Wirecard through money laundering glasses: Reflections on possible accounting fraud and money laundering schemes at Wirecard

author: Dick Crijns

Content

I will first briefly review Wirecard's activities and then what is known about a number of potential frauds that now appear to be emerging. In concluding, I will discuss a number of signals surrounding this case that may have to do with money laundering and focus on other involvement in money laundering than is now emerging from possible investigations in the USA and Germany. I will also, partly in view of the training provided by the AMLC for accountants and others, give a number of points for attention for this target group. To be clear, my goal with this article is not to pass judgment on the Wirecard case, I am happy to leave that to the authorities in other countries. My goal is to place the factual complex that now seems to emerge more generally in a fraud and money laundering perspective and, above all, to see if we cannot already learn something from this case for recognizing large-scale and organized money laundering in which Wirecard may be consciously or unconsciously involved.

What kind of company is Wirecard

Wirecard appears to have originated both factually and materially at the turn of the century. It has been listed on several German stock exchanges from its inception and, as of 2018, on the DAX.(1) The main activity that is important for understanding the relevant facts is that they handle payments between sellers and buyers of, in particular, transactions done online. Importantly, they do not themselves interact with the buyers and sellers. Wirecard is the middle man for the companies that do have this direct relationship such as credit card organizations. Therefore, Wirecard is often referred to as a payment processor. What they do is that once you make a purchase online with your credit/debit card or similar instruments, they make sure that the issuing bank or more specifically the bank account where the money (your balance) is held is charged for the purchase. After this, Wirecard ensures that the money is then transferred to the seller's bank account.

So, in fact, a very simple process that, however, requires you to have good technical facilities to handle it quickly but, above all, securely. Wirecard seems to have done this very well for many years both technically and in terms of risk because it grew very strongly and more and more reputable parties, including KLM, involved Wirecard in their chain of payment processing. In addition to this growth through new customers, many acquisitions were made or deals were closed with large parties to handle all processing of "digital" payments for them. These include parties such as City-bank but also telecom providers.

Wirecard has operations in a large number of countries around the world but not everywhere, and for that reason also has relationships with third-party providers who also handle payments but have access to the countries/markets where Wirecard itself was not. In fact, we are already getting to the heart of where the problems seem to be. Through 2 of its own branches in particular (in Ireland and Dubai), more and more transactions were being handled from these third parties in countries such as Dubai, Philippines and Singapore. The suspicion now is that these transactions, which even amounted to 60% or more of sales, were actually fake. At Wirecard, at least €1.9 billion appears to have disappeared which had some relation to these transactions. The amount was held through collateral accounts (so-called escrow accounts) on behalf of Wirecard with Philippine banks. Disappeared is perhaps an understatement. In fact, it seems to have never even been there.

Available information from open sources

After the first signs come as early as 2016, it doesn't actually begin until spring 2019 when the Financial Times, in particular, brings out information that it is implausible that certain third parties are partly responsible for the revenue increases and the huge number of transactions going through Wirecard. It starts with businesses in the Philippines located at the address of a marginal bus company and charged through Singapore. This also already indicates that the necessary information and substantiation that you would expect from a publicly traded financial company like this is lacking. That this has been going on for years is substantiated, among other things, by spreadsheets and emails from 2016-2018 published by the Financial Times. After summer 2019, the Financial Times goes further and publishes that there are similar doubts with the very important Dubai partner (Al Alam) as well, in part because Al Alam has only 6 employees. This could still be explained if Al Alam is only an administrative intermediary. What does make it strange is that major credit card organizations do not seem to know this so-called third party aquirer.

Wirecard always responds immediately to such publications by saying that the Financial Times (and other journalists) are being used by "shortsellers" hoping to profit from a share price drop.

In the fall of 2019, the pressure on Wirecard becomes so great that they ask KPMG as an independent auditor to investigate these allegations. In December, there are again publications that these major Wirecard customers are actually not much. In April 2020, KPMG comes out with a report that Wirecard perceives completely differently from investors. Or as the FD puts it neatly in the headline "Wirecard feels exonerated by KPMG report, investors not convinced." Conclusion is that the uncertainty about the third party turnover could not be removed and the necessary documentation for substantiation could not be presented. At the end of June, Wirecard must again postpone the publication of its annual figures because the auditor (EY) could not issue a statement. On June 23, EY even brings out that "There are clear indications Wirecard was involved in a fraud with multiple parties around the world in different institutions."

