-ft","from":"wirecard","to":"ft","status":"documented","role":"Claimant in an action against the newspaper and its reporter","period":"Filed 22 March 2019; withdrawn 28 October 2020","claim_ids":["c-sup-ft-suit-2019","c-ins-court-volume"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"wirecard → ft: Claimant in an action against the newspaper and its reporter [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-goerres-wirecard","record":{"id":"r-goerres-wirecard","from":"goerres","to":"wirecard","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"6 August 2007 to 3 September 2020","claim_ids":["c-lead-prokura-end"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"goerres → wirecard: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-goldman-wirecard","record":{"id":"r-goldman-wirecard","from":"goldman","to":"wirecard","status":"documented","role":"Shareholder (3.53% of the votes)","period":"2019","claim_ids":["c-own-2019"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"goldman → wirecard: Shareholder (3.53% of the votes) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-haeuserax-wdglobal","record":{"id":"r-haeuserax-wdglobal","from":"haeuser-axtner","to":"wd-global-sales","status":"documented","role":"Managing director","period":"27 January 2016 to 30 June 2020","claim_ids":["c-lead-global-sales-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"haeuser-axtner → wd-global-sales: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-hammelbonten-wirecard","record":{"id":"r-hammelbonten-wirecard","from":"hammel-bonten","to":"wirecard","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"Recorded in the register","claim_ids":["c-lead-other-prokura"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"hammel-bonten → wirecard: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-herview","record":{"id":"r-wirecard-herview","from":"wirecard","to":"herview","status":"documented","role":"Parent company (100%)","period":"Recorded from 2011 to 2018","claim_ids":["c-str-2018-list-1","c-str-2011-functions"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → herview: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-holten-wdinvest","record":{"id":"r-holten-wdinvest","from":"holten","to":"wd-invest","status":"documented","role":"Manager (gérant)","period":"From 17 September 2019","claim_ids":["c-fin-wd-invest-managers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"holten → wd-invest: Manager (gérant) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-holten-wirecard","record":{"id":"r-holten-wirecard","from":"holten","to":"wirecard","status":"documented","role":"Treasurer; holder of joint power of attorney","period":"Until 3 September 2020 (power of attorney lapsed on insolvency)","claim_ids":["c-lead-prokura-end","c-crim-holten"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"holten → wirecard: Treasurer; holder of joint power of attorney [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-ing-wirecard","record":{"id":"r-ing-wirecard","from":"ing","to":"wirecard","status":"documented","role":"Joint bookrunner of the 2019 bond; lender represented on the creditors' committee","period":"2019 to 2020","claim_ids":["c-fin-bond-banks","c-fin-creditors-committee"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"ing → wirecard: Joint bookrunner of the 2019 bond; lender represented on the creditors' committee [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-ingdiba-wirecard","record":{"id":"r-ingdiba-wirecard","from":"ing-diba","to":"wirecard","status":"documented","role":"Mandated lead arranger of the 2018 revolving credit facility","period":"From 15 June 2018","claim_ids":["c-fin-rcf-2018","c-fin-loans-callable"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"ing-diba → wirecard: Mandated lead arranger of the 2018 revolving credit facility [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-ioannou-wdservice","record":{"id":"r-ioannou-wdservice","from":"ioannou","to":"wd-service-tech","status":"documented","role":"Managing director","period":"12 January 2018 to 12 September 2019","claim_ids":["c-lead-newsubs-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"ioannou → wd-service-tech: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-jennings-wdcs","record":{"id":"r-jennings-wdcs","from":"jennings","to":"wd-card-solutions","status":"documented","role":"Director","period":"From 8 December 2011","claim_ids":["c-lead-wcs-directors"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"jennings → wd-card-solutions: Director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdtech-2011","record":{"id":"r-wirecard-wdtech-2011","from":"wirecard","to":"wd-tech","status":"documented","role":"Parent company (100%) of the company, then Wirecard Technologies AG, which developed and ran the software platform","period":"Recorded in 2010 and 2011","claim_ids":["c-str-2011-list","c-str-2011-functions"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → wd-tech: Parent company (100%) of the company, then Wirecard Technologies AG, which developed and ran the software platform [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-klestil-speedinvest","record":{"id":"r-klestil-speedinvest","from":"klestil","to":"speedinvest","status":"reported","role":"Partner of the venture capital firm","period":"From 30 September 2014","claim_ids":["c-lead-klestil"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"klestil → speedinvest: Partner of the venture capital firm [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-krahe-wdissuing","record":{"id":"r-krahe-wdissuing","from":"krahe","to":"wd-issuing-tech","status":"documented","role":"Managing director","period":"From 2 September 2017","claim_ids":["c-lead-newsubs-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"krahe → wd-issuing-tech: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-ley-acqiss","record":{"id":"r-ley-acqiss","from":"ley","to":"wd-acq-iss","status":"documented","role":"Managing director","period":"10 April 2013 to 26 January 2018","claim_ids":["c-lead-acqiss-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"ley → wd-acq-iss: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-ley-wdcs","record":{"id":"r-ley-wdcs","from":"ley","to":"wd-card-solutions","status":"documented","role":"Director","period":"February-April 2012 to 31 December 2017 / 2 January 2018","claim_ids":["c-lead-wcs-directors"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"ley → wd-card-solutions: Director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-liebera-acqiss","record":{"id":"r-liebera-acqiss","from":"liebera","to":"wd-acq-iss","status":"documented","role":"First managing director of the shelf company Blitz 05-059 GmbH","period":"20 April to 15 June 2005","claim_ids":["c-lead-acqiss-2005"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"liebera → wd-acq-iss: First managing director of the shelf company Blitz 05-059 GmbH [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-marsalek-roussev","record":{"id":"r-marsalek-roussev","from":"marsalek","to":"roussev","status":"reported","role":"Tasked and paid him (cryptocurrency payments) for surveillance and other operations, according to the prosecution case recorded in the UK sentencing remarks","period":"August 2020 to February 2023","claim_ids":["c-mar-uk-trial","c-mar-uk-trial-tasks"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"marsalek → roussev: Tasked and paid him (cryptocurrency payments) for surveillance and other operations, according to the prosecution case recorded in the UK sentencing remarks [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-matthias-wdbank","record":{"id":"r-matthias-wdbank","from":"matthias","to":"wd-bank","status":"documented","role":"Supervisory board member, later chairman","period":"Recorded from 2011 to 2020","claim_ids":["c-lead-2018-bank-sb","c-lead-sb-later"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"matthias → wd-bank: Supervisory board member, later chairman [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-neeff-wdservice","record":{"id":"r-neeff-wdservice","from":"neeff","to":"wd-service-tech","status":"documented","role":"Managing director","period":"27 January 2018 to 18 April 2019","claim_ids":["c-lead-newsubs-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"neeff → wd-service-tech: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-pagseguro","record":{"id":"r-wirecard-pagseguro","from":"wirecard","to":"pagseguro","status":"documented","role":"Seller of Wirecard Brazil to a PagSeguro subsidiary","period":"Agreement announced in 2020; sale completed by January 2021","claim_ids":["c-ins-santander","c-ins-brazil-railsbank"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → pagseguro: Seller of Wirecard Brazil to a PagSeguro subsidiary [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-plaenitz-wdcomm","record":{"id":"r-plaenitz-wdcomm","from":"plaenitz","to":"wd-comm-services","status":"documented","role":"Managing director","period":"30 March 2009 to 15 May 2018","claim_ids":["c-lead-commservices-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"plaenitz → wd-comm-services: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-primavista","record":{"id":"r-wirecard-primavista","from":"wirecard","to":"prima-vista","status":"documented","role":"Parent company (100%)","period":"Recorded from 2018 to 2020","claim_ids":["c-str-2018-list-1","c-ins-romania"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → prima-vista: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-ressource-wirecard","record":{"id":"r-ressource-wirecard","from":"ressource","to":"wirecard","status":"documented","role":"Third party that paid amounts on behalf of PayEasy (EUR 23.0 million on 30 December 2014)","period":"2014","claim_ids":["c-tpa-rp-payers"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"ressource → wirecard: Third party that paid amounts on behalf of PayEasy (EUR 23.0 million on 30 December 2014) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-ruprecht","record":{"id":"r-wirecard-ruprecht","from":"wirecard","to":"ruprecht","status":"reported","role":"Granted a \"security deposit\" of EUR 40 million through subsidiaries; Ruprecht was presented as TPA partner from December 2019 (prosecution account)","period":"December 2019","claim_ids":["c-mca-security-deposit","c-crim-knoop-steidl"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → ruprecht: Granted a \"security deposit\" of EUR 40 million through subsidiaries; Ruprecht was presented as TPA partner from December 2019 (prosecution account) [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-sankar-wdacceptance","record":{"id":"r-sankar-wdacceptance","from":"sankar","to":"wd-acceptance-tech","status":"documented","role":"Managing director","period":"From 10 January 2018","claim_ids":["c-lead-newsubs-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"sankar → wd-acceptance-tech: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-sankar-wdissuing","record":{"id":"r-sankar-wdissuing","from":"sankar","to":"wd-issuing-tech","status":"documented","role":"Managing director","period":"2 September 2017 to 30 January 2018","claim_ids":["c-lead-newsubs-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"sankar → wd-issuing-tech: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-schotte-acqiss","record":{"id":"r-schotte-acqiss","from":"schotte","to":"wd-acq-iss","status":"documented","role":"Sole managing director","period":"From 2 September 2020","claim_ids":["c-lead-acqiss-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"current"},"reading":"schotte → wd-acq-iss: Sole managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-steidl-acqiss","record":{"id":"r-steidl-acqiss","from":"steidl","to":"wd-acq-iss","status":"documented","role":"Managing director","period":"10 April 2013 to 2 September 2020","claim_ids":["c-lead-acqiss-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"steidl → wd-acq-iss: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-steinhoff-wirecard","record":{"id":"r-steinhoff-wirecard","from":"steinhoff","to":"wirecard","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"30 October 2019 to 3 September 2020","claim_ids":["c-lead-prokura-end"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"steinhoff → wirecard: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-tschmidt-wdservice","record":{"id":"r-tschmidt-wdservice","from":"t-schmidt","to":"wd-service-tech","status":"documented","role":"Managing director","period":"From 16 May 2019","claim_ids":["c-lead-newsubs-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"t-schmidt → wd-service-tech: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-translaos","record":{"id":"r-wirecard-translaos","from":"wirecard","to":"trans-laos","status":"documented","role":"Parent company (100%)","period":"Recorded in 2016 and 2017","claim_ids":["c-str-2016-list","c-str-2017-list"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → trans-laos: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-trautmann-wirecard","record":{"id":"r-trautmann-wirecard","from":"trautmann","to":"wirecard","status":"documented","role":"Management board member","period":"Registered on 6 August 2007; left by 31 January 2010","claim_ids":["c-lead-2007-board","c-lead-pay-2010-2011"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"trautmann → wirecard: Management board member [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-vonerffa-acqiss","record":{"id":"r-vonerffa-acqiss","from":"von-erffa","to":"wd-acq-iss","status":"documented","role":"Holder of power of attorney (Prokurist)","period":"21 March 2012 to 20 August 2020","claim_ids":["c-lead-acqiss-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"von-erffa → wd-acq-iss: Holder of power of attorney (Prokurist) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-vonerffa-wdglobal","record":{"id":"r-vonerffa-wdglobal","from":"von-erffa","to":"wd-global-sales","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"27 January 2016 to 30 June 2020","claim_ids":["c-lead-global-sales-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"von-erffa → wd-global-sales: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-vonerffa-wdinvest","record":{"id":"r-vonerffa-wdinvest","from":"von-erffa","to":"wd-invest","status":"documented","role":"Manager (gérant)","period":"17 September 2019 to 1 July 2020","claim_ids":["c-fin-wd-invest-managers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"von-erffa → wd-invest: Manager (gérant) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-vonerffa-wdissuing","record":{"id":"r-vonerffa-wdissuing","from":"von-erffa","to":"wd-issuing-tech","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"2 September 2017 to 27 June 2020","claim_ids":["c-lead-newsubs-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"von-erffa → wd-issuing-tech: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-vonerffa-wdservice","record":{"id":"r-vonerffa-wdservice","from":"von-erffa","to":"wd-service-tech","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"12 January 2018 to 30 June 2020","claim_ids":["c-lead-newsubs-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"von-erffa → wd-service-tech: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-vonerffa-wdsih","record":{"id":"r-vonerffa-wdsih","from":"von-erffa","to":"wd-sih","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"25 August 2010 to 14 July 2020","claim_ids":["c-lead-wsih-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"von-erffa → wd-sih: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-vonknoop-acqiss","record":{"id":"r-vonknoop-acqiss","from":"von-knoop","to":"wd-acq-iss","status":"documented","role":"Managing director","period":"26 January 2018 to 20 August 2020","claim_ids":["c-lead-acqiss-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"von-knoop → wd-acq-iss: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-vonknoop-wdbank","record":{"id":"r-vonknoop-wdbank","from":"von-knoop","to":"wd-bank","status":"documented","role":"Management board member (earlier holder of power of attorney)","period":"31 January 2014 to 9 July 2020","claim_ids":["c-lead-bank-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"von-knoop → wd-bank: Management board member (earlier holder of power of attorney) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-vonknoop-wdcs","record":{"id":"r-vonknoop-wdcs","from":"von-knoop","to":"wd-card-solutions","status":"documented","role":"Director","period":"1-2 January 2018 to 6-7 July 2020","claim_ids":["c-lead-wcs-directors"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"von-knoop → wd-card-solutions: Director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdacceptance","record":{"id":"r-wirecard-wdacceptance","from":"wirecard","to":"wd-acceptance-tech","status":"documented","role":"Parent company (100%); founded in 2017","period":"From 2017","claim_ids":["c-str-2018-list-2","c-str-2017-founded"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-acceptance-tech: Parent company (100%); founded in 2017 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdafrica","record":{"id":"r-wirecard-wdafrica","from":"wirecard","to":"wd-africa-holding","status":"documented","role":"Parent company (100%)","period":"Recorded from 2018 to 2019","claim_ids":["c-str-2018-list-2","c-str-2019-halfyear"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-africa-holding: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdasia-wdsingapore","record":{"id":"r-wdasia-wdsingapore","from":"wd-asia-holding","to":"wd-singapore","status":"documented","role":"Second group company in Singapore investigated by the Commercial Affairs Department; registered at the same address (1 Raffles Quay #27-10)","period":"Recorded 2020 to 2022","claim_ids":["c-asia-sg-charges-2022","c-asia-wah-registry"],"kind":"other","direction":"undirected","role_group":"associations","temporal_status":"historical"},"reading":"wd-asia-holding → wd-singapore: Second group company in Singapore investigated by the Commercial Affairs Department; registered at the same address (1 Raffles Quay #27-10) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdaustraliaai","record":{"id":"r-wirecard-wdaustraliaai","from":"wirecard","to":"wd-australia-ai","status":"documented","role":"Parent company (100%)","period":"Until its sale to an Australian payment provider (before April 2021)","claim_ids":["c-str-2018-list-2","c-ins-asia-sales"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → wd-australia-ai: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdforexindia","record":{"id":"r-wirecard-wdforexindia","from":"wirecard","to":"wd-forex-india","status":"documented","role":"Parent company (100%)","period":"From 30 December 2015","claim_ids":["c-str-2018-list-1","c-asia-gi-retail"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-forex-india: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdgibraltar","record":{"id":"r-wirecard-wdgibraltar","from":"wirecard","to":"wd-gibraltar","status":"documented","role":"Parent company (100%)","period":"Recorded from 2010 to 2018","claim_ids":["c-str-2018-list-2","c-str-2011-functions"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-gibraltar: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdinvest","record":{"id":"r-wirecard-wdinvest","from":"wirecard","to":"wd-invest","status":"documented","role":"Guarantor of the EUR 900 million convertible bond issued by the company (ISIN DE000A2R76L7)","period":"From 2019","claim_ids":["c-fin-wd-invest"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → wd-invest: Guarantor of the EUR 900 million convertible bond issued by the company (ISIN DE000A2R76L7) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdpshk","record":{"id":"r-wirecard-wdpshk","from":"wirecard","to":"wd-ps-hk","status":"documented","role":"Parent company (100%)","period":"Until the sale announced on 16 April 2021","claim_ids":["c-str-2018-list-2","c-ins-asia-sales"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → wd-ps-hk: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdpsmalaysia","record":{"id":"r-wirecard-wdpsmalaysia","from":"wirecard","to":"wd-ps-malaysia","status":"documented","role":"Parent company (100%)","period":"Until the sale announced on 16 April 2021","claim_ids":["c-str-2018-list-1","c-ins-asia-sales"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → wd-ps-malaysia: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdsih-wdpsh","record":{"id":"r-wdsih-wdpsh","from":"wd-sih","to":"wd-psh","status":"documented","role":"Sole shareholder (100%)","period":"Recorded in 2019","claim_ids":["c-str-wpsh"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wd-sih → wd-psh: Sole shareholder (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdpsh-wduki","record":{"id":"r-wdpsh-wduki","from":"wd-psh","to":"wd-uki","status":"documented","role":"Sole shareholder (100%)","period":"From 2015","claim_ids":["c-str-wpsh","c-str-wuki-owner"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wd-psh → wd-uki: Sole shareholder (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdretail","record":{"id":"r-wirecard-wdretail","from":"wirecard","to":"wd-retail-services","status":"documented","role":"Parent company (100%)","period":"Recorded from 2010 to 2018","claim_ids":["c-str-2018-list-2"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-retail-services: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdsih-wdromania","record":{"id":"r-wdsih-wdromania","from":"wd-sih","to":"wd-romania","status":"documented","role":"Parent company (100%)","period":"Until the sale to SIBS on 28 September 2020","claim_ids":["c-ins-romania"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wd-sih → wd-romania: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdsouthafrica","record":{"id":"r-wirecard-wdsouthafrica","from":"wirecard","to":"wd-south-africa","status":"documented","role":"Parent company (100%)","period":"Until its merger in 2019","claim_ids":["c-str-2018-list-2","c-str-2019-halfyear"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → wd-south-africa: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdbus","record":{"id":"r-wirecard-wdbus","from":"wirecard","to":"wdb-us","status":"documented","role":"Parent company (100%, directly or indirectly); founded in 2019","period":"From 2019","claim_ids":["c-str-2019-list","c-str-2018-founded"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wdb-us: Parent company (100%, directly or indirectly); founded in 2019 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdbank-aldi","record":{"id":"r-wdbank-aldi","from":"wd-bank","to":"aldi-sued","status":"reported","role":"Card-payment acquirer for the retailer, which moved its customers' card payments to Payone from early July 2020 (gift card retained)","period":"Until early July 2020","claim_ids":["c-bank-customers-2020"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wd-bank → aldi-sued: Card-payment acquirer for the retailer, which moved its customers' card payments to Payone from early July 2020 (gift card retained) [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-americanpayment","record":{"id":"r-wirecard-americanpayment","from":"wirecard","to":"american-payment","status":"documented","role":"Parent company (100%)","period":"Recorded in 2018","claim_ids":["c-str-2018-list-1"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → american-payment: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdcee-aurin","record":{"id":"r-wdcee-aurin","from":"wd-cee","to":"aurin","status":"documented","role":"Seller of its business, through its insolvency administrator, to the investor","period":"With effect from 30 September 2020","claim_ids":["c-ins-cee"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wd-cee → aurin: Seller of its business, through its insolvency administrator, to the investor [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-bafin-braun","record":{"id":"r-bafin-braun","from":"bafin","to":"braun","status":"documented","role":"Examined his share transactions for possible insider trading","period":"2020","claim_ids":["c-sup-braun-shares"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"bafin → braun: Examined his share transactions for possible insider trading [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-bafin-mb","record":{"id":"r-bafin-mb","from":"bafin","to":"mb-beteiligung","status":"reported","role":"Filed a criminal complaint for insider trading over share sales of 24 June 2020","period":"July 2020","claim_ids":["c-braun-insider"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"bafin → mb-beteiligung: Filed a criminal complaint for insider trading over share sales of 24 June 2020 [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-bakertilly-wdsih","record":{"id":"r-bakertilly-wdsih","from":"bakertilly","to":"wd-sih","status":"documented","role":"Auditor of the annual accounts","period":"Recorded in the register publications","claim_ids":["c-str-wsih-owner"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"bakertilly → wd-sih: Auditor of the annual accounts [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-matthias-sarasin","record":{"id":"r-matthias-sarasin","from":"matthias","to":"bank-sarasin","status":"documented","role":"Managing director (Frankfurt am Main)","period":"Recorded in 2011","claim_ids":["c-lead-2011-sb"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"matthias → bank-sarasin: Managing director (Frankfurt am Main) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-bauer-wdcomm","record":{"id":"r-bauer-wdcomm","from":"bauer-heiner","to":"wd-comm-services","status":"documented","role":"Managing director","period":"Recorded in the register","claim_ids":["c-lead-commservices-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"bauer-heiner → wd-comm-services: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-bellenhaus-wdcs","record":{"id":"r-bellenhaus-wdcs","from":"bellenhaus","to":"wd-card-solutions","status":"documented","role":"Director","period":"13 February 2012 to 30 June 2020","claim_ids":["c-lead-wcs-directors"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"bellenhaus → wd-card-solutions: Director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-bellenhaus-wdprocessing","record":{"id":"r-bellenhaus-wdprocessing","from":"bellenhaus","to":"wd-processing","status":"documented","role":"Director","period":"Recorded in 2019","claim_ids":["c-str-processing","c-lead-cardsystems-directors"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"bellenhaus → wd-processing: Director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-klestil-belview","record":{"id":"r-klestil-belview","from":"klestil","to":"belview","status":"documented","role":"Managing director and owner","period":"Recorded from 2011","claim_ids":["c-lead-2011-sb"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"klestil → belview: Managing director and owner [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-jaffe-braun-claim","record":{"id":"r-jaffe-braun-claim","from":"jaffe","to":"braun","status":"documented","role":"Claimant as insolvency administrator: attachment of EUR 140 million confirmed in 2022; judgment of 5 September 2024 ordering payment of EUR 140 million (jointly with two other former board members)","period":"2021 to 2024","claim_ids":["c-mca-civil-judgment"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"jaffe → braun: Claimant as insolvency administrator: attachment of EUR 140 million confirmed in 2022; judgment of 5 September 2024 ordering payment of EUR 140 million (jointly with two other former board members) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdbank-braun-loan","record":{"id":"r-wdbank-braun-loan","from":"wd-bank","to":"braun","status":"reported","role":"Lender of a EUR 35 million loan with which he refinanced a bank loan of his company (cancelled as of 1 April 2020), according to the prosecution and a press report","period":"Early 2020","claim_ids":["c-mca-ocap-flow","c-bank-braun-loan"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wd-bank → braun: Lender of a EUR 35 million loan with which he refinanced a bank loan of