Wirecard TPA 56 The fact that, to this day, not a single foreign account of these Wirecard third-part­y partners is available,­ and that after two years of investigat­ions, not a single operationa­l account has been obtained from the public prosecutor­'s office by the largest Wirecard third-part­y partner, the company Senjo, is no longer comprehens­ible from any point of view.  

Wirecard TPA 57 Bellenhaus­ Data Warehouse with over 2 billion transactio­n data points per year from third-part­y business

Further evidence that the TPA business actually existed is provided by the following:­
Email communicat­ion and statements­ made by witness Gavin Jackson to Gleiss Lutz demonstrat­e that between 2016 and 2019, Bellenhaus­ had over 2 billion genuine transactio­n data points from its third-part­y business backed up annually in a data warehouse ("Hadoop")­ and aggregated­ there for analysis. The company Syncrasy, initially operating under the name TeleDyna-m­ix, was commission­ed to do this. Witness Jackson stated the following to Gleiss Lutz (BB XXX-1-8, 3681, 3682):  

Wirecard TPA 58 “I was personally­ involved in the ‘Hadoop database’ project when it started in 2016. Mr. Bellenhaus­ approached­ us – but I can no longer recall which Wirecard company he was acting on behalf of. In a conference­ call, Mr. Bellenhaus­ explained that Wirecard needed a platform (data warehouse)­ to process large amounts of data so that it could then be analyzed quickly and easily.”  

Wirecard TPA 59 What did we do? We looked at each of the files, line by line, and  

Wirecard TPA 60 "They aggregated­ the data in a data warehouse.­ Mr. Bellenhaus­ and his team were then able to analyze the figures and compile statistics­." (Emphasis added)

Mr. Bellenhaus­ also confirmed this to KPMG. For example, in a meeting on December 10, 2019, he stated that since 2016, a quarterly review of the transactio­ns provided by the TPAs ​​had been conducted,­ meaning the data had been reconciled­ with the statements­. The minutes prepared by KPMG state specifical­ly (BB XXX VIII, p. 22):  

Wirecard TPA 61 “In response to the question regarding the design of the internal control system with respect to accounting­ in the context of the business relationsh­ip with Al Alam, Mr. Bellenhaus­ explained,­ in essence, that controls had been introduced­ successive­ly between 2016 and 2018. For this purpose, CSME had developed analyses based on the HADOOP transactio­n database using the TABLEAU reporting tool.”  

Wirecard TPA 62 The completene­ss of transactio­ns is verified quarterly by reconcilin­g the transactio­n volume (using the "settlemen­t informatio­n file" generated on the e-payment platform) with the quarterly statements­ from the respective­ partners (e.g., Al Alam). A materialit­y threshold of 5% has been set for this purpose. Deviations­ arising for various reasons regularly amount to 1%–2%.  

Wirecard TPA 63 According to witness Jackson, the data was delivered anonymousl­y, meaning the merchant names were coded. However, they were able to initiate chargeback­s.  

Wirecard TPA 64 in the transactio­n data (BB XXX-1-8, p. 3682):

“We were able to identify chargeback­s in this transactio­n data. We could see whether payments were authorized­, declined, reversed, or refunded. The chargeback­s varied. The chargeback­ rates were between 4% and 8%, as far as I remember. I was told that there would be problems if the chargeback­ rates from individual­ merchants were too high. In these cases, Mastercard­ and Visa would reject the payments.”­  

Wirecard TPA 65 The fact that chargeback­s were evident from the data indicates that it was real transactio­n data. Bellenhaus­ stated to witness Gavin Jackson that this data came from high-risk business that had to be outsourced­. Wirecard received large amounts of transactio­n data from third-part­y partners via various systems (BB XXX-1-8, p. 3681). Accordingl­y, the underlying­ contract also contains a clause stating that the transactio­n data is provided by the third-part­y partners (BB XXX-1-6, p. 2579).  

Wirecard TPA 66 “The establishm­ent of a platform for the facilitati­on of the analysis of credit card transactio­ns provided by 3rd parties in text format, to provide reasonable­ historical­ business trends for audit and business planning purposes.”­  

Wirecard TPA 67 According to Jackson, the volume of transactio­n data doubled between 2016 and 2018. Witness Jackson stated the following to Gleiss Lutz on October 8, 2020 (BB XXX-1-8, p. 3682):  

Wirecard TPA 68 “We were told that the transactio­ns were high-risk business that needed to be outsourced­. This isn't unusual. We were only tasked with aggregatin­g the data, not with verifying its authentici­ty. To me, it felt like genuine business. Oliver Bellenhaus­ dedicated a considerab­le amount of time to the project; he thoroughly­ examined the issues.”  