The downward spiral with the exchange fund then quickly set in and eventually the key executives also left and a criminal investigation began in Germany and elsewhere. The conclusion seems to be that Wirecard falsely overstated its records and financial statements for years.

These possible criminal acts are therefore quickly compared, with good reason, to the frauds at Enron, Ahold, Imtech but also Parmalat. In essence, Wirecard thus appears to have influenced the financial statements and thereby misled investors, investors, banks and especially the public.

The trick used has been known in the financial world for years and even has its own name namely "roundtripping. What this amounts to is fingering high turnovers and accompanying income by running the same trades through your books over and over again. Depending on your importance as a stock fund, this allows you to both show that you are experiencing increasing market growth which is often seen as a sign of a healthy company with especially good future prospects and also that you are very profitable. This pumping around of money and thus showing extra turnover is still possible for most companies, but especially showing and justifying where the related profit remains is more complex in practice. At Wirecard, they tried to hide the money/assets associated with these transactions by indicating that these amounts were held in banks in Asia.

However, the fraud did not yet come to the fore through the focused investigation by KPMG because materially they did not find more than that they could not verify the turnover and found flaws in Wirecard's compliance in particular. The fraud only really emerged when the auditor EY itself went to inquire at the banks in the Philippines about the existence of the amounts held there on behalf of Wirecard and learned there that they had never been held.

Alarm bells for accountant

Of course, the question that many now raise is obvious, how is it possible that the auditor did not use this balance inquiry as part of his audit tools earlier and did not critically investigate the existence of these receivables. As Marcel Pheijffer nicely put it in NRC, "Why do you choose to keep such a large amount in an account far outside Germany, in a country where you have relatively few activities?". Moreover: the amount allegedly held there, at €1.9 billion, was 5% of the amount held in foreign currency assets there, according to the head of the AMLC in the Philippines. An amount of 100 million would already have been a big red flag according to him, so certainly the 20-fold. Even a simple look at the financial statements and financing structure could have raised questions for the auditor or other interested parties. How is it possible that this company had a structural picture of 3 billion in financial assets (including the now-defunct 1.9) and at the same time 1.75 in loans with banks? This was remarkable to say the least. In short, I share the opinions of many that there were at least the necessary red flags here.

But just as important, rather than just observing this in retrospect, is the point of how Wirecard was able to let this go unnoticed for years.

In this context, it is very nice to point to the documents (spreadsheets and emails from Wirecard) I mentioned earlier that have also been made public by the Financial Times. From these, it is clear that at least in 2018, there was already very deliberate thinking by Wirecard about how the auditors proceeded in their annual audit. In short, the bottom line is that as long as there is no write-off risk with the customers then the auditor is fine. The text of the internal email from Lars Rasteder (M&A manager and as a former accounting firm employee point of contact for the external auditor) to Edo Kurniawan (responsible for group companies in Asia) speaks volumes: "There is a reason our practice is called "triggering event analysis" If in 2017 Maxcone generates more Gross Profit than annual depreciation, EY has to accept it. No fuc**ing Impairment Test is necessary!" So Wirecard makes sure to produce neat statements showing that there is no risk with any of those large customers.

That these customer(s) account for as much as 60% of Wirecard's revenue and appear to owe them another 1.9 billion is irrelevant, seems to be the picture. It becomes perhaps even more extraordinary when you also see that there are already emails in 2016 indicating that the auditor is requesting substantiation of revenue/income. The employee who is clearly responsible for supplying the turnover figures for what later appears to be one of the tainted companies then asks the aforementioned Edo how he thinks the employee should make this statement for the accountant when he only gets a quarterly statement of the turnover to be booked without the supporting documents to back it up. "How would you like to approach this topic as regards documenting how revenue is booked here as I only get a report usually quarterly to book revenue without the back up data to support the calculations?"

These two examples paint a picture that certain detailed information was very skillfully kept away from the auditor and that, above all, it was ensured that the auditor had no reason to ask further questions either.

Spreadsheets made public by the Financial Times, which seem to match up reasonably well with the mail correspondence, also indicate that there are some other details around revenue booking. The commission Wirecard receives on what may be the tainted transactions appear to have not been billed over the entire^2nd quarter 2017 well past that quarter. I am very much aware that billions from these third-parties were going through the books (and possibly even over suspense accounts) at Wirecard. But a company that did not invoice its commission for an entire quarter? One would expect that this too would have at least raised questions. Or again, was it ensured that the auditor never looked at any underlying transaction?