his company (cancelled as of 1 April 2020), according to the prosecution and a press report [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-chaeuser-ocap","record":{"id":"r-chaeuser-ocap","from":"c-haeuser","to":"ocap","status":"reported","role":"Managing director (as stated by opposition deputies citing a magazine)","period":"2018","claim_ids":["c-mca-wd-bank-loans"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"c-haeuser → ocap: Managing director (as stated by opposition deputies citing a magazine) [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-cacib-wirecard","record":{"id":"r-cacib-wirecard","from":"cacib","to":"wirecard","status":"documented","role":"Joint global coordinator of the 2019 bond","period":"September 2019","claim_ids":["c-fin-bond-banks"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"cacib → wirecard: Joint global coordinator of the 2019 bond [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-cad-ocap","record":{"id":"r-cad-ocap","from":"cad","to":"ocap","status":"documented","role":"Investigating authority that froze the company's funds","period":"2020","claim_ids":["c-mca-ocap-singapore-2020"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"cad → ocap: Investigating authority that froze the company's funds [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-cad-wdasia","record":{"id":"r-cad-wdasia","from":"cad","to":"wd-asia-holding","status":"documented","role":"Investigated the company (charges against former staff in 2022)","period":"2020 to 2022","claim_ids":["c-asia-sg-charges-2022"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"cad → wd-asia-holding: Investigated the company (charges against former staff in 2022) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-caps","record":{"id":"r-wirecard-caps","from":"wirecard","to":"caps","status":"documented","role":"Strategic partner for e-commerce payment acceptance and point-of-sale solutions in Europe","period":"Recorded in the 2018 annual report","claim_ids":["c-acq-partnerships-2018"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → caps: Strategic partner for e-commerce payment acceptance and point-of-sale solutions in Europe [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-cardsystemsfz","record":{"id":"r-wirecard-cardsystemsfz","from":"wirecard","to":"cardsystems-fz","status":"documented","role":"Parent company (100%)","period":"Recorded in 2010 and 2011","claim_ids":["c-str-2011-list"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → cardsystems-fz: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-marsalek-cardsystems","record":{"id":"r-marsalek-cardsystems","from":"marsalek","to":"cardsystems-me","status":"documented","role":"Director","period":"Recorded in the register","claim_ids":["c-lead-cardsystems-directors"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"marsalek → cardsystems-me: Director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-cardsystems-senjo","record":{"id":"r-cardsystems-senjo","from":"cardsystems-me","to":"senjo","status":"reported","role":"Seller of a platform to the TPA partner under an agreement of 16 April 2018","period":"From 16 April 2018","claim_ids":["c-tpa-rp-2018-contracts"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"cardsystems-me → senjo: Seller of a platform to the TPA partner under an agreement of 16 April 2018 [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdtech-cardsystems","record":{"id":"r-wdtech-cardsystems","from":"wd-tech","to":"cardsystems-me","status":"documented","role":"Sole shareholder (100%)","period":"Recorded in 2019","claim_ids":["c-str-cardsystems-owner"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wd-tech → cardsystems-me: Sole shareholder (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-matthias-wdtech","record":{"id":"r-matthias-wdtech","from":"matthias","to":"wd-tech","status":"documented","role":"Supervisory board member (of the company, then Wirecard Technologies AG)","period":"Recorded in 2011; earlier membership per investor profiles","claim_ids":["c-lead-2011-sb","c-lead-sb-later"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"matthias → wd-tech: Supervisory board member (of the company, then Wirecard Technologies AG) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-lauterbach-censhare","record":{"id":"r-lauterbach-censhare","from":"lauterbach","to":"censhare","status":"documented","role":"Chair (outside mandate)","period":"Until 31 January 2019","claim_ids":["c-lead-lauterbach"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"lauterbach → censhare: Chair (outside mandate) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-lauterbach-dnb","record":{"id":"r-lauterbach-dnb","from":"lauterbach","to":"dun-bradstreet","status":"documented","role":"Independent director (outside mandate)","period":"Until 7 February 2019","claim_ids":["c-lead-lauterbach"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"lauterbach → dun-bradstreet: Independent director (outside mandate) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-lauterbach-easyjet","record":{"id":"r-lauterbach-easyjet","from":"lauterbach","to":"easyjet","status":"documented","role":"Independent non-executive director (outside mandate)","period":"Until 20 December 2020","claim_ids":["c-lead-lauterbach"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"lauterbach → easyjet: Independent non-executive director (outside mandate) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-chujfi-wirecard","record":{"id":"r-chujfi-wirecard","from":"chujfi","to":"wirecard","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"Registered on 6 August 2007","claim_ids":["c-lead-2007-board"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"chujfi → wirecard: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-senjo-citadelle","record":{"id":"r-senjo-citadelle","from":"senjo","to":"citadelle","status":"hypothesis","role":"Possible link through a shared individual (the Senjo company secretary matched the signatory of a trustee confirmation), according to the special investigators","period":"2016","claim_ids":["c-tpa-rp-senjo"],"kind":"other","direction":"undirected","role_group":"associations","temporal_status":"historical"},"reading":"senjo → citadelle: Possible link through a shared individual (the Senjo company secretary matched the signatory of a trustee confirmation), according to the special investigators [hypothesis]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-ocap-citibank","record":{"id":"r-ocap-citibank","from":"ocap","to":"citibank-na","status":"documented","role":"Holder of two bank accounts, restrained by the Singapore court on 3 November 2023","period":"Restraint from 3 November 2023","claim_ids":["c-mca-ocap-restraint"],"kind":"business","direction":"directed","role_group":"infrastructure","temporal_status":"unknown"},"reading":"ocap → citibank-na: Holder of two bank accounts, restrained by the Singapore court on 3 November 2023 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-citibank","record":{"id":"r-wirecard-citibank","from":"wirecard","to":"citibank-na","status":"documented","role":"Buyer of Citi's card-acceptance customer portfolios in eleven Asia-Pacific markets","period":"Agreement of 13 March 2017; closings 2018","claim_ids":["c-acq-citi-asia"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → citibank-na: Buyer of Citi's card-acceptance customer portfolios in eleven Asia-Pacific markets [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-citioverseas","record":{"id":"r-wirecard-citioverseas","from":"wirecard","to":"citi-overseas","status":"documented","role":"Buyer of Citi's card-acceptance customer portfolios in eleven Asia-Pacific markets","period":"Agreement of 13 March 2017; closings 2018","claim_ids":["c-acq-citi-asia"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → citi-overseas: Buyer of Citi's card-acceptance customer portfolios in eleven Asia-Pacific markets [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-goerres-click2pay","record":{"id":"r-goerres-click2pay","from":"goerres","to":"click2pay","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"Recorded in the register","claim_ids":["c-lead-click2pay-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"goerres → click2pay: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-mb-click2pay","record":{"id":"r-mb-click2pay","from":"mb-beteiligung","to":"click2pay","status":"documented","role":"Registered at the same address (Einsteinring 35, Aschheim)","period":"Recorded in the register","claim_ids":["c-own-mb-registry"],"kind":"other","direction":"undirected","role_group":"associations","temporal_status":"unknown"},"reading":"mb-beteiligung → click2pay: Registered at the same address (Einsteinring 35, Aschheim) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-teamtreuhand-click2pay","record":{"id":"r-teamtreuhand-click2pay","from":"team-treuhand","to":"click2pay","status":"documented","role":"Liquidator","period":"From 2 March 2021","claim_ids":["c-lead-click2pay-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"team-treuhand → click2pay: Liquidator [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-creditsuisse-wirecard","record":{"id":"r-creditsuisse-wirecard","from":"credit-suisse","to":"wirecard","status":"documented","role":"Joint global coordinator of the 2019 bond","period":"September 2019","claim_ids":["c-fin-bond-banks"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"credit-suisse → wirecard: Joint global coordinator of the 2019 bond [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-deutschebank-wdbank","record":{"id":"r-deutschebank-wdbank","from":"deutsche-bank","to":"wd-bank","status":"reported","role":"Intended to support the bank and was reported to be positioning itself for a possible takeover (insiders cited by the press)","period":"July 2020","claim_ids":["c-bank-customers-2020"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"deutsche-bank → wd-bank: Intended to support the bank and was reported to be positioning itself for a possible takeover (insiders cited by the press) [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-deutschebank-wirecard","record":{"id":"r-deutschebank-wirecard","from":"deutsche-bank","to":"wirecard","status":"documented","role":"Joint bookrunner of the 2019 bond","period":"September 2019","claim_ids":["c-fin-bond-banks"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"deutsche-bank → wirecard: Joint bookrunner of the 2019 bond [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-henseler-diamos","record":{"id":"r-henseler-diamos","from":"henseler","to":"diamos","status":"documented","role":"Supervisory board member (outside mandate)","period":"Recorded in 2011","claim_ids":["c-lead-2011-sb"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"henseler → diamos: Supervisory board member (outside mandate) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-sdk-wirecard","record":{"id":"r-sdk-wirecard","from":"sdk","to":"wirecard","status":"documented","role":"Claimant challenging the 2008 general meeting's discharge resolutions and the validity of the 2007 annual accounts","period":"From 2008","claim_ids":["c-aud-2008-mandate"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"sdk → wirecard: Claimant challenging the 2008 general meeting's discharge resolutions and the validity of the 2007 annual accounts [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-ecount","record":{"id":"r-wirecard-ecount","from":"wirecard","to":"ecount","status":"documented","role":"Acquired control (with Citi Prepaid Card Services)","period":"From 9 March 2017","claim_ids":["c-acq-2017"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → ecount: Acquired control (with Citi Prepaid Card Services) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-ecreditcorp","record":{"id":"r-wirecard-ecreditcorp","from":"wirecard","to":"ecredit-corp","status":"documented","role":"Parent company (100%)","period":"Recorded in 2010 and 2011","claim_ids":["c-str-2011-list"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → ecredit-corp: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-epaymentssg","record":{"id":"r-wirecard-epaymentssg","from":"wirecard","to":"epayments-sg","status":"documented","role":"Parent company (100%)","period":"Recorded in 2010 and 2011","claim_ids":["c-str-2011-list"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → epayments-sg: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-esma-wirecard","record":{"id":"r-esma-wirecard","from":"esma","to":"wirecard","status":"documented","role":"Peer review of the German supervisors' handling of Wirecard's financial reporting","period":"Report of 3 November 2020","claim_ids":["c-sup-esma-mandate"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"esma → wirecard: Peer review of the German supervisors' handling of Wirecard's financial reporting [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-ey-wdtech","record":{"id":"r-ey-wdtech","from":"ey","to":"wd-tech","status":"documented","role":"Auditor","period":"Financial years 2014 to 2019","claim_ids":["c-aud-2019-refusal"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"ey → wd-tech: Auditor [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-fieldfisher","record":{"id":"r-wirecard-fieldfisher","from":"wirecard","to":"fieldfisher","status":"documented","role":"Client that commissioned the law firm to investigate the Singapore allegations","period":"2018 to 2019","claim_ids":["c-aud-rp-2018-audit"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → fieldfisher: Client that commissioned the law firm to investigate the Singapore allegations [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdbank-fiu","record":{"id":"r-wdbank-fiu","from":"wd-bank","to":"fiu","status":"documented","role":"Filer of more than 500 suspicious-transaction reports on its customers","period":"Up to July 2020","claim_ids":["c-bank-fiu"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"wd-bank → fiu: Filer of more than 500 suspicious-transaction reports on its customers [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-fsb-marsalek","record":{"id":"r-fsb-marsalek","from":"fsb","to":"marsalek","status":"reported","role":"Refused him exit from Moscow in September 2017 and tracked his international travel from 2015 to 2018, according to leaked Russian records reported by investigative media","period":"2015 to 2018","claim_ids":["c-mar-russia-travel"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"fsb → marsalek: Refused him exit from Moscow in September 2017 and tracked his international travel from 2015 to 2018, according to leaked Russian records reported by investigative media [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-fuchs-wdpsh","record":{"id":"r-fuchs-wdpsh","from":"fuchs","to":"wd-psh","status":"documented","role":"Director","period":"Recorded in the Irish register","claim_ids":["c-lead-wpsh-directors"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"fuchs → wd-psh: Director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-fuchs-wduki","record":{"id":"r-fuchs-wduki","from":"fuchs","to":"wd-uki","status":"documented","role":"Director (sales director)","period":"Until the liquidation","claim_ids":["c-mar-ireland"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"fuchs → wd-uki: Director (sales director) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-funk-wdcomm","record":{"id":"r-funk-wdcomm","from":"funk","to":"wd-comm-services","status":"documented","role":"Managing director","period":"Until 6 July 2020","claim_ids":["c-lead-commservices-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"funk → wd-comm-services: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-giretail","record":{"id":"r-wirecard-giretail","from":"wirecard","to":"gi-retail","status":"documented","role":"Buyer of the payment business of the Great Indian Retail Group","period":"Agreement of 27 October 2015","claim_ids":["c-asia-gi-retail"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → gi-retail: Buyer of the payment business of the Great Indian Retail Group [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-goerres-wdacceptance","record":{"id":"r-goerres-wdacceptance","from":"goerres","to":"wd-acceptance-tech","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"19 January 2018 to 29 August 2020","claim_ids":["c-lead-newsubs-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"goerres → wd-acceptance-tech: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-goerres-acqiss","record":{"id":"r-goerres-acqiss","from":"goerres","to":"wd-acq-iss","status":"documented","role":"Managing director","period":"10 April 2013 to 2 September 2020","claim_ids":["c-lead-acqiss-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"goerres → wd-acq-iss: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-goerres-wdcomm","record":{"id":"r-goerres-wdcomm","from":"goerres","to":"wd-comm-services","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"Until 9 September 2020 (lapsed on insolvency)","claim_ids":["c-ins-comm-services"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"goerres → wd-comm-services: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-goerres-wdglobal","record":{"id":"r-goerres-wdglobal","from":"goerres","to":"wd-global-sales","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"27 January 2016 to 28 August 2020","claim_ids":["c-lead-global-sales-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"goerres → wd-global-sales: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-goerres-wdsih","record":{"id":"r-goerres-wdsih","from":"goerres","to":"wd-sih","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"25 August 2010 to 28 August 2020","claim_ids":["c-lead-wsih-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"goerres → wd-sih: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-goerres-wdtech","record":{"id":"r-goerres-wdtech","from":"goerres","to":"wd-tech","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"14 August 2012 to 28 August 2020","claim_ids":["c-lead-wdtech-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"goerres → wd-tech: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-goomo","record":{"id":"r-wirecard-goomo","from":"wirecard","to":"goomo","status":"reported","role":"Guarantor of a EUR 11 million loan from Wirecard Bank AG (as stated by opposition deputies citing a magazine)","period":"2018","claim_ids":["c-mca-wd-bank-loans"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → goomo: Guarantor of a EUR 11 million loan from Wirecard Bank AG (as stated by opposition deputies citing a magazine) [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-gray-wduki","record":{"id":"r-gray-wduki","from":"gray","to":"wd-uki","status":"documented","role":"Statutory auditor, sanctioned by the Irish audit regulator","period":"Audits of the company","claim_ids":["c-aud-iaasa"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"gray → wd-uki: Statutory auditor, sanctioned by the Irish audit regulator [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-spf-haeuserax","record":{"id":"r-spf-haeuserax","from":"spf","to":"haeuser-axtner","status":"documented","role":"Arrested her on a German request and handed her over in extradition","period":"4 November 2025 to 30 March 2026","claim_ids":["c-crim-haeuser-axtner"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"spf → haeuser-axtner: Arrested her on a German request and handed her over in extradition [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-haeuserax-wdasia","record":{"id":"r-haeuserax-wdasia","from":"haeuser-axtner","to":"wd-asia-holding","status":"documented","role":"Director","period":"Former","claim_ids":["c-crim-haeuser-axtner"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"haeuser-axtner → wd-asia-holding: Director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-haeuserax-wirecard","record":{"id":"r-haeuserax-wirecard","from":"haeuser-axtner","to":"wirecard","status":"documented","role":"Former director for Asia","period":"Former","claim_ids":["c-crim-haeuser-axtner"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"haeuser-axtner → wirecard: Former director for Asia [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-henseler-wdbank","record":{"id":"r-henseler-wdbank","from":"henseler","to":"wd-bank","status":"documented","role":"Supervisory board member","period":"Recorded from 2011","claim_ids":["c-lead-sb-later"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"henseler → wd-bank: Supervisory board member [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-henseler-wdsih","record":{"id":"r-henseler-wdsih","from":"henseler","to":"wd-sih","status":"documented","role":"Supervisory board member (of Trustpay International AG)","period":"Until 23 August 2010","claim_ids":["c-lead-sb-later"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"henseler → wd-sih: Supervisory board member (of Trustpay International AG) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-henseler-wdtech","record":{"id":"r-henseler-wdtech","from":"henseler","to":"wd-tech","status":"documented","role":"Supervisory board member (of Wirecard Technologies AG)","period":"Until 30 June 2012","claim_ids":["c-lead-sb-later"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"henseler → wd-tech: Supervisory board member (of Wirecard Technologies AG) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdpsh-herview","record":{"id":"r-wdpsh-herview","from":"wd-psh","to":"herview","status":"documented","role":"Holding company of the Irish operating subsidiary","period":"Recorded in 2019","claim_ids":["c-str-wpsh"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wd-psh → herview: Holding company of the Irish operating subsidiary [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-heuser-wdbank","record":{"id":"r-heuser-wdbank","from":"heuser","to":"wd-bank","status":"documented","role":"Management board member","period":"Appointed with a publication of 3 January 2018","claim_ids":["c-lead-bank-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"heuser → wd-bank: Management board member [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-holten-wdacceptance","record":{"id":"r-holten-wdacceptance","from":"holten","to":"wd-acceptance-tech","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"19 January 2018 to 29 August 2020","claim_ids":["c-lead-newsubs-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"holten → wd-acceptance-tech: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-holten-acqiss","record":{"id":"r-holten-acqiss","from":"holten","to":"wd-acq-iss","status":"documented","role":"Holder of power of attorney (Prokurist)","period":"21 March 2012 to 2 September 2020","claim_ids":["c-lead-acqiss-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"holten → wd-acq-iss: Holder of power of attorney (Prokurist) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-holten-wdcomm","record":{"id":"r-holten-wdcomm","from":"holten","to":"wd-comm-services","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"Until 9 September 2020 (lapsed on insolvency)","claim_ids":["c-ins-comm-services"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"holten → wd-comm-services: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-holten-wdglobal","record":{"id":"r-holten-wdglobal","from":"holten","to":"wd-global-sales","status":"documented","role":"Managing director","period":"From 27 January 2016","claim_ids":["c-lead-global-sales-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"holten → wd-global-sales: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-holten-wdtech","record":{"id":"r-holten-wdtech","from":"holten","to":"wd-tech","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"14 August 2012 to 28 August 2020","claim_ids":["c-lead-wdtech-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"holten → wd-tech: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdcs-holvi","record":{"id":"r-wdcs-holvi","from":"wd-card-solutions","to":"holvi","status":"documented","role":"Issuer of the Holvi Business Mastercard cards","period":"Until June 2020","claim_ids":["c-sup-fca-cards"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wd-card-solutions → holvi: Issuer of the Holvi Business Mastercard cards [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wduki-iaasa","record":{"id":"r-wduki-iaasa","from":"iaasa","to":"wd-uki","status":"documented","role":"Audit supervisor that concluded settlements with the auditors of the company's financial statements","period":"Recorded in 2023","claim_ids":["c-aud-iaasa"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"iaasa → wd-uki: Audit supervisor that concluded settlements with the auditors of the company's financial statements [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-incani-wdinvest","record":{"id":"r-incani-wdinvest","from":"incani","to":"wd-invest","status":"documented","role":"Manager (gérant)","period":"30 September 2019 to 3 July 2020","claim_ids":["c-fin-wd-invest-managers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"incani → wd-invest: Manager (gérant) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-infogeniecom","record":{"id":"r-wirecard-infogeniecom","from":"wirecard","to":"infogenie-comservice","status":"documented","role":"Absorbed the company by merger","period":"Merger recorded in the register","claim_ids":["c-id-mergers"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → infogenie-comservice: Absorbed the company by merger [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-infogeniede","record":{"id":"r-wirecard-infogeniede","from":"wirecard","to":"infogenie-de","status":"documented","role":"Absorbed the company by merger (legal successor)","period":"Merger recorded in the register","claim_ids":["c-id-mergers"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → infogenie-de: Absorbed the company by merger (legal successor) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-infogenieglobal","record":{"id":"r-wirecard-infogenieglobal","from":"wirecard","to":"infogenie-global","status":"documented","role":"Absorbed the company by merger","period":"Merger agreement of 29 June 2005","claim_ids":["c-id-mergers"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → infogenie-global: Absorbed the company by merger [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-netsales","record":{"id":"r-wirecard-netsales","from":"wirecard","to":"net-sales","status":"documented","role":"Absorbed the company by merger","period":"Merger agreement of 29 June 2005","claim_ids":["c-id-mergers"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → net-sales: Absorbed the company by merger [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-infogenieltd","record":{"id":"r-wirecard-infogenieltd","from":"wirecard","to":"infogenie-ltd","status":"documented","role":"Parent company (100%)","period":"Recorded in 2010","claim_ids":["c-str-2010-list"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → infogenie-ltd: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-intertrust-wdinvest","record":{"id":"r-intertrust-wdinvest","from":"intertrust-lux","to":"wd-invest","status":"documented","role":"Initial shareholder of the shelf company","period":"23 August to 27 September 2019","claim_ids":["c-fin-wd-invest-managers"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"intertrust-lux → wd-invest: Initial shareholder of the shelf company [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-jaffe-ocap","record":{"id":"r-jaffe-ocap","from":"jaffe","to":"ocap","status":"documented","role":"Controls the Wirecard group's recoveries as majority creditor (over 97% of the company's debt) in its liquidation","period":"From 2020","claim_ids":["c-mca-ocap-creditors"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"jaffe → ocap: Controls the Wirecard group's recoveries as majority creditor (over 97% of the company's debt) in its liquidation [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-jupiterfm-wirecard","record":{"id":"r-jupiterfm-wirecard","from":"jupiter-fm","to":"wirecard","status":"documented","role":"Shareholder (5.00% of the