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interpretation.

40
 Wirecard AG (WDI GR)
Wirecard’s Underhand Practices & How It Incriminated Itself

50
 Summary of Findings
Wirecard AG  Wirecard has avoided publicly responding to the issues we raised. Instead, Wirecard has
Ticker: WDI GR
disseminated false and misleading information to ‘Sell Side’ analysts and Investors.
Exchange: Xetra
 Wirecard has been caught in one of its lies. Having been confronted with evidence from
Price Target: €0/share
UK Companies House, Wirecard now admits it did incorporate Wire Card UK Ltd.
Share Price: €37.68
 This is a significant and devastating admission that directly connects Wirecard to online
Market Cap: €4.67B gambling companies and companies laundering money into the United States.
52-week high: €48.96
 The United States Secret Service was unaware of Wirecard's incriminating connections
52-week low: €31.88 to these companies at the time of its investigation. The important company filings that
Shares count: 123.6M60 show these connections were filed after the U.S. Secret Service’s initial investigation.
P/E: 30.5  This is significant and new evidence demonstrating Wirecard's central involvement in
EV/EBITDA: 17.2 transmitting unlawful monies into the United States. Evidence that the United States
Secret Service is now becoming aware of.
 Zatarra will reveal new evidence demonstrating the fraudulent nature of Wirecard’s
operations in due course.

Questions to Wirecard
1. Why does Wirecard refuse to make a public statement, specifically addressing the
issues we have raised?
2. Why did Wirecard deny any awareness of the existence of Wire Card UK Ltd, nor the
70 involvement of its former or current officers with Wire Card UK Ltd?
3. After denying association with Wire Card UK Ltd, what prompted Wirecard to admit a
few days later that it did incorporate Wire Card UK Ltd?
4. Why was Wire Card UK Ltd registered to a residential housing address in Consett,
County Durham, United Kingdom?
5. Why did Wire Card UK Ltd share the same shareholders, Fermoya Ltd and BMIE Ltd, as
Bluetool Ltd? Bluetool was the company at the center of a United States Secret Services
investigation into money laundering and the violation of the Wire Act.
6. Why did Wire Card UK Ltd share the same shareholders, Fermoya Ltd and BMIE Ltd, as
Bluemay Enterprises Ltd? Bluemay was a company found in 2014 to be a front for an
80 online gambling site, 7red.com, with €36 Million in credits to a Wirecard Bank account.
7. What is Wirecard’s relationship with Fermoya Ltd, BMIE Ltd, Bluetool Ltd, and Bluemay
Enterprises Ltd?
8. Who other than Zatarra’s Internet Service Provider, has Wirecard initiated legal action
against? Zatarra has received no complaint from Wirecard or its legal representatives
despite our contact details being readily available.
Bonus Questions:
9. Did Wirecard process payments on behalf of Full Tilt Poker, into the United States at
any time during the period 2006 to 2011?
10. Has Wirecard processed payments on behalf of any online poker companies, into the
90 United States since 2011?
We will demonstrate how Wirecard has made further false statements, and reveal
further evidence of the fraudulent nature of Wirecard’s operations in due course.
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 Wirecard’s Underhand Practices and
Defamation
Wirecard has feebly attempted to distract by questioning Zatarra’s credibility. However,
there can be no question as to the credibility of UK Companies House nor every other source
of publicly available and the irrefutable evidence we provided.

Since the publication of Zatarra’s research note “Wide Scale Corruption and Corporate
Fraud”, the Zatarra website has been under constant cyber-attack. These attacks largely
100 stem from Germany.

Wirecard’s management has avoided responding publicly to the issues we raised.

Instead, Wirecard’s legal representative, Gowling WLG, has threatened our internet service
provider (ISP). To provide a flavor of matters, Gowling WLG threaten everything without
specifying precisely which illegal activities it claims Zatarra and its ISP are undertaking.

Although Wirecard’s legal firm writes at length to our ISP about this and that, its main bone
of contention is how our report impacted upon Wirecard’s market valuation.

We note that while Wirecard has indicated to parts of the media that it has taken legal
action, none of this has been directed towards Zatarra itself. Zatarra’s website clearly states
an easy mode of communication through which we can be contacted. And yet we have not
110 received one single email or letter from Wirecard’s legal representative.

Wirecard has asserted that BaFIN is investigating Zatarra. This appears to be another
example of Wirecard misleading the market. The reality is that Zatarra itself has contacted
BaFIN with our evidence and contact details to liaise with the German regulator.

When a company’s management pursues underhand practices, complimented by

defamation, it is an absolute certainty that the management has something to hide.

Wirecard Changes its Story

Zatarra has been made aware1 that Wirecard has changed its statement with regards to the
incorporation of Wire Card UK Ltd (UK Companies House).
Initially, Wirecard denied any awareness of the existence of Wire Card UK Ltd and any links
120 to Wire Card UK Ltd by any former or current employees. Morgan Stanley went as far to
reveal this statement in its note, "Addressing Concerns", published on March 1, 2016.
Now Wirecard states that it did incorporate Wire Card UK Ltd.
 This demonstrates that Wirecard has again misled investors, analysts and the media.
 Wirecard now continues to mislead investors, analysts. and the media.
Wirecard's management have moved from denying any involvement or even awareness of
Wire Card UK Ltd to now confirming that it did incorporate Wire Card UK Ltd.
Wirecard changed its version of events AFTER we presented the incontrovertible evidence
easily obtained from UK Companies House.