In summary, it looks very much like the auditors were given professionally orchestrated information for years, with the score completely determined by how the auditors were supposed to do their jobs. So everything looked perfect and there was no reason to do detailed research. Consequently, the auditor does not appear to have done so.

Besides questioning how the accountant did his job, there is more. All the normal triggers that should have been noticed when looking with some distance at the client itself or at the market in which they operate (such as sales growth; type of clients; geographic make-up) seem not to have been picked up. Third, normal financial and prudential analyses (e.g. bank debt to balance ratio) should also have been triggers here that needed to be looked at further. This looking with distance is also an important point in recognizing possible crimes and money laundering.

The interests of the criminal

Now if we want to put the information that emerges into perspective, we will have to think from the criminal's point of view. What could be the motivations for defrauding Wirecard's business activities? Here I distinguish self-enrichment (where the loot must be laundered again), personal status, and laundering of money obtained through another criminal land crime.

Self-enrichment

Let's go back to 2004 when Markus Braun gets power at the very small publicly traded company InfoGenie AG. The company is then a so-called penny-stock fund so the shares are worth next to nothing. By then Braun has been CEO (and shareholder) at Wirecard for 2 years. At the end of December it is decided to contribute Wirecard to the virtually worthless stock fund in the form of a (share) capital contribution. In fact, Wirecard thus simply became a stock market fund, and the Wirecard shareholders became the major shareholders. Wirecard then grows steadily in terms of sales and profits and continues to grow on the German stock exchange until finally listing on the DAX in September 2018.

a. The bonus as an interest for fraud
When the Wirecard financial statements are examined, it is striking that the CEO and his staff (including the COO Jan Marsalek, to be discussed below), in addition to a good salary, are also very well rewarded with additional rewards that seem to depend, among other things, on the performance (the EBITDA) of the fund. Thus, the obvious thing to recognize as a possible interest is that pumping up the accounts was intended to serve this financial interest of salary and bonus of these individuals.

b. Favorable acquisitions as interest for fraud
In addition to this bonus, however, there are more interests. We also see that Wirecard grew in part because of acquisitions that were paid for with shares. So the higher the stock market value was, the more the shares were worth and the fewer shares one had to pay for. The interest in getting hold of valuable companies at the lowest possible price was thus served by a high stock market value that could be obtained through inflated accounting.

The question here, of course, is how the stakeholders behind the fraud could then benefit again. Two possible directions:

1) The Hermes case study:
Wirecard has been struggling for years to acquire the Hermes I-Tickets Private Ltc company. As written in the introduction, acquisitions and purchases of companies gave them additional revenue and access to certain markets/areas, in this case India. What is striking is that shortly before the purchase of Hermes, suddenly Emerging Market Investment Fund (EMIF), a Mauritius-based private equity fund, comes into the picture. They buy Hermes for an undisclosed amount, but according to the old owners, it is a fraction of the price of over €300 million for which it is resold weeks later, along with another company, to Wirecard. After this, EMIF in turn invests another 50 million in a third company which, both directly and through affiliated other companies, again buys software for considerable sums from Hermes which meanwhile belongs to Wirecard. Of course, everything may be quite legal, but in this way a substantial amount of profit may also have been very easily created at Wirecard with the sale of the software. But even more striking and relevant to recognizing the interest that one could possibly have in the Hermes purchases and sales is that there is also strong evidence that the COO of Wirecard (Marsalek) is affiliated with EMIF which has made a significant profit.

Sham litigation as legitimization and cover up?
By the way, there are several lawsuits surrounding this case. Recently, an English judge indicated that he did not need additional documents because the case of the old owners against Wirecard could actually be settled without further proceedings. Of course, once again, it may be a regular (civil) case. However, conducting "sham litigations" in order to legitimize transactions is a well-known fact within the money laundering world.(2)

2) Payment for "3D secure tokenization" software:
Returning for a moment to being able to profit from purchases and falsely extracting funds from a company. Back in 2019, the Financial Times described that once again the Indian branch of Wirecard allegedly bought "3D secure tokenization" software for 3 million. The payments were again made through Hermes, among others. However, the seller did not know both the buyer and the product sold. Even stronger, they did not do business in India. In short, an expenditure of 3 million for no reason. The question is where did this money go? Who had an interest in Wirecard spending 3 million? Incidentally, the financial settlement does seem to have gone entirely through Wirecard's own channels.