votes)","period":"2019","claim_ids":["c-own-2019"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"jupiter-fm → wirecard: Shareholder (5.00% of the votes) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-senjo-kalixa","record":{"id":"r-senjo-kalixa","from":"senjo","to":"kalixa","status":"documented","role":"Buyer of 100% of the company for EUR 29.0 million","period":"From 1 June 2017","claim_ids":["c-tpa-rp-kalixa"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"senjo → kalixa: Buyer of 100% of the company for EUR 29.0 million [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-kelly-wduki","record":{"id":"r-kelly-wduki","from":"kelly","to":"wd-uki","status":"documented","role":"Statutory auditor, sanctioned by the Irish audit regulator","period":"Audits of the company","claim_ids":["c-aud-iaasa"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"kelly → wd-uki: Statutory auditor, sanctioned by the Irish audit regulator [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-kestrel","record":{"id":"r-wirecard-kestrel","from":"wirecard","to":"kestrel","status":"documented","role":"Parent company (100%) of the transaction vehicle for the Citi Prepaid purchase","period":"Recorded at 31 December 2016; merged into Wirecard North America in 2017","claim_ids":["c-acq-2017"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → kestrel: Parent company (100%) of the transaction vehicle for the Citi Prepaid purchase [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-klestil-wdsih","record":{"id":"r-klestil-wdsih","from":"klestil","to":"wd-sih","status":"documented","role":"Supervisory board member (of Trustpay International AG)","period":"Former","claim_ids":["c-lead-sb-later"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"klestil → wd-sih: Supervisory board member (of Trustpay International AG) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-klestil-wdtech","record":{"id":"r-klestil-wdtech","from":"klestil","to":"wd-tech","status":"documented","role":"Supervisory board member (of Wirecard Technologies AG)","period":"Until 30 June 2012","claim_ids":["c-lead-sb-later"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"klestil → wd-tech: Supervisory board member (of Wirecard Technologies AG) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-ley-wdbank","record":{"id":"r-ley-wdbank","from":"ley","to":"wd-bank","status":"documented","role":"Management board member","period":"Until a publication of 3 January 2018","claim_ids":["c-lead-bank-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"ley → wd-bank: Management board member [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-ley-wdtech","record":{"id":"r-ley-wdtech","from":"ley","to":"wd-tech","status":"documented","role":"Managing director","period":"14 August 2012 to 5 December 2012","claim_ids":["c-lead-wdtech-officers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"ley → wd-tech: Managing director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-marsalek-libyacement","record":{"id":"r-marsalek-libyacement","from":"marsalek","to":"libya-cement","status":"reported","role":"Investor in the company (according to investigative media)","period":"From 2015","claim_ids":["c-mar-libya"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"marsalek → libya-cement: Investor in the company (according to investigative media) [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-lloyds-wirecard","record":{"id":"r-lloyds-wirecard","from":"lloyds-cm","to":"wirecard","status":"documented","role":"Joint bookrunner of the 2019 bond","period":"September 2019","claim_ids":["c-fin-bond-banks"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"lloyds-cm → wirecard: Joint bookrunner of the 2019 bond [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-marsalek-payeasy","record":{"id":"r-marsalek-payeasy","from":"marsalek","to":"payeasy","status":"reported","role":"Received and forwarded the TPA partner's letter explaining its registration gaps (special investigators)","period":"March 2015","claim_ids":["c-tpa-rp-payeasy-existence"],"kind":"other","direction":"directed","role_group":"associations","temporal_status":"historical"},"reading":"marsalek → payeasy: Received and forwarded the TPA partner's letter explaining its registration gaps (special investigators) [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-schellenbacher-marsalek","record":{"id":"r-schellenbacher-marsalek","from":"schellenbacher","to":"marsalek","status":"reported","role":"Chartered the private jet for his escape (according to investigative media)","period":"18 June 2020","claim_ids":["c-mar-flight"],"kind":"other","direction":"directed","role_group":"associations","temporal_status":"historical"},"reading":"schellenbacher → marsalek: Chartered the private jet for his escape (according to investigative media) [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-marsalek-senjo","record":{"id":"r-marsalek-senjo","from":"marsalek","to":"senjo","status":"documented","role":"Asked in an e-mail that the TPA partner be supported","period":"2 June 2015","claim_ids":["c-tpa-rp-senjo-email"],"kind":"other","direction":"directed","role_group":"associations","temporal_status":"historical"},"reading":"marsalek → senjo: Asked in an e-mail that the TPA partner be supported [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-marsalek-wdasiapte","record":{"id":"r-marsalek-wdasiapte","from":"marsalek","to":"wd-asia-pte","status":"documented","role":"Director (of E-Credit Plus Pte. Ltd.)","period":"From 18 March 2010 per the compliance extract","claim_ids":["c-mar-ecredit"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"marsalek → wd-asia-pte: Director (of E-Credit Plus Pte. Ltd.) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-marsalek-wdpsh","record":{"id":"r-marsalek-wdpsh","from":"marsalek","to":"wd-psh","status":"documented","role":"Director","period":"Recorded in the Irish register","claim_ids":["c-lead-wpsh-directors"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"marsalek → wd-psh: Director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-marsalek-wduki","record":{"id":"r-marsalek-wduki","from":"marsalek","to":"wd-uki","status":"documented","role":"Director and chief executive","period":"Until the liquidation","claim_ids":["c-mar-ireland"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"marsalek → wd-uki: Director and chief executive [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-weiss-marsalek","record":{"id":"r-weiss-marsalek","from":"weiss","to":"marsalek","status":"reported","role":"Business associate from 2019 who organised his escape (according to investigative media)","period":"2019 to June 2020","claim_ids":["c-mar-flight"],"kind":"other","direction":"directed","role_group":"associations","temporal_status":"historical"},"reading":"weiss → marsalek: Business associate from 2019 who organised his escape (according to investigative media) [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-mas-ruprecht","record":{"id":"r-mas-ruprecht","from":"mas","to":"ruprecht","status":"documented","role":"Lists the company as a former exempt entity under the Payment Services Act","period":"Recorded by the regulator","claim_ids":["c-mca-ruprecht-registry"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"mas → ruprecht: Lists the company as a former exempt entity under the Payment Services Act [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-mas-wdasia","record":{"id":"r-mas-wdasia","from":"mas","to":"wd-asia-holding","status":"documented","role":"Lists the company as no longer exempt under the Payment Services Act","period":"Recorded by the regulator","claim_ids":["c-sup-mas"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"mas → wd-asia-holding: Lists the company as no longer exempt under the Payment Services Act [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-mas-wdsingapore","record":{"id":"r-mas-wdsingapore","from":"mas","to":"wd-singapore","status":"documented","role":"Lists the company as no longer exempt under the Payment Services Act","period":"Recorded by the regulator","claim_ids":["c-sup-mas"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"mas → wd-singapore: Lists the company as no longer exempt under the Payment Services Act [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-sta-matthias","record":{"id":"r-sta-matthias","from":"sta-muenchen","to":"matthias","status":"reported","role":"Opened an investigation into him among other former supervisory board members (402 Js 199828/20), as reported","period":"2020 to 2021","claim_ids":["c-crim-matthias"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"sta-muenchen → matthias: Opened an investigation into him among other former supervisory board members (402 Js 199828/20), as reported [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-maula-wdinvest","record":{"id":"r-maula-wdinvest","from":"maula","to":"wd-invest","status":"documented","role":"Manager (gérant)","period":"30 September 2019 to 3 July 2020","claim_ids":["c-fin-wd-invest-managers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"maula → wd-invest: Manager (gérant) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-mccrum","record":{"id":"r-wirecard-mccrum","from":"wirecard","to":"mccrum","status":"documented","role":"Claimant in an action against the reporter and his newspaper","period":"Filed 22 March 2019; withdrawn 28 October 2020","claim_ids":["c-sup-ft-suit-2019"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"wirecard → mccrum: Claimant in an action against the reporter and his newspaper [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-meehan-wdpsh","record":{"id":"r-meehan-wdpsh","from":"meehan","to":"wd-psh","status":"documented","role":"Director","period":"Recorded in the Irish register","claim_ids":["c-lead-wpsh-directors"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"meehan → wd-psh: Director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-mizuho","record":{"id":"r-wirecard-mizuho","from":"wirecard","to":"mizuho","status":"documented","role":"Acquiring partnership for Japanese retailers in Singapore and Hong Kong","period":"Recorded in the 2018 annual report","claim_ids":["c-acq-partnerships-2018"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → mizuho: Acquiring partnership for Japanese retailers in Singapore and Hong Kong [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-acqiss-moelis","record":{"id":"r-acqiss-moelis","from":"wd-acq-iss","to":"moelis","status":"documented","role":"Client that engaged the investment bank to sell Wirecard North America","period":"From 5 July 2020","claim_ids":["c-ins-moelis"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wd-acq-iss → moelis: Client that engaged the investment bank to sell Wirecard North America [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdcs-newcastle","record":{"id":"r-wdcs-newcastle","from":"wd-card-solutions","to":"newcastle-bs","status":"documented","role":"Took over the prepaid card issuing business of the building society","period":"From December 2011","claim_ids":["c-acq-newcastle"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wd-card-solutions → newcastle-bs: Took over the prepaid card issuing business of the building society [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-newcastle","record":{"id":"r-wirecard-newcastle","from":"wirecard","to":"newcastle-bs","status":"documented","role":"Buyer, through its subsidiary, of the prepaid card portfolio (about 1.5 million cards)","period":"2011","claim_ids":["c-acq-newcastle"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → newcastle-bs: Buyer, through its subsidiary, of the prepaid card portfolio (about 1.5 million cards) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-nomupay-wdturkey","record":{"id":"r-nomupay-wdturkey","from":"nomu-pay","to":"wd-turkey","status":"documented","role":"Buyer of the company","period":"Sale announced on 30 March 2021","claim_ids":["c-ins-turkey"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"nomu-pay → wd-turkey: Buyer of the company [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-nomupay","record":{"id":"r-wirecard-nomupay","from":"wirecard","to":"nomu-pay","status":"documented","role":"Seller, through the administrator, of the Philippine, Malaysian, Thai and Hong Kong subsidiaries","period":"Sale announced on 16 April 2021","claim_ids":["c-ins-asia-sales"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → nomu-pay: Seller, through the administrator, of the Philippine, Malaysian, Thai and Hong Kong subsidiaries [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-nouinou-wdprocessing","record":{"id":"r-nouinou-wdprocessing","from":"nouinou","to":"wd-processing","status":"documented","role":"General manager","period":"Recorded in 2019","claim_ids":["c-lead-cardsystems-directors"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"nouinou → wd-processing: General manager [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-ocap-ocapasia","record":{"id":"r-ocap-ocapasia","from":"ocap","to":"ocap-asia","status":"documented","role":"Parent company of the subsidiary","period":"Recorded in 2020","claim_ids":["c-mca-ocap-singapore-2020"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"ocap → ocap-asia: Parent company of the subsidiary [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-ocap-senjo","record":{"id":"r-ocap-senjo","from":"ocap","to":"senjo","status":"documented","role":"TPA partner and borrower in the same Wirecard Bank loan portfolio; OCAP was formerly called Senjo Trading Pte. Ltd.","period":"Recorded for 2017","claim_ids":["c-mca-ocap-senjo"],"kind":"other","direction":"undirected","role_group":"associations","temporal_status":"historical"},"reading":"ocap → senjo: TPA partner and borrower in the same Wirecard Bank loan portfolio; OCAP was formerly called Senjo Trading Pte. Ltd. [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdasia-ocap","record":{"id":"r-wdasia-ocap","from":"wd-asia-holding","to":"ocap","status":"documented","role":"Lender (loans of September 2018; a criminal count over them was discontinued on 27 February 2025)","period":"September 