1We reproduce the email that Wirecard’s VP Corporate Communications and Investor Relations, Iris Stöckl
sent to ‘sell-side’ analysts at the end of this note.
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 130
Figure 1 Morgan Stanley research note from March 1, 2016 - highlighting Wirecard management stating no
such awareness of Wire Card UK Ltd

Now Wirecard States it Incorporated Wire Card UK Ltd

In section 5 of Wirecard’s email to ‘sell side’ analysts, Wirecard now states that it did
incorporate Wire Card UK Ltd.
“5. Wire Card UK Limited (company number 05888415) was incorporated on 27
July 2006. This was for the purpose of establishing a subsidiary for Wirecard in the
UK.”
Aside from misleading investors and analysts and the media, in its updated statement,
140 Wirecard has now confirmed its direct association with Wire Card UK Ltd.

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 Wirecard Incriminates Itself with its Association with Wire
Card UK Ltd
We urge Regulators, MasterCard and Visa to investigate the ownership of Wire Card UK Ltd
and Bluetool Ltd (UK Companies House).
Bluetool Ltd is the company that was at the center of a United States Secret Service
investigation into Money Laundering - Court Document Michael Schuett.
Bluetool Ltd was the company transmitting unlawful monies into the United States from its
Wirecard Bank account.

150
Figure 2 Ownership of Wire Card UK Ltd and Bluetool Ltd

The filings for Wire Card UK Ltd and Bluetool Ltd show that each company was owned by
Fermoya Ltd and BMIE Ltd. Wirecard now states that it incorporated Wire Card UK Ltd and
this company had the same owners as Bluetool Ltd.
 Wire Card UK Incorporation Documents for Wire Card UK (Page 17)
 Bluetool Ltd Incorporation Documents (Page 18)
We believe that the United States Secret Service will investigate Wirecard's connection to
Wire Card UK Ltd and Bluetool Ltd and we have updated on these developments.

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 160 Figure 3 United States of America v. Michael Olaf Schuett

Further Incriminating Evidence

Fermoya Ltd and BMIE Ltd were also reported as the owners of Bluemay Enterprises Ltd. As
we have shown on page 40 of our research note, "Wide Scale Corruption and Corporate
Fraud", Bluemay Enterprises was a front for 7red.com, an online poker gambling site.

Bluemay Enterprises was struck off the UK Companies House register at the request of the
UK Secretary of State in 2014. Bluemay Enterprises was found to have €36 Million in credits
to a Wirecard Bank account. See: The UK Insolvency Service - Bluemay Enterprises Limited.

Wirecard incorporated a company, Wire Card UK Ltd, that had the same owners as Bluetool
Ltd, a company violating the Wire Act, and Bluemay Enterprises, a front for an online poker
170 company, with significant monies credited to a Wirecard Bank account.

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 Figure 4 Bluemay Enterprises struck off in 2014 at the request of the UK Secretary of State

Why this is NEW and Devastating Evidence

The United States Secret Service was unaware of Wirecard's incriminating connections to
these companies at the time of its investigation. The important company filings that show
these connections were filed after its investigation.
This is significant and new evidence demonstrating Wirecard's central involvement in
transmitting unlawful monies into the United States. Evidence that the United States Secret
180 Service is now becoming aware of.

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 Why Did Wirecard Register Wire Card UK Ltd at a Residential
Address?
Wire Card UK Ltd was registered to a residential address in Gateshead, United Kingdom. This
is clearly not a location from which Wirecard conducted any business. It is a violation of UK
Companies House rules to register a business to an address that has no relation to the
registered company’s activities.
We believe that Wirecard registered Wire Card UK Ltd to this residential address to make it
harder to track Wirecard and its officers’ involvement in money laundering and transmitting
illegal monies into the United States.

190
Figure 5 Wire Card UK Ltd registered to someone's house in Gateshead, United Kingdom

We will respond with additional evidence to show the further false statements Wirecard
has made in due course.

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 The Email Sent From Wirecard to Sell Side Analysts
Dear all
below you find a statement to a number of the points raised by Zatarra report.
200 Best regards,
Iris

Wirecard statement: Zatarra report

Despite Zatarra’s distinct lack of credibility, Wirecard has spent significant time and
effort reviewing the Report and the allegations it makes and determined that the
report is totally false. Below you will find answers in detail to a number of the points
raised.