I would summarize these variants as modus operandi involving actual "theft" of funds from Wirecard by overpaying or paying for non-existent products. There is obvious use of deliberately set up concealment schemes and falsifications. It is therefore obvious that the funds obtained were then flowed back to the fraudsters using a concealed construction, possibly including the Wirecard executives. If evidence of this were found, this would most likely be characterized in the Netherlands as money laundering in its pure form.

c. Overvalued shares as interest for fraud
Another very obvious reason for driving up the stock price as much as possible is to sell the shares to unsuspecting investors and in this way obtain financial gain from the sellers of the shares. As indicated earlier, Wirecard became a stock fund because of the company's contribution to the penny-stock fund after which the owners of Wirecard obtained the shares. That the CEO was one of the major shareholders may become clear when you see that, as I discuss later, he sold a very large stake in the company's stock shortly before the big clash.

Many more examples of self-enrichment could be cited, but for the move to money laundering, the previous examples are exemplary.

Social pressures and personal status

As already mentioned, I do not rule out the possibility that the previous interests were an important reason for acting. But we should also not close our eyes to the possibility that outside pressure (investors) to show good results and market growth were important drivers. This could be done, as indicated earlier, through the acquisition and, of course, full co-consolidation of the acquired companies. Payment with the overvalued shares was a perfect tool for this. For many of the CEOs cs of the companies involved in this type of fraud, social pressure was at play. Or as one of them put it a few years ago in a lecture for accountants and students at the University of Maastricht: "After working at the stock exchange fund for 3 months, I called my former colleagues to say: we thought we knew how to influence figures, but here at the company they really know how it works". When the audience asked why he had not quit and whether no one had warned him that he was playing a dangerous game, the answer was: "I had to perform for my shareholders and the analysts and in MY environment no naysayers. I was the entrepreneur of the year!" CEO Markus Braun and his staff may well have been in the same boat.

Speculating with shares in your own company as collateral.
On the subject of egos and financial interests, a brief comment which I promised and which may also give an idea of the interests at play. According to publications Braun was forced to sell a large part of his shares in Wirecard when the stock price started to fall sharply in connection with the publications about possible fraud. He had to increase the margin requirement by € 150 million. He had taken positions with borrowed money, with the result that in the already declining market an additional offer was made with this sale. That Braun is not alone in this construction of borrowing with shares in his own company as collateral becomes clear when we look back a few months. We then see that in April Goldman Sachs also forced Chinese billionaire Lu Zhengyao to sell a large portion of his stock, again to meet a margin requirement. An example of how a private investment can have major consequences, not only for the private person but also for the company, once one gets into dire straits.

The 'high end' money laundering scheme

I have so far focused on the private interests that may be behind the possible accounting fraud, both financial and ego/social pressures. But there may be entirely different interests at play here. And that brings us to a potential high end money laundering scheme.

The Americans are looking into Wirecard's involvement in criminal investigations into a drug marketplace where third-party payment processors were used to have credit card payments for the drugs handled. It is suggested that Wirecard played a role in this chain of handling payment for these purchases in several places. Incidentally, Wirecard in Germany is also said to have had a "visit" from the prosecution in 2015 in connection with a money laundering investigation in the U.S., and already in 2010 an investigation played out into a German who was handling unlicensed transactions related to gambling in online casinos in the U.S. where Wirecard was named. Apart from the U.S., Wirecard is also mentioned by many around the potential fraud at Payvision. The question is whether this is odd and whether there is real evidence that Wirecard knowingly played an active role in all of these potential frauds. That there are relationships between Wirecard and Payvision (or any of the others) is not at all strange. They each acted with their own specific characteristics within payment processing in the same market. And the fact that Wirecard handled payments in situations where an American was gambling or buying drugs through his bank or credit card is not surprising either; that is precisely their business model.

This is not where we should stop, more importantly, as many are now suggesting, we should start looking at that active involvement and the knowledge at Wirecard that they moved funds associated with crimes or derived from crimes (and had a role in a money laundering scheme). In the next chapter, I explore the high end money laundering scheme in greater depth.

Wirecard as a money laundering machine

Business model opportunities

It can be established that there are a number of elements in Wirecard's business model that are very interesting to a money launderer:

• Wirecard's primary activities are in the area of moving funds based on third-party buying and selling transactions. In doing so, Wirecard is never actually the bank or payment organization directly associated with the buyer and seller; any transactions with a money laundering purpose will not be readily recognized because there is no direct insight into the actual buying and selling.

• There are international money flows which, on the one hand, meets the money launderer's interest in moving money from one country to another or converting money into another currency and, on the other hand, makes the money flows more difficult to control.