2018","claim_ids":["c-mca-wah-loans"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wd-asia-holding → ocap: Lender (loans of September 2018; a criminal count over them was discontinued on 27 February 2025) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdbank-ocap","record":{"id":"r-wdbank-ocap","from":"wd-bank","to":"ocap","status":"documented","role":"Lender (loans in the 2017 MaRisk audit sample)","period":"Recorded for 2017","claim_ids":["c-mca-ocap-senjo"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wd-bank → ocap: Lender (loans in the 2017 MaRisk audit sample) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-paymenttech","record":{"id":"r-wirecard-paymenttech","from":"wirecard","to":"payment-tech","status":"documented","role":"Parent company (100%)","period":"Recorded at 31 December 2016","claim_ids":["c-str-2016-list"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → payment-tech: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdcs-payoneer","record":{"id":"r-wdcs-payoneer","from":"wd-card-solutions","to":"payoneer","status":"documented","role":"Issuer of the Payoneer prepaid Mastercard cards","period":"Until June 2020","claim_ids":["c-sup-fca-cards"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wd-card-solutions → payoneer: Issuer of the Payoneer prepaid Mastercard cards [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdsih-primavista","record":{"id":"r-wdsih-primavista","from":"wd-sih","to":"prima-vista","status":"documented","role":"Parent company","period":"Until the sale in the insolvency","claim_ids":["c-ins-romania"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wd-sih → prima-vista: Parent company [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdretail-procard","record":{"id":"r-wdretail-procard","from":"wd-retail-services","to":"procard-kartensysteme","status":"documented","role":"Absorbed the company by merger","period":"2010","claim_ids":["c-str-2010-mergers"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wd-retail-services → procard-kartensysteme: Absorbed the company by merger [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-pudewill-wirecard","record":{"id":"r-pudewill-wirecard","from":"pudewill","to":"wirecard","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"Registered on 6 August 2007","claim_ids":["c-lead-2007-board"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"pudewill → wirecard: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdcs-railsbank","record":{"id":"r-wdcs-railsbank","from":"wd-card-solutions","to":"railsbank","status":"documented","role":"Seller in principle of customer relationships and other assets","period":"Agreement in principle of 2020","claim_ids":["c-ins-brazil-railsbank"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wd-card-solutions → railsbank: Seller in principle of customer relationships and other assets [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-rajaratnam-senjo","record":{"id":"r-rajaratnam-senjo","from":"rajaratnam","to":"senjo","status":"reported","role":"Company secretary of Senjo Payments Asia Pte. Ltd.","period":"Recorded for 2016","claim_ids":["c-tpa-rp-senjo"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"rajaratnam → senjo: Company secretary of Senjo Payments Asia Pte. Ltd. [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-rcs-wdinvest","record":{"id":"r-rcs-wdinvest","from":"rcs-mgmt","to":"wd-invest","status":"documented","role":"Corporate manager of the shelf company","period":"Until 26 September 2019","claim_ids":["c-fin-wd-invest-managers"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"rcs-mgmt → wd-invest: Corporate manager of the shelf company [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-reisch-wdcee","record":{"id":"r-reisch-wdcee","from":"reisch","to":"wd-cee","status":"documented","role":"Insolvency administrator in Austria","period":"2020","claim_ids":["c-ins-cee"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"reisch → wd-cee: Insolvency administrator in Austria [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdromania-romcard","record":{"id":"r-wdromania-romcard","from":"wd-romania","to":"romcard","status":"documented","role":"Parent company","period":"Until the sale to SIBS on 28 September 2020","claim_ids":["c-ins-romania"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wd-romania → romcard: Parent company [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-romcard","record":{"id":"r-wirecard-romcard","from":"wirecard","to":"romcard","status":"documented","role":"Parent company (100%, indirectly)","period":"Recorded in 2018","claim_ids":["c-str-2018-list-1"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → romcard: Parent company (100%, indirectly) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-rsm-wdasia","record":{"id":"r-rsm-wdasia","from":"rsm","to":"wd-asia-holding","status":"documented","role":"Auditor","period":"Recorded in the Singapore register","claim_ids":["c-asia-wah-registry"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"rsm → wd-asia-holding: Auditor [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-safe2pay","record":{"id":"r-wirecard-safe2pay","from":"wirecard","to":"safe2pay","status":"documented","role":"Indirect parent company (100%, through Systems@Work)","period":"From December 2011","claim_ids":["c-str-2011-list"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → safe2pay: Indirect parent company (100%, through Systems@Work) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-santander","record":{"id":"r-wirecard-santander","from":"wirecard","to":"santander","status":"documented","role":"Seller, through the administrator, of the core assets of Wirecard AG and Wirecard Technologies GmbH","period":"Signed November 2020; closed 28 January 2021","claim_ids":["c-ins-santander"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → santander: Seller, through the administrator, of the core assets of Wirecard AG and Wirecard Technologies GmbH [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-senjo-wdasiapte","record":{"id":"r-senjo-wdasiapte","from":"senjo","to":"wd-asia-pte","status":"reported","role":"Senjo's leading managers sold E-Creditplus Pte. Ltd. to Wirecard and later bought it back (special investigators)","period":"Before 2016","claim_ids":["c-tpa-rp-senjo"],"kind":"other","direction":"directed","role_group":"associations","temporal_status":"historical"},"reading":"senjo → wd-asia-pte: Senjo's leading managers sold E-Creditplus Pte. Ltd. to Wirecard and later bought it back (special investigators) [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdbank-senjo","record":{"id":"r-wdbank-senjo","from":"wd-bank","to":"senjo","status":"documented","role":"Lender of EUR 25.0 million to finance the Kalixa purchase","period":"May-June 2017","claim_ids":["c-tpa-rp-kalixa"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wd-bank → senjo: Lender of EUR 25.0 million to finance the Kalixa purchase [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-sibs-wdromania","record":{"id":"r-sibs-wdromania","from":"sibs","to":"wd-romania","status":"documented","role":"Buyer of 100% of the company","period":"From 28 September 2020","claim_ids":["c-ins-romania"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"current"},"reading":"sibs → wd-romania: Buyer of 100% of the company [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-sibs","record":{"id":"r-wirecard-sibs","from":"wirecard","to":"sibs","status":"documented","role":"Seller, through the administrator, of Wirecard Romania","period":"28 September 2020","claim_ids":["c-ins-santander"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → sibs: Seller, through the administrator, of Wirecard Romania [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-six","record":{"id":"r-wirecard-six","from":"wirecard","to":"six","status":"reported","role":"Processing provider used by Wirecard Bank","period":"Recorded by the special investigators","claim_ids":["c-aud-rp-fraud-risk"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"wirecard → six: Processing provider used by Wirecard Bank [reported]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-sta-wirecard","record":{"id":"r-sta-wirecard","from":"sta-muenchen","to":"wirecard","status":"documented","role":"Investigated the company; searched its premises on 5 June 2020 after a BaFin complaint","period":"From June 2020","claim_ids":["c-sup-2020-complaints"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"sta-muenchen → wirecard: Investigated the company; searched its premises on 5 June 2020 after a BaFin complaint [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-steidl-wdprocessing","record":{"id":"r-steidl-wdprocessing","from":"steidl","to":"wd-processing","status":"documented","role":"Director","period":"Recorded in 2019","claim_ids":["c-str-processing","c-lead-cardsystems-directors"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"steidl → wd-processing: Director [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-steinhoff-wdissuing","record":{"id":"r-steinhoff-wdissuing","from":"steinhoff","to":"wd-issuing-tech","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"25 October 2019 to 28 August 2020","claim_ids":["c-lead-newsubs-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"steinhoff → wd-issuing-tech: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdromania-supercard","record":{"id":"r-wdromania-supercard","from":"wd-romania","to":"supercard","status":"documented","role":"Parent company","period":"Until the sale to SIBS on 28 September 2020","claim_ids":["c-ins-romania"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wd-romania → supercard: Parent company [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-supercard","record":{"id":"r-wirecard-supercard","from":"wirecard","to":"supercard","status":"documented","role":"Parent company (100%, indirectly)","period":"Recorded in 2018","claim_ids":["c-str-2018-list-1"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → supercard: Parent company (100%, indirectly) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-syncapay","record":{"id":"r-wirecard-syncapay","from":"wirecard","to":"syncapay","status":"documented","role":"Seller, through the administrator, of Wirecard North America","period":"Before January 2021","claim_ids":["c-ins-santander"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → syncapay: Seller, through the administrator, of Wirecard North America [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-systemsatworkmy","record":{"id":"r-wirecard-systemsatworkmy","from":"wirecard","to":"systemsatwork-my","status":"documented","role":"Indirect parent company (100%, through Systems@Work)","period":"From December 2011","claim_ids":["c-str-2011-list"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → systemsatwork-my: Indirect parent company (100%, through Systems@Work) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-tolentino","record":{"id":"r-wirecard-tolentino","from":"wirecard","to":"tolentino","status":"documented","role":"Trustee of the TPA trust accounts, succeeding Citadelle","period":"From 20 February 2020","claim_ids":["c-tpa-rp-2019-file"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → tolentino: Trustee of the TPA trust accounts, succeeding Citadelle [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-tuscany-wirecard","record":{"id":"r-tuscany-wirecard","from":"tuscany","to":"wirecard","status":"documented","role":"Third party that paid EUR 10 million on behalf of the TPA partner Rising Sun (Senjo)","period":"2015","claim_ids":["c-tpa-rp-payers"],"kind":"pays","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"tuscany → wirecard: Third party that paid EUR 10 million on behalf of the TPA partner Rising Sun (Senjo) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdbank-unionpay","record":{"id":"r-wdbank-unionpay","from":"wd-bank","to":"unionpay","status":"documented","role":"Holder of an online-acquiring licence from China UnionPay","period":"From 2011","claim_ids":["c-bank-licences"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"wd-bank → unionpay: Holder of an online-acquiring licence from China UnionPay [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-unionpay","record":{"id":"r-wirecard-unionpay","from":"wirecard","to":"unionpay","status":"documented","role":"Online-acquiring licence held by Wirecard Bank (first non-Chinese bank)","period":"2011","claim_ids":["c-acq-newcastle"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wirecard → unionpay: Online-acquiring licence held by Wirecard Bank (first non-Chinese bank) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-vonerffa-wdacceptance","record":{"id":"r-vonerffa-wdacceptance","from":"von-erffa","to":"wd-acceptance-tech","status":"documented","role":"Holder of joint power of attorney (Gesamtprokura)","period":"19 January 2018 to 30 June 2020","claim_ids":["c-lead-newsubs-officers"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"von-erffa → wd-acceptance-tech: Holder of joint power of attorney (Gesamtprokura) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-vonknoop-wdluxembourg","record":{"id":"r-vonknoop-wdluxembourg","from":"von-knoop","to":"wd-luxembourg","status":"documented","role":"Member of the board of directors","period":"Until a publication of 28 August 2020","claim_ids":["c-lead-lux-board"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"von-knoop → wd-luxembourg: Member of the board of directors [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdtech-wdacceptance","record":{"id":"r-wdtech-wdacceptance","from":"wd-tech","to":"wd-acceptance-tech","status":"documented","role":"Parent company","period":"Recorded in 2019","claim_ids":["c-str-wdtech-holding"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wd-tech → wd-acceptance-tech: Parent company [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdasia","record":{"id":"r-wirecard-wdasia","from":"wirecard","to":"wd-asia-holding","status":"documented","role":"Parent company (100%, indirectly)","period":"Recorded in 