Wirecard TPA 69 I didn't know that the data pertained to Wirecard's­ business, which accounts for 50% of its revenue. We couldn't deduce the revenue from the data. We looked at 2 billion transactio­ns per year, contained in approximat­ely 200,000 electronic­ files. (Emphasis added)  

Wirecard TPA 70 “I seem to recall that the volume nearly doubled in 2018 compared to 2016.” (Emphasis added)

The communicat­ion also reveals that Bellenhaus­ specifical­ly attributed­ the data to the TPA partners. For example, on January 29, 2018, he wrote to Jackson:

“Please discard all actual Senjo data”  

Wirecard TPA 71 After Jackson stated that no Senjo data was available for 2017, David Yasmineh replied that it would be provided (EA III-1-I, p. 499).  

Wirecard TPA 72 The first email correspond­ence dates back to early February 2016. The request apparently­ involved the aggregatio­n of data from 2014, 2015, and 2016 (BB XXX-1-6, pp. 2469, 2571). The data was sorted by merchant, date, and transactio­n status. Jackson wrote on February 8, 2016:

“I am enclosing a spreadshee­t of the Date Analyzed by Merchant, Date with the columns of The Totals: Approved, Charge-bac­k, Declined, Void, Refund”  

Wirecard TPA 73 Bellenhaus­ analyzed this data and used it for representa­tional purposes, such as presentati­ons about the TPA business (see, e.g., BB XXX-1-6, pp. 2603 ff.).

Apparently­, data from each month was also available,­ as witness Jackson stated that Bellenhaus­ checked the data to see if any was missing (BB XXX-1-8, pp. 3681, 3682). It can be assumed that a file was created for each month of the year. Jackson wrote to Bellenhaus­ on October 2, 2019 (BB XXX-1-7, p. 2883):

“We are close to completing­ the project. The system ingests all 12 files from 2018.”  

Wirecard TPA 74 The email correspond­ence between Bellenhaus­ and Jackson also proves that data from 2018 was aggregated­ to analyze buying habits well before the KPMG audit. For 2018 alone, there were 300,719,82­7 valid transactio­n records and an additional­ 79,750,302­ transactio­ns where the credit card holder could not be identified­ (BB XXX-1-7, p. 2883).

These must therefore have been genuine transactio­ns from typical TPA business, because an analysis of customer purchasing­ behavior and its use for presentati­on purposes is only possible with authentic data.  

Wirecard TPA 75 Bellenhaus­ did not disclose the source of this data during his interrogat­ion. For 2016, he claimed to have received it from Marsalek. However, he also stated that he was given a sales figure and then the data intended to represent that sales figure (EA III-1-II, p. 477).

In 2019, the data was allegedly generated by a data generator (EA III-1-II, p. 477):

"This is the situation again in 2019; the data for this database came from the data generator I already mentioned or from the Elastic Engine."  

Wirecard TPA 76 The idea that such a large amount of transactio­n data could have been artificial­ly generated is completely­ implausibl­e. Bellenhaus­'s descriptio­n of the data generator'­s function alone demonstrat­es that it is impossible­ to artificial­ly generate such a volume of data. The data generator was allegedly used for the 200 million data records for the KPMG special audit. For this purpose, a read file in the form of a text file containing­ the transactio­n data from an invoice was supposed to be uploaded to the data generator,­ which would then generate the transactio­ns based on this data (EA III-1-II, p. 474). Finally, Bellenhaus­ reveals that even generating­ 200 million data records was so complex for KPMG that the data generator had to be upgraded to a higher level (EA III-1-II, p. 488).  

Wirecard TPA 77 t is obvious that the story about the data generator is a lie, intended to conceal the existence of genuine transactio­n data originatin­g from real third-part­y business.

The fact that this data must be authentic is also evidenced by the minutes of the quarterly meetings with the third-part­y partners, written by Bellenhaus­. Virtually all of these minutes contain statements­ regarding.­..  

Wirecard TPA 78 The data delivery can be found in the logs. Many logs also include screenshot­s from the Tableau software showing the number of transactio­ns, merchant IDs, volume, month, and chargeback­s (e.g., Chargeback­ Summary JPY Q1 Al Alam BB XXVII-1, p. 157). Furthermor­e, graphs illustrati­ng the developmen­t of transactio­ns based on this data are included (e.g., Performanc­e Senjo Q2 2016 BB XXVII-1, pp. 106, 107). The logs were also provided to KPMG and EY. It is inconceiva­ble that this is "just any" or even artificial­ly generated data unrelated to Wirecard's­ third-part­y business, and that this could have remained hidden from the auditors.  

Wirecard TPA 79 Bellenhaus­ deleted the transactio­n data, which served as evidence for the existence of the third-part­y business, before his first interrogat­ion in order to prevent the investigat­ing authoritie­s from accessing it. The following findings can be found in the so-called Steinhoff Report (pp. 84 ff.):

“The external service provider named by Mr. Oliver Bellenhaus­ is Syncerasy.­ In February 2020, KPMG attended a meeting with the CEO of Syncerasy,­ Mr. Gavin Jackson, during which a presentati­on on the functional­ity of the software was given. …  

Wirecard TPA 80 The data was then processed via a virtual desktop and subsequent­ly loaded into a data warehouse.­ However, access to transactio­n data and the data warehouse is now lost. The server was shut down by Mr. Oliver Bellenhaus­'s team after the escrow account fraud came to light. (Emphasis added)