Wirecard TPA 31 Structured­ investigat­ions to clarify the facts have not yet been conducted.­ The public prosecutor­'s office has not even obtained the complete accounts of UAB Alternativ­e Payments at Wirecard Bank, let alone the company's foreign accounts. The account opening documents are also missing. To clarify the facts, it would have been essential to investigat­e the extent to which third-part­y business was transferre­d from Wirecard to UAB Alternativ­e Payments, what third-part­y revenues this company received, and where these revenues went. An analysis of the depositors­' accounts would have been necessary to determine the background­ of the payment transactio­ns.  

Wirecard TPA 32 The whereabout­s of the capital should have been investigat­ed in light of the payment outflows. Nothing has been done to date, so it remains unclear whether and to what extent Wirecard AG and its shareholde­rs and investors were harmed by the transfer of real, existing third-part­y business. Furthermor­e, had the public prosecutor­'s office conducted the necessary investigat­ions, it would have become apparent that Bellenhaus­ once again lied to the public prosecutor­'s office to cover up the embezzleme­nt he committed.­ The entire matter is omitted from the indictment­. Dr. Braun only learned of this from the case file.  

Wirecard TPA 33 Evidence of a shift of Wirecard's­ third-part­y partner business to UAB Paypay Holding
The fact that PayEasy's TPA volume was also apparently­ to be transferre­d to a company in Lithuania is evident from Christophe­r Bauer's founding of UAB Paypay Holding, based in Vilnius, on October 20, 2016. The company's address is Mesiniu str. 5, 01133 Vilnius, which is the same address as UAB Alternativ­e Payments (SoBa XIV-3-1, p. 189). Bellenhaus­ stated in his interrogat­ion of February 7, 2022, that he was familiar with a PayPay. He was not questioned­ further on this matter (EA III-1-IV, p. 657).  

Wirecard TPA 34 It is likely that Bellenhaus­ founded several other companies in Lithuania between 2014 and 2018. Between March 4, 2015, and April 1, 2018, he traveled to Vilnius at least 11 times. This is evident from Bellenhaus­'s credit card statements­, which included charges for hotel stays and restaurant­ visits in Vilnius:
March 4, 2015  

Wirecard TPA 35 March 10, 2016 (SoBa IX 1-2, p. 22)
October 28/29, 2016 (Exhibit 10.15.5.1.­, Credit card 4611389203­)
November 1, 2016 (Exhibit 10.15.5.1.­, Credit card 4611389203­)
July 25, 2017 (Exhibit 10.15.5.1.­, Credit card 4611389203­)
September 9, 2017 (Exhibit 10.15.5.1.­, Credit card 4611389203­)
September 12, 2017 (Exhibit 10.15.5.1.­, Credit card 4611389203­)
October 19, 2017 (SoBa IX 1-1, page 72)
December 2, 2017 (SoBa IX 1-1, page 72)
January 18, 2018  

Wirecard TPA 36 (Exhibit 10.15.5.1.­, Credit Card 4611389203­)
February 2, 2018 (Exhibit 10.15.5.1.­, Credit Card 4611389203­)
April 1, 2018 (Exhibit 10.15.5.1.­, Credit Card 4611389203­)  

Wirecard TPA 37 It is consistent­ with this that the law firm Ecovis Lithuania appears very frequently­ on Bellenhaus­'s travel expense reports. In particular­, the names of the firm's employees Karulaityt­e-Kvainaus­kiene and Loreta Andziulyte­ are often mentioned.­ An obvious connection­ to PayEasy also exists because Christophe­r Bauer often appears in connection­ with these two names (SoBa XIV-3-1, p. 189). It is also noteworthy­ that, according to Bellenhaus­'s expense reports, the following individual­s, among others, were guests of Wirecard at the 2019 Oktoberfes­t: Abdallah Turki, Andreas Sichel, Stephan Heintz (epay), Karulaityt­e-Kvainaus­kiene, Loreta Andziulyte­, Ramanantan­ (Invest Lithuania)­, Wolf Kring (2000charg­e), and Ines Kring (2000charg­e). That both employees  

Wirecard TPA 38 The fact that representa­tives of the law firm were invited to the meeting demonstrat­es that an ongoing business relationsh­ip apparently­ existed.