• In addition, Wirecard is a company that handles a lot of transactions, so transactions that have the sole purpose of facilitating money laundering can easily blend in with the masses.

• Finally, because of its stock market listing, the company exudes a high degree of reliability. Who would suspect a publicly traded fund with all the associated controls of being involved in money laundering?

This makes Wirecard an ideal tool for money launderers to play a role in their money laundering scheme. But how could Wirecard be involved in this? And must there always have been active involvement and knowledge with Wirecard or could Wirecard also have been used unknowingly in a money laundering scheme?

Money laundering targets

The money launderer would use Wirecard in a money laundering scheme:

• can show large 'legitimate' profits by making profits on (fake) trades (legitimize) (see 1:'Creating profits via fake sales')

• use the trades to circumvent restrictions that prevent him from getting his black money into or out of a country or converting it into other currencies; think foreign exchange restrictions, strict anti-money laundering rules/gatekeepers, or sanctions measures (place, move, conceal) (see 2:'Using fake turnover to move money or convert currency')

I will show that these money laundering goals can be achieved not only by using Wirecard's trades, but also by using the exchange fund itself as a money laundering tool (see 3:"Using the exchange fund's own activities as a money laundering tool").

1. Create profits via fake turnover
In variant 1), the money laundering organization will be able to set up a large circulation of funds fairly easily, whereby funds originating from criminal parties are always converted via the same method into commercial transactions in which the profits end up with the seller or provider of the service. Behind this seller are the criminal groups who make legitimate profits in this way. Specifically, what can it look like? A business is chosen as the seller where there is no strong link between the revenue and the possibly goods. Think of gambling sites, porn or chat services or call centers where calls are made for high amounts of money. But ordinary Internet deliveries are also certainly suitable. The money launderer sets up an automated service (dialing in to the call center, for example, or making purchases from the Internet vendor). The payment is handled through the payment processor such as Wirecard. As a result, this new company turns out to have a booming business and makes a lot of profit. In the process before the money gets to the payment processor, the money is brought into the system along with lots of other legal transactions. Because this goes through multiple links, some of which are often opaque, it is virtually impossible to tell where the criminal organization's money came from.

Of course, the contribution can also be made transparently. However, the good money launderer will then make sure that the audit trail (the trace) of the money flow is complicated in some other way. Here you can think not only about the use of new payment methods such as Bitcoins and Monero etc. but also pre-paid debit cards or simply pre-paid phone cards (credits).

If we now take a look at what is known about Wirecard, we see that, as far as transactions can be traced, a very large portion now goes precisely to companies such as gambling, porn etc. That of the companies from which something can already be traced, it remains quite unclear how they can be very booming. That Wirecard, given the services they provide, works a lot for companies offering these kinds of services via the Internet is of course not strange in itself. But the large size and very strong growth in the volume of transactions is. But also the way in which the money flows through unclear companies in less transparent countries and partly the unclear and concealed structures that are used are at the very least reason for the Public Prosecutor's Office to take another look at these transactions. Which then certainly raises the question of whether Wirecard is knowingly or unknowingly involved. But given the size and active role that management has played in disguising the nature of the figures, I am beginning to have doubts as to whether Wirecard was not very deliberately set up to enable these types of transactions without too many questions.

The pros and cons of selling goods vs. services in a money laundering transaction
During the trainings I often get the question whether using goods-related Internet sales is not a risk and you, as a money launderer, should not use it. It is true that services such as gambling, porn, call centers, etc. are less risky because they are less easy to control. However, these branches are also seen as high risk. Therefore, the money launderer does not want to use these branches. Stronger still, he wants to prevent e.g. the accountant from refusing to issue a statement with the annual accounts (because that statement is precisely what the money launderer wants, namely trust and a semblance of legitimacy). And that only because an accounting firm does not want clients from these industries. This is why regular Internet trading is certainly so convenient. You just have to make sure that the buyer and seller both know that nothing will ever really be delivered and it's only about the seller's profit. So if the buyer and seller are from the same criminal organization there will never be any complaints and with the seller a stream of fake purchase invoices facing sales and shipping empty boxes is more than enough evidence.(3)

2. Via fake sales moving money or currency conversions
The previous modus operandi can be applied in an almost identical way for the^2nd interest. Because related to the fake sales or services, money must also be moved. Particularly if there is then a very large payment processor in between, which is listed on the stock exchange and comes from a country known for its "gründlichkeit" then the chance of questions is quite small. Here the big advantage is that it is now about the payment amount and not the profit made, so you can quickly move and convert a lot of money .