2018","claim_ids":["c-str-2018-list-1"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-asia-holding: Parent company (100%, indirectly) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdaustralia","record":{"id":"r-wirecard-wdaustralia","from":"wirecard","to":"wd-australia","status":"documented","role":"Parent company (100%)","period":"Recorded in 2018","claim_ids":["c-str-2018-list-2"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-australia: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdbank-xolo","record":{"id":"r-wdbank-xolo","from":"wd-bank","to":"xolo","status":"documented","role":"Account bank behind the IBAN accounts the service provider offered to e-residents (new accounts suspended after the parent's insolvency filing)","period":"From March 2020","claim_ids":["c-bank-after-insolvency"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"wd-bank → xolo: Account bank behind the IBAN accounts the service provider offered to e-residents (new accounts suspended after the parent's insolvency filing) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdcomm","record":{"id":"r-wirecard-wdcomm","from":"wirecard","to":"wd-comm-services","status":"documented","role":"Parent company (100%)","period":"Recorded in 2018","claim_ids":["c-str-2018-list-2"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-comm-services: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdhk","record":{"id":"r-wirecard-wdhk","from":"wirecard","to":"wd-hk","status":"documented","role":"Parent company (100%)","period":"Recorded in 2018","claim_ids":["c-str-2018-list-2"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-hk: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdindia","record":{"id":"r-wirecard-wdindia","from":"wirecard","to":"wd-india","status":"documented","role":"Parent company (100%)","period":"Recorded in 2018","claim_ids":["c-str-2018-list-1"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-india: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdsih-wdindonesia","record":{"id":"r-wdsih-wdindonesia","from":"wd-sih","to":"wd-indonesia","status":"documented","role":"Parent company","period":"Until the sale in the insolvency","claim_ids":["c-ins-romania"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wd-sih → wd-indonesia: Parent company [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdtech-wdissuing","record":{"id":"r-wdtech-wdissuing","from":"wd-tech","to":"wd-issuing-tech","status":"documented","role":"Parent company","period":"Recorded in 2019","claim_ids":["c-str-wdtech-holding"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wd-tech → wd-issuing-tech: Parent company [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdmalaysia","record":{"id":"r-wirecard-wdmalaysia","from":"wirecard","to":"wd-malaysia","status":"documented","role":"Parent company (100%)","period":"Recorded in 2010 and 2011","claim_ids":["c-str-2011-list"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wirecard → wd-malaysia: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdmexico","record":{"id":"r-wirecard-wdmexico","from":"wirecard","to":"wd-mexico","status":"documented","role":"Parent company (100%)","period":"Recorded in 2018","claim_ids":["c-str-2018-list-1"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-mexico: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdmyanmar","record":{"id":"r-wirecard-wdmyanmar","from":"wirecard","to":"wd-myanmar","status":"documented","role":"Parent company (100%)","period":"Recorded in 2018","claim_ids":["c-str-2018-list-1"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-myanmar: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdnz","record":{"id":"r-wirecard-wdnz","from":"wirecard","to":"wd-nz","status":"documented","role":"Parent company (100%)","period":"Recorded in 2018","claim_ids":["c-str-2018-list-2"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-nz: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdpoland","record":{"id":"r-wirecard-wdpoland","from":"wirecard","to":"wd-poland","status":"documented","role":"Parent company (100%)","period":"Recorded in 2018","claim_ids":["c-str-2018-list-1"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-poland: Parent company (100%) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-white-wdpsh","record":{"id":"r-white-wdpsh","from":"white","to":"wd-psh","status":"documented","role":"Director and company secretary","period":"Recorded in the Irish register","claim_ids":["c-lead-wpsh-directors"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"white → wd-psh: Director and company secretary [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wirecard-wdsasolutions","record":{"id":"r-wirecard-wdsasolutions","from":"wirecard","to":"wd-sa-solutions","status":"documented","role":"Parent company (100%, directly or indirectly)","period":"Recorded in 2019","claim_ids":["c-str-2019-list"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"wirecard → wd-sa-solutions: Parent company (100%, directly or indirectly) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-wdsih-wdvietnam","record":{"id":"r-wdsih-wdvietnam","from":"wd-sih","to":"wd-vietnam","status":"documented","role":"Parent company","period":"Until the sale in the insolvency","claim_ids":["c-ins-romania"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"wd-sih → wd-vietnam: Parent company [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-sta-braun","record":{"id":"r-sta-braun","from":"sta-muenchen","to":"braun","status":"documented","role":"Charged him (indictment of 10 March 2022; trial before the Munich I regional court since 8 December 2022)","period":"From 2020","claim_ids":["c-crim-indictment-2022","c-crim-charges-accounts","c-crim-charges-market","c-crim-trial","c-tpa-bka","c-mca-ocap-selection","c-mca-ocap-flow","c-mca-security-deposit"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"sta-muenchen → braun: Charged him (indictment of 10 March 2022; trial before the Munich I regional court since 8 December 2022) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-sta-vonerffa","record":{"id":"r-sta-vonerffa","from":"sta-muenchen","to":"von-erffa","status":"documented","role":"Charged him (indictment of 10 March 2022; joint trial with Braun)","period":"From 2020","claim_ids":["c-crim-indictment-2022","c-crim-charges-accounts","c-crim-von-erffa-admission"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"sta-muenchen → von-erffa: Charged him (indictment of 10 March 2022; joint trial with Braun) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-sta-bellenhaus","record":{"id":"r-sta-bellenhaus","from":"sta-muenchen","to":"bellenhaus","status":"documented","role":"Charged him (indictment of 10 March 2022; joint trial with Braun)","period":"From 2020","claim_ids":["c-crim-indictment-2022","c-crim-charges-accounts","c-crim-bundestag-witnesses","c-crim-dubai-arrest"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"sta-muenchen → bellenhaus: Charged him (indictment of 10 March 2022; joint trial with Braun) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-sta-ley","record":{"id":"r-sta-ley","from":"sta-muenchen","to":"ley","status":"documented","role":"Indicted him on 12 December 2023","period":"From 2023","claim_ids":["c-crim-ley"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"sta-muenchen → ley: Indicted him on 12 December 2023 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-sta-vonknoop","record":{"id":"r-sta-vonknoop","from":"sta-muenchen","to":"von-knoop","status":"documented","role":"Indicted him on 31 July 2024 (breach of trust)","period":"From 2024","claim_ids":["c-crim-knoop-steidl"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"sta-muenchen → von-knoop: Indicted him on 31 July 2024 (breach of trust) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-sta-steidl","record":{"id":"r-sta-steidl","from":"sta-muenchen","to":"steidl","status":"documented","role":"Indicted her on 31 July 2024 (breach of trust)","period":"From 2024","claim_ids":["c-crim-knoop-steidl"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"sta-muenchen → steidl: Indicted her on 31 July 2024 (breach of trust) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-sta-marsalek","record":{"id":"r-sta-marsalek","from":"sta-muenchen","to":"marsalek","status":"documented","role":"Seeks him on an arrest warrant","period":"From 2020","claim_ids":["c-crim-marsalek-wanted","c-tpa-bka"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"sta-muenchen → marsalek: Seeks him on an arrest warrant [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-bka-marsalek","record":{"id":"r-bka-marsalek","from":"bka","to":"marsalek","status":"documented","role":"Lists him as a wanted person","period":"From 2020","claim_ids":["c-crim-marsalek-wanted","c-mar-career","c-mar-screening","c-mar-belarus"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"bka → marsalek: Lists him as a wanted person [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-sta-holten","record":{"id":"r-sta-holten","from":"sta-muenchen","to":"holten","status":"documented","role":"Investigated him; investigation closed (confirmed by his lawyer in July 2024)","period":"Until 2024","claim_ids":["c-crim-holten"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"sta-muenchen → holten: Investigated him; investigation closed (confirmed by his lawyer in July 2024) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-braun-kapmug","record":{"id":"r-braun-kapmug","from":"braun","to":"bayoblg","status":"documented","role":"Model defendant 1 in the investor model proceeding 101 Kap 1/22","period":"From 2023","claim_ids":["c-civ-kapmug-parties","c-civ-kapmug-allegations","c-civ-kapmug-may2024"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"braun → bayoblg: Model defendant 1 in the investor model proceeding 101 Kap 1/22 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-ey-kapmug","record":{"id":"r-ey-kapmug","from":"ey","to":"bayoblg","status":"documented","role":"Model defendant 2 in the investor model proceeding 101 Kap 1/22","period":"From 2023","claim_ids":["c-civ-ey-suits","c-civ-kapmug-parties","c-civ-kapmug-allegations","c-civ-kapmug-may2024"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"ey → bayoblg: Model defendant 2 in the investor model proceeding 101 Kap 1/22 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-vonknoop-kapmug","record":{"id":"r-vonknoop-kapmug","from":"von-knoop","to":"bayoblg","status":"documented","role":"Model defendant 5 in the investor model proceeding 101 Kap 1/22","period":"From 2023","claim_ids":["c-civ-kapmug-parties"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"von-knoop → bayoblg: Model defendant 5 in the investor model proceeding 101 Kap 1/22 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-marsalek-kapmug","record":{"id":"r-marsalek-kapmug","from":"marsalek","to":"bayoblg","status":"documented","role":"Model defendant 6 in the investor model proceeding 101 Kap 1/22","period":"From 2023","claim_ids":["c-civ-kapmug-parties","c-mar-belarus"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"marsalek → bayoblg: Model defendant 6 in the investor model proceeding 101 Kap 1/22 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-mb-kapmug","record":{"id":"r-mb-kapmug","from":"mb-beteiligung","to":"bayoblg","status":"documented","role":"Model defendant 7 in the investor model proceeding 101 Kap 1/22 (interrupted by its insolvency in 2024)","period":"From 2023","claim_ids":["c-civ-kapmug-parties","c-civ-kapmug-may2024"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"mb-beteiligung → bayoblg: Model defendant 7 in the investor model proceeding 101 Kap 1/22 (interrupted by its insolvency in 2024) [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-jaffe-kapmug","record":{"id":"r-jaffe-kapmug","from":"jaffe","to":"bayoblg","status":"documented","role":"Model defendant 8 in the investor model proceeding 101 Kap 1/22, as insolvency administrator of Wirecard AG","period":"From 2023","claim_ids":["c-civ-kapmug-parties"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"jaffe → bayoblg: Model defendant 8 in the investor model proceeding 101 Kap 1/22, as insolvency administrator of Wirecard AG [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"relationships","id":"r-bellenhaus-kapmug","record":{"id":"r-bellenhaus-kapmug","from":"bellenhaus","to":"bayoblg","status":"documented","role":"Model defendant 10 in the investor model proceeding 101 Kap 1/22","period":"From 2024","claim_ids":["c-civ-kapmug-parties"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"bellenhaus → bayoblg: Model defendant 10 in the investor model proceeding 101 Kap 1/22 [documented]"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-1999-incorporation","record":{"id":"e-1999-incorporation","date":"1999-05-06","title":"The company that became Wirecard AG is incorporated in Berlin","claim_ids":["c-id-registration"]},"reading":"1999-05-06 The company that became Wirecard AG is incorporated in Berlin"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2000-listing","record":{"id":"e-2000-listing","date":"2000-10-25","title":"Wirecard shares are listed","claim_ids":["c-own-2018"]},"reading":"2000-10-25 Wirecard shares are listed"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2006-xcom","record":{"id":"e-2006-xcom","date":"2006","title":"Wirecard buys XCOM and renames it Wirecard Bank","claim_ids":["c-bank-origin"]},"reading":"2006 Wirecard buys XCOM and renames it Wirecard Bank"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2007-munich","record":{"id":"e-2007-munich","date":"2007-08-06","title":"Wirecard AG is registered in Munich under HRB 169227","claim_ids":["c-id-registration","c-lead-2007-board"]},"reading":"2007-08-06 Wirecard AG is registered in Munich under HRB 169227"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2009-ecredit","record":{"id":"e-2009-ecredit","date":"2009-12-16","title":"Wirecard agrees to buy E-Credit Plus Pte. Ltd. of Singapore","claim_ids":["c-acq-ecredit"]},"reading":"2009-12-16 Wirecard agrees to buy E-Credit Plus Pte. Ltd. of Singapore"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2010-marsalek","record":{"id":"e-2010-marsalek","date":"2010-02-01","title":"Jan