Wirecard has always supported strengthened regulation of the internet payment industry,
210 with strict compliance to protect consumers, merchants and the industry from any form of
misconduct. It was the first Payment Service Provider (PSP) to hold a full banking licence,
as early as 2006. Being a regulated entity involves extensive regulatory oversight and
enforces the application of strict compliance procedures to the company’s operations. Since
Wirecard acquired its full banking licence, the European Union has introduced a regulatory
framework that has required Wirecard’s competitors to apply for licences and to become
subject to regulatory oversight. Wirecard’s German banking licence and the regulatory
regime which that entails shows that Wirecard operates under one of the most extensive
and strictest regulatory environments in Europe.
1. As one of the world’s leading online payment companies, Wirecard has
220 excellent relations with all credit card organisations. It is an active licensee/member
of such organisations through its regulated entities in the UK and Germany, and
has been for more than a decade. Further to its role as an acquirer and issuer for
various credit card organisations, Wirecard holds strategic partnerships with these
card organisations and has acquired assets and subsidiaries from them.
2. Wirecard continuously discloses the nature of the transaction volumes
processed by the company and the revenues related to each client industry
segment in its audited annual reports. Online gambling transactions solely originate
from regulated online gambling operators and volumes constitute about 7% of
Wirecard’s total transaction volumes. They are aggregated under the ‘digital goods’
230 segment of Wirecard’s public reporting. Any claim that Wirecard obfuscates
payment jurisdiction and associated merchant risk, to circumvent high risk
categorization and authentication requirements within the credit card organisation
networks, is wrong. Wirecard’s compliance and merchant account setup
procedures are repeatedly audited by regulatory bodies as well as the credit card
organisations themselves. The allocation of country and merchant category codes
to individual merchant accounts is conducted fully in accordance with all regulatory,
tax and credit card organisation rules.
3. Wirecard has never acquired Krores from Mr Knöchelmann, Mr Trautmann or
any other party. Wirecard also does not have any business relationship with Krores.
240 4. Since the departure of Dietmar Knöchelmann and Rüdiger Trautmann,
Wirecard has no direct or indirect business dealings or relationship with either
individual.
Wirecard has no direct or indirect business dealings with Inatec GmbH.
Mr Knöchelmann is not involved in any legal cases involving Wirecard or any of its
subsidiaries.
5. Wire Card UK Limited (company number 05888415) was incorporated on 27
July 2006. This was for the purpose of establishing a subsidiary for Wirecard in the
UK but in the end other decisions were made. In its whole lifetime it was a dormant
company which was never operational. It was dissolved on 17 August 2010.

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 250 6. With recards to the Schütt case, in 2010 the online portal Goldman,
Morgenstern & Partners (“Gomopa”) published a report falsely claiming that Mr
Michael Schütt, in his testimony to US authorities, named Wirecard as an ally in his
money laundering scheme for gambling companies. Several investigations by
journalists have entirely cleared both Wirecard and Mr Trautmann in relation to
Gomopa’s false claims. Gomopa’s claims were entirely fraudulent and made solely
to manipulatively drive down Wirecard’s stock price. For an example of this, please
see the Handelsblatt article available via the link:
http://www.handelsblatt.com/finanzen/maerkte/boerseinside/marktgeruechtefinanzaufsicht-
untersucht-kursachterbahn-beiwirecard/3406252.html (an English translation can be
260 made available upon request) Gomopa’s reputation for questionable business
practices is well known.
7. Mr Usman Fayaz was neither directly nor indirectly a shareholder of any of the
companies at the time of the purchase of the payment business of GI Retail Group.
Neither GI Technologies nor Hermes have ever been involved in any form of lottery
or gaming business. GI Technologies is India’s leading domestic money remittance
operator and regulated by the Reserve Bank of India (RBI). It is regularly audited by
the regulator and applies rigorous KYC and compliance procedures to its
remittance operations. The corporate fraud which is referred to is in respect of the
company Popular Agro Farms Pvt Ltd, which has nothing at all to do with Wirecard
270 or GI Retail.
8. Wirecard has never acquired Asia Pacific E-Serv Corporation (aspaconline).
Wirecard Asia Pacific, Philippines was a newly established company in 2007 and
was dissolved in 2012.
Mr Magleo's incorrect CV was updated on the website of Paynamics, Philippines.
Mrs Magleo headed the finance department of Wirecard Asia Pacific, Inc. during its
time of operation. She was not involved in any legal cases involving Wirecard or her
past activities as an officer of a subsidiary of Wirecard.
9. Wirecard has never hosted any content websites or any other merchant
business model.

280

Iris Stöckl
VP Corporate Communications & Investor Relations

Wirecard AG
Einsteinring 35
D-85609 Aschheim
Ph.: +49 (0) 89 4424-1424
Fax: +49 (0) 89 4424-2424
290 iris.stoeckl@wirecard.com <mailto:iris.stoeckl@wirecard.com>
Mobile: +49 (160) 445 11 58
http://www.wirecard.de http://www.wirecardbank.com http://mywirecard.com
FSE/ TecDAX/Prime ISIN DE0007472060 Ticker symbol WDI
Amtsgericht München HRB
169227
Vorstand: Dr. Markus Braun, Burkhard Ley, Jan
Marsalek
Aufsichtsratsvorsitzender: Wulf Matthias

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