In short, if you are able as a criminal group to set up a company that sits in such a crucial place in the financial chain as Wirecard as a payment processor; if you are then also able to get it listed on the stock exchange and end up with a listing in the index of the largest stock exchange of a reliable country like Germany then you have a wonderful instrument in the need of organizing the money flows that you need in money laundering. Of course, you will then actually perform this service. Because the good money launderer will always blend his criminal activities into legitimate ones, because that way you don't stand out immediately. In fact, for years there were questions about the activities and the extent of the activities at Wirecard, but with the exception of a few journalists, we all didn't see it.

3. Using the stock market fund's own activities as a money laundering tool
However, I want to go a little further. If you do then own that stock market fund, the money launderer can also use that very reliable instrument. The fact that a stock market fund purchases participations, makes large investments and thus makes large payments related to it is not a question for anyone. Even stronger in this type of activity, large sums of money are often involved, everyone is convinced of that. So as a criminal, instead of having a lot of work setting up a system with fake transactions and possibly even going to send empty boxes as described in 1) and 2), why not just let me occasionally get paid for the sale of a new stake that can grow the stock market fund? That this company is a good investment and brings revenue may be obvious, because I then run the transactions I need under 1) and 2) through it. Whether the purchases made by Wirecard are also related to this I think would certainly be very useful to investigate again. The 2 deals described earlier around India do give an idea that Wirecard may not be a blank sheet.

If this variant has played out then there can in fact be no doubt that at least within Wirecard's top leadership there has been money laundering or other criminal activity in addition to influence peddling, but the facts will have to substantiate it.

Speculation in your own stock market fund as an instrument of money laundering
On this variant, a brief comment. A stock market fund lends itself particularly well to depositing legitimate profits with the investors or investors in these companies. If any fund has been subject to price fluctuations, it was Wirecard in recent years. Expertly, the response from Wirecard was always that these price fluctuations were caused by outsiders. So no one would look at the company itself. But if you look back now and see that, among other things, it is known about CEO Braun that he seemingly had a very large margining commitment and that there are also reports that he had already made large sales on at least 3 days prior to the problems, then the question also arises as to who were the other parties that have benefited from the price fluctuations in the past. Again, possibly everything was done entirely correctly within the (formal) rules. But if you see the necessary signs here that a stock market fund was clearly used here and possibly for money laundering then it is certainly worth investigating this option as well.

Completion

My goal with this article is not to say anything about Wirecard or possible individuals surrounding this case. The objective was at the request of many to project some of the options for fraud and money laundering onto the Wirecard case. I have done that as much as possible with the information that has come out. Whether that is all accurate information will have to be seen in retrospect. I have not necessarily wanted to be complete. Just like in our training 'Edje van Utrecht' I want to stimulate further thinking; if this is possible, so can this. Whether the possibilities I have mentioned actually happened, as was the case with the article on money laundering with games a few years ago,(4) will also have to be proven. It is noteworthy, however, that some of the options I had included in my first draft have already been substantiated by publications in the past two weeks.

It is precisely for this reason that I have chosen an open-ended article that I will certainly update as more information comes out. I have limited myself to things that are really relevant to money laundering fighters and also gatekeepers, such as accountants. That there is still much to tell around the disappeared COO who may have links to secret services, and that it is quite extraordinary that around the fall of Wirecard a known hacker group suddenly became very active I have left out.

If you have any questions as a result of this article, see new signs or want to investigate cases (for example, as a student), you can always contact the AMLC, where we work together to combat money laundering.

I conclude by wishing that for high-end money laundering, we will learn to "see things differently. More from the hypotheses of what the money launderer will do from his interest and how he takes advantage of situations that we see as normal or even trustworthy. I hope this article provides an impetus for this. In any case, I am going to take a closer look next time at particulars around stock market funds, because Wirecard has given us many additional red flags that in part should have been recognized in previous frauds.

Dick Crijns is a senior advisor at the Anti Money Laundering Center (ALMC).

Footnotes

(1) Index of value development of largest listed German companies
(2) Also listen to the podcast 'Money laundering in the news', available at https://www.amlc.nl/podcasts/
(3) Also listen to the podcast 'Business typologies', available at https://www.amlc.nl/podcasts/
(4) See https://www.amlc.nl/online-games-en-witwassen/ from 2016 and https://www.amlc.nl/witwassen-met-fortnite/ from 2019