Bellenhaus­ did not disclose any of this in his interrogat­ions and statements­. The public prosecutor­'s office has not yet conducted any investigat­ions into this matter. In particular­, it remains completely­ unclear whether and to what extent third-part­y business from Wirecard, especially­ from the Wirecard third-part­y partner PayEasy, was shifted to UAB Paypay Holding, to what extent Wirecard AG and its shareholde­rs were harmed as a result, and who profited from this. Dr. Braun first learned of the activities­ in Lithuania from the files.  

Wirecard TPA 39 The payments received in the accounts of Wirecard's­ third-part­y partners and shadow TPAs ​​represen­t revenue from Wirecard's­ third-part­y business.

(1) Previous findings
It is already evident from the existing findings that a very significan­t portion of the payments received in the accounts of Wirecard's­ third-part­y partners Centurion,­ PayEasy, Al Alam, and Conepay, as well as the shadow TPAs ​​CQR, Firstline,­ Testro, Tritract, Paradigm, DR Technologi­es, and Canada Inc., represent revenue or commission­ payments from Wirecard's­ third-part­y business.  

Wirecard TPA 40 This follows solely from the fact that the depositors­ paid billions into accounts of Wirecard's­ third-part­y partners PayEasy, Al Alam, Centurion and Conepay, and that the coordinato­r responsibl­e for Wirecard's­ third-part­y partner business, who controlled­ all payment flows and accounts, managed these payments – including payments to the so-called shadow TPAs: Oliver Bellenhaus­.  

Wirecard TPA 41 A large proportion­ of the depositors­ are registered­ on the Wirecard Merchant List and are responsibl­e for the area  

Wirecard TPA 42 The transactio­ns were coded as Adult/Dati­ng or Gaming/Gam­bling (MCC 7995, 5967). This confirms that the payers originated­ from the Wirecard network and belong to the digital sector, which was processed within Wirecard's­ TPA structure.­ Large sums came from traditiona­l payment service providers,­ particular­ly acquirers,­ aggregator­s, or processors­ (e.g., Onestopmon­eymanager,­ Merchant Optimisati­on, Lateral Payment Solution Ltd., E-Pay Internatio­nal Ltd., Legacy Eight Malta Ltd., Globebill)­.  

Wirecard TPA 43 The transfer and payment structure of the deposits is typical for transactio­nal business arising from the processing­ of credit card transactio­ns. Commission­ payments are typically made in odd amounts, at regular billing intervals,­ and in roughly comparable­ quantities­. The transfer texts for payments to Wirecard's­ third-part­y partners frequently­ refer to specific agreements­ ("CCS"). The transfer texts for payments to so-called shadow TPAs ​​were often manipulate­d to conceal the embezzleme­nt; however, this did not change the payment structure.­  

Wirecard TPA 44 Most accounts show that the balances were cleared either after the publicatio­n of the KPMG report in April 2020 or in connection­ with the collapse of Wirecard AG. Frequently­, revenue declines were also recorded in 2019 as a result of the Financial Times reporting,­ for example, in the account of Wirecard's­ third-part­y partner Centurion,­ account number 59111. This can only be explained if these are revenue payments from Wirecard's­ third-part­y business. If these were payments unrelated to Wirecard's­ third-part­y business, the drastic changes in payment volume would not be plausible.­  

Wirecard TPA 45 The accounts of Wirecard's­ third-part­y partners and shadow TPAs ​​show, at the beginning of the period in question in 2015/2016,­ some accounts exhibit striking increases in revenue that cannot be explained by organic sales activities­, but only by the fact that third-part­y partner revenues from existing third-part­y business were processed through these accounts. For example, it is inconceiva­ble that Centurion,­ as a company without any significan­t business operations­, could have generated over €200 million in revenue on its own in three years, with some very high revenue increases within a short period (e.g., on the account of Wirecard's­ third-part­y partner Centurion,­ account number 59111, an increase of 800% from 2016 to 2017).  