Marsalek joins the management board","claim_ids":["c-lead-2010-marsalek","c-lead-2010-board"]},"reading":"2010-02-01 Jan Marsalek joins the management board"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2011-newcastle","record":{"id":"e-2011-newcastle","date":"2011-12","title":"Wirecard takes over the Newcastle Building Society prepaid card business and buys Systems@Work","claim_ids":["c-acq-newcastle","c-acq-2011"]},"reading":"2011-12 Wirecard takes over the Newcastle Building Society prepaid card business and buys Systems@Work"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2015-gi","record":{"id":"e-2015-gi","date":"2015-10-27","title":"Wirecard signs agreements to buy the GI Retail payment business in India","claim_ids":["c-asia-gi-retail"]},"reading":"2015-10-27 Wirecard signs agreements to buy the GI Retail payment business in India"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2016-concurrence","record":{"id":"e-2016-concurrence","date":"2016-03-03","title":"EY's concurrence memorandum on Wirecard's role in third-party acquiring","claim_ids":["c-aud-rp-concurrence"]},"reading":"2016-03-03 EY's concurrence memorandum on Wirecard's role in third-party acquiring"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2016-ring","record":{"id":"e-2016-ring","date":"2016-09-12","title":"The management board instructs EY's forensic service to carry out Projekt Ring","claim_ids":["c-asia-ring-mandate"]},"reading":"2016-09-12 The management board instructs EY's forensic service to carry out Projekt Ring"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2017-citi","record":{"id":"e-2017-citi","date":"2017-03-09","title":"The purchase of Citi Prepaid Card Services closes","claim_ids":["c-acq-2017"]},"reading":"2017-03-09 The purchase of Citi Prepaid Card Services closes"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2017-opinion","record":{"id":"e-2017-opinion","date":"2017-04-05","title":"EY signs an unqualified opinion on the 2016 consolidated accounts","claim_ids":["c-asia-ring-opinion"]},"reading":"2017-04-05 EY signs an unqualified opinion on the 2016 consolidated accounts"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2018-sg","record":{"id":"e-2018-sg","date":"2018-05-04","title":"Preliminary law-firm report on the Singapore whistleblower allegations","claim_ids":["c-asia-sg-whistleblower"]},"reading":"2018-05-04 Preliminary law-firm report on the Singapore whistleblower allegations"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2018-rcf","record":{"id":"e-2018-rcf","date":"2018-06-15","title":"EUR 1,750 million syndicated revolving credit facility","claim_ids":["c-fin-rcf-2018"]},"reading":"2018-06-15 EUR 1,750 million syndicated revolving credit facility"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2018-dax","record":{"id":"e-2018-dax","date":"2018-09","title":"Wirecard AG enters the DAX 30 index","claim_ids":["c-id-dax"]},"reading":"2018-09 Wirecard AG enters the DAX 30 index"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2019-ft","record":{"id":"e-2019-ft","date":"2019-01-30","title":"The Financial Times reports the Singapore whistleblower allegations","claim_ids":["c-asia-sg-ft","c-aud-rp-2018-audit"]},"reading":"2019-01-30 The Financial Times reports the Singapore whistleblower allegations"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2019-shortban","record":{"id":"e-2019-shortban","date":"2019-02","title":"BaFin bans short selling of Wirecard shares","claim_ids":["c-sup-short-ban"]},"reading":"2019-02 BaFin bans short selling of Wirecard shares"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2019-fine","record":{"id":"e-2019-fine","date":"2019-04-15","title":"BaFin fines Wirecard AG EUR 1.52 million for reporting breaches","claim_ids":["c-sup-fine-2019"]},"reading":"2019-04-15 BaFin fines Wirecard AG EUR 1.52 million for reporting breaches"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2019-softbank","record":{"id":"e-2019-softbank","date":"2019-04-24","title":"Binding term sheet for the SoftBank-linked convertible bond","claim_ids":["c-fin-softbank"]},"reading":"2019-04-24 Binding term sheet for the SoftBank-linked convertible bond"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2019-bond","record":{"id":"e-2019-bond","date":"2019-09","title":"Wirecard AG issues EUR 500 million of 0.50% notes due 2024","claim_ids":["c-fin-bond-2019"]},"reading":"2019-09 Wirecard AG issues EUR 500 million of 0.50% notes due 2024"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2019-kpmg","record":{"id":"e-2019-kpmg","date":"2019-10-31","title":"KPMG begins its special investigation","claim_ids":["c-aud-kpmg-timeline"]},"reading":"2019-10-31 KPMG begins its special investigation"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2019-ruprecht","record":{"id":"e-2019-ruprecht","date":"2019-12-23","title":"Security deposit for Ruprecht Services raised to EUR 40 million, according to the prosecution","claim_ids":["c-mca-security-deposit"]},"reading":"2019-12-23 Security deposit for Ruprecht Services raised to EUR 40 million, according to the prosecution"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2020-ocap","record":{"id":"e-2020-ocap","date":"2020-03-27","title":"EUR 100 million reaches OCAP and is transferred on the same day, according to the prosecution","claim_ids":["c-mca-ocap-flow"]},"reading":"2020-03-27 EUR 100 million reaches OCAP and is transferred on the same day, according to the prosecution"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2020-kpmg-report","record":{"id":"e-2020-kpmg-report","date":"2020-04-28","title":"KPMG's report is published; Wirecard announces that it found no evidence of manipulation","claim_ids":["c-aud-kpmg-adhoc","c-aud-kpmg-esma"]},"reading":"2020-04-28 KPMG's report is published; Wirecard announces that it found no evidence of manipulation"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2020-search","record":{"id":"e-2020-search","date":"2020-06-05","title":"Prosecutors search Wirecard's premises","claim_ids":["c-sup-2020-complaints"]},"reading":"2020-06-05 Prosecutors search Wirecard's premises"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2020-06-18","record":{"id":"e-2020-06-18","date":"2020-06-18","title":"EY cannot confirm EUR 1.9 billion on trust accounts; Marsalek is suspended","claim_ids":["c-tpa-adhoc-2020-06-18","c-lead-2020-suspension"]},"reading":"2020-06-18 EY cannot confirm EUR 1.9 billion on trust accounts; Marsalek is suspended"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2020-braun","record":{"id":"e-2020-braun","date":"2020-06-19","title":"Markus Braun resigns from the management board","claim_ids":["c-lead-2020-braun-exit"]},"reading":"2020-06-19 Markus Braun resigns from the management board"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2020-06-22","record":{"id":"e-2020-06-22","date":"2020-06-22","title":"Wirecard says the EUR 1.9 billion probably does not exist","claim_ids":["c-tpa-2020-06-22"]},"reading":"2020-06-22 Wirecard says the EUR 1.9 billion probably does not exist"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2020-filing","record":{"id":"e-2020-filing","date":"2020-06-25","title":"Wirecard AG applies to open insolvency proceedings","claim_ids":["c-ins-petition"]},"reading":"2020-06-25 Wirecard AG applies to open insolvency proceedings"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2020-opening","record":{"id":"e-2020-opening","date":"2020-08-25","title":"Insolvency proceedings opened; Michael Jaffé appointed administrator","claim_ids":["c-ins-opening"]},"reading":"2020-08-25 Insolvency proceedings opened; Michael Jaffé appointed administrator"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2020-esma","record":{"id":"e-2020-esma","date":"2020-11-03","title":"ESMA publishes its peer review of BaFin and FREP","claim_ids":["c-sup-esma-findings"]},"reading":"2020-11-03 ESMA publishes its peer review of BaFin and FREP"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2020-bundestag","record":{"id":"e-2020-bundestag","date":"2020-11-19","title":"Braun and Bellenhaus decline to answer the Bundestag committee of inquiry","claim_ids":["c-crim-bundestag-witnesses"]},"reading":"2020-11-19 Braun and Bellenhaus decline to answer the Bundestag committee of inquiry"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2021-santander","record":{"id":"e-2021-santander","date":"2021-01-28","title":"Sale of the European technology platform to the Santander group closes","claim_ids":["c-ins-santander"]},"reading":"2021-01-28 Sale of the European technology platform to the Santander group closes"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2021-report","record":{"id":"e-2021-report","date":"2021-04-16","title":"The special investigators deliver their report on EY's audits","claim_ids":["c-tpa-rp-scope"]},"reading":"2021-04-16 The special investigators deliver their report on EY's audits"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2022-indictment","record":{"id":"e-2022-indictment","date":"2022-03-10","title":"Braun, von Erffa and Bellenhaus are charged","claim_ids":["c-crim-indictment-2022"]},"reading":"2022-03-10 Braun, von Erffa and Bellenhaus are charged"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2022-void","record":{"id":"e-2022-void","date":"2022-05-05","title":"Court declares Wirecard AG's 2017 and 2018 annual accounts void","claim_ids":["c-ins-annulment"]},"reading":"2022-05-05 Court declares Wirecard AG's 2017 and 2018 annual accounts void"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2022-sg-charges","record":{"id":"e-2022-sg-charges","date":"2022-08-17","title":"Singapore police charge three former Wirecard Asia Holding employees","claim_ids":["c-asia-sg-charges-2022"]},"reading":"2022-08-17 Singapore police charge three former Wirecard Asia Holding employees"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2022-trial","record":{"id":"e-2022-trial","date":"2022-12-08","title":"The criminal trial begins in Munich","claim_ids":["c-crim-trial"]},"reading":"2022-12-08 The criminal trial begins in Munich"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2023-apas","record":{"id":"e-2023-apas","date":"2023-03-31","title":"Auditor oversight body finds breaches of professional duties in the 2016–2018 audits","claim_ids":["c-aud-apas"]},"reading":"2023-03-31 Auditor oversight body finds breaches of professional duties in the 2016–2018 audits"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2023-sg-convictions","record":{"id":"e-2023-sg-convictions","date":"2023-06-20","title":"Two former Wirecard Asia Holding employees are convicted in Singapore","claim_ids":["c-asia-sg-convictions-2023"]},"reading":"2023-06-20 Two former Wirecard Asia Holding employees are convicted in Singapore"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2023-ley","record":{"id":"e-2023-ley","date":"2023-12-12","title":"The former chief financial officer is indicted","claim_ids":["c-crim-ley"]},"reading":"2023-12-12 The former chief financial officer is indicted"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2024-knoop-steidl","record":{"id":"e-2024-knoop-steidl","date":"2024-07-31","title":"Two further former board members are indicted","claim_ids":["c-crim-knoop-steidl"]},"reading":"2024-07-31 Two further former board members are indicted"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2024-civil","record":{"id":"e-2024-civil","date":"2024-09-05","title":"Civil court orders three former board members to pay EUR 140 million","claim_ids":["c-mca-civil-judgment"]},"reading":"2024-09-05 Civil court orders three former board members to pay EUR 140 million"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2025-restriction","record":{"id":"e-2025-restriction","date":"2025-02-27","title":"The criminal chamber limits the charges","claim_ids":["c-crim-trial"]},"reading":"2025-02-27 The criminal chamber limits the charges"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2025-roussev","record":{"id":"e-2025-roussev","date":"2025-05-12","title":"London sentencing remarks record the prosecution's case that Marsalek was the agent in a Russian spy case","claim_ids":["c-mar-uk-trial"]},"reading":"2025-05-12 London sentencing remarks record the prosecution's case that Marsalek was the agent in a Russian spy case"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2025-bgh-shareholders","record":{"id":"e-2025-bgh-shareholders","date":"2025-11-13","title":"Federal Court of Justice rules on shareholders' claims in the insolvency","claim_ids":["c-ins-bgh-shareholders"]},"reading":"2025-11-13 Federal Court of Justice rules on shareholders' claims in the insolvency"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2025-bgh-files","record":{"id":"e-2025-bgh-files","date":"2025-12-11","title":"Federal Court of Justice upholds the administrator's claims to the auditor's working files","claim_ids":["c-aud-bgh-files"]},"reading":"2025-12-11 Federal Court of Justice upholds the administrator's claims to the auditor's working files"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2026-extradition","record":{"id":"e-2026-extradition","date":"2026-03-30","title":"Brigitte Häuser-Axtner is extradited from Singapore to Germany","claim_ids":["c-crim-haeuser-axtner"]},"reading":"2026-03-30 Brigitte Häuser-Axtner is extradited from Singapore to Germany"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2026-ocap","record":{"id":"e-2026-ocap","date":"2026-05-13","title":"Singapore's High Court rules on oCap Management's restrained funds","claim_ids":["c-mca-ocap-singapore-2026"]},"reading":"2026-05-13 Singapore's High Court rules on oCap Management's restrained funds"}
{"case_id":"wirecard-ag","version":"1.0","as_of":"2026-10-21","record_type":"events","id":"e-2026-judge","record":{"id":"e-2026-judge","date":"2026-09-14","title":"Presiding judge reportedly sees no indication that the TPA business existed","claim_ids":["c-crim-judge-2026"]},"reading":"2026-09-14 Presiding judge reportedly sees no indication that the TPA business existed"}