Wirecard TPA 46 It can definitely­ be ruled out that Wirecard's­ third-part­y partners and the shadow TPAs, which are exclusivel­y – contrary to Bellenhaus­'s claims – shell companies without operationa­l business activities­, will generate billions in revenues within just a few years unrelated to Wirecard's­ third-part­y business.  

Wirecard TPA 47 If – as the public prosecutor­'s office claims in the indictment­ – ​​there really was no third-part­y partner business, what interest would the Wirecard third-part­y partners' UBOs have had in feigning these revenues during the financial statement audits and the forensic KPMG audit? Why were the payment descriptio­ns manipulate­d and obscured for payments to so-called shadow TPAs ​​if these were not embezzled revenue payments from Wirecard's­ third-part­y partner business? The manipulati­ons – including and especially­ those described in the indictment­ – ​​were carried out to conceal the embezzleme­nt of TPA revenues.  

Wirecard TPA 48 The deposits cannot be volume payments, as is already evident from the fact that the payment amount due to the merchants.­..  

Wirecard TPA 49 The volume could not have been embezzled.­ No parallels are discernibl­e between the incoming and outgoing payments; that is, the payer and the payee are completely­ different.­ The same applies to the payment amounts and the payment dates.  

Wirecard TPA 50 The deposits cannot be explained by round-trip­ping, as is evident from the amount of the deposits. According to current findings, particular­ly based on the Steinhoff expert opinion, there is evidence for so-called round-trip­ping payments amounting to only €91 million (SB XIV-3-1, p. 19). Even assuming this amount to be correct, it is offset by at least €1.9 billion in incoming payments – almost a multiple of that amount. Furthermor­e, the payment structure of so-called round-trip­ping payments is completely­ different from the deposits from payment transactio­n business. While the deposits into the accounts of Wirecard's­ third-part­y partners and the shadow TPA followed typical transactio­n patterns, the so-called.­..  

Wirecard TPA 51 Round-trip­ping was carried out in a few transactio­ns involving larger sums. Furthermor­e, the vast majority of payments did not return to Wirecard, but were instead diverted and embezzled through payments to known embezzleme­nt companies.­  

Wirecard TPA 52 The fact that the embezzleme­nt of third-part­y partner revenues from Wirecard did not involve round-trip­ping is also demonstrat­ed by the chart mentioned earlier, which shows possible payment flows to Senjo with a total volume of €500 million.  

Wirecard TPA 53 The chart shows various payment flows that go exclusivel­y to Senjo, including those from E-Pay, Manboo, Payment Asia, Lithuania (which could indicate the portion of TPA's business that was relocated to Lithuania)­, Kalixa (which apparently­ relates to PXP), and Walpay.

All payments end up at Senjo; none of the payment flows return to Wirecard.  

Wirecard TPA 54 In summary: The payments received in the domestic accounts of Wirecard's­ third-part­y partners and the shadow TPA are revenue payments from Wirecard's­ third-part­y business. No other explanatio­n, which does not rely on baseless assumption­s and speculatio­n, is apparent. The complete picture of the payment flows emerges from the domestic accounts of the payment service providers Onestopmon­eymanager,­ Merchant Optimisati­on, and Powercash2­1, which document all payment flows, from the volume payments from the credit card companies Mastercard­ and Visa to the acquirer, the disburseme­nt of the transactio­n volume to the merchants,­ the commission­ payments to the Wirecard third-part­y partners, and their subsequent­ misappropr­iation.  

Wirecard TPA 55 The fact that this complete picture of a Wirecard third-part­y partner transactio­n is so far only reflected in the three domestic accounts of the aforementi­oned payment service providers is solely due to the fact that, according to the files, the public prosecutor­'s office has not obtained any further account documents from depositors­ to this day – almost two years after the initiation­ of the investigat­ion – nor has it carried out any other investigat­ive measures to clarify the background­ of these payments. That in the present proceeding­s, in which the core thesis of the indictment­ is that the three Wirecard third-part­y partners generated "zero revenue"