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049SMU

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A WHISTLEBLOWER’S DILEMMA IN THE HOUSE OF WIRECARD
(A)

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Resign, or be fired! He was told.

As he thought about that conversation, Pav Gill was gazing out of the window on the 40th floor of his
office building. It was September 2018, his first work anniversary as Head of the Legal Department
for the Asia Pacific (APAC) region at Wirecard, a payment processing company headquartered in
Germany. Instead of celebrating, he was deeply perturbed. For the past six months, he had been
reeling from one shock to another – the discovery of forgery, round-tripping, cover-ups, and finally

yo
threats.

Within a few months of joining the fast-growing fintech outfit as the first in-house legal counsel in
Wirecard’s APAC region, Gill was appalled to discover suspicious transactions. Wirecard, valued at
nearly €25 billion1 (US$29 billion2) had ascended to Germany’s main stock exchange comprising
blue-chip stocks. This was despite years of doubts over its accounting practices raised by the
Financial Times (FT), a British newspaper, which published a series of articles titled ‘The House of
op
Wirecard’.3

Gill escalated the matter to the headquarters and engaged a top Singapore law firm, Rajah & Tann
(R&T), to investigate what appeared very likely a financial misconduct that was not only isolated to
the local finance team but extended to the board level at the German headquarters. Allegations of the
involvement of one of the board members, Jan Marsalek, the group’s Chief Operating Officer, were
tC

met with swift and strong denial, and he later delegated the probe to the local CEO reporting to him.4
Gill had witnessed fraud, deception, and concealment within the house, and was a target of
intimidation by the local management.5

More than a year into his short-lived career at Wirecard, Gill struggled with the thought: should he
blow the whistle and spill the beans to the world?
No

1
Paul Condylis and Emir Hrnjic, “The Curious Case of Wirecard”, The Straits Times, July 26, 2020,
https://www.straitstimes.com/business/invest/the-curious-case-of-wirecard, accessed October 2022.
2
€1 = US$1.16 as at 2018, www.xe.com, accessed October 2022.
3
Dan McCrum, “Wirecard: The Timeline”, Financial Times, June 25, 2020, https://www.ft.com/content/284fb1ad-ddc0-45df-a075-
0709b36868db, accessed October 2022.
4
NewsBeezer, “Wirecard Whistleblower: The Uncoverer Comes Out of Cover”, May 19, 2021,
https://newsbeezer.com/austriaeng/wirecard-whistleblower-the-uncoverer-comes-out-of-cover/, accessed October 2022.
5
Paul Kilby, “Wirecard's Whistleblower”, Fraud Magazine, March/April 2022, https://www.fraud-magazine.com/cover-
article.aspx?id=4295017127, accessed October 2022.
Do

This case was written by Professor Abhijeet Vadera, Dr. Cheah Sin Mei and Mahima Rao-Kachroo at the Singapore
Management University. The case was prepared solely to provide material for class discussion. The authors do not intend to
illustrate either effective or ineffective handling of a managerial situation. The authors may have disguised certain names and
other identifying information to protect confidentiality.

Copyright © 2023, Singapore Management University Version: 2023-07-27

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 SMU-23-0013 A Whistleblower’s Dilemma in the House of Wirecard

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Gill’s Background

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Growing up in Singapore, Gill could be considered a poster boy for the city-state’s meritocratic
system. He came from a humble family background, living in public housing, and was raised single-
handedly by his mother, but against the odds, he excelled consistently in his studies to graduate from
law school at the nation’s top university. Formerly a senior banker, Gill’s mother, Sokhbir Kaur, had
worked hard by taking on several jobs while indefatigably nurturing him for a future career in law.

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After graduating, Gill worked as an associate at one of the most prestigious Magic Circle6 law firms,
Allen & Overy, in Singapore. He left to join another renowned Magic Circle law firm, Clifford
Chance and was based in Dubai. After spending four years in the Middle East covering debt and
Islamic bond markets, his curiosity about the fintech industry led him to move back to Singapore to
join a start-up. A year and a half later, he was headhunted to join Wirecard.

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Wirecard AG

The Early Years

Wirecard AG was founded in 1999 in Aschheim, a small town on the outskirts of Munich, Germany.
Austria-born Markus Braun became its CEO in 2002 after rescuing the company from the brink of
collapse with a personal investment of £75 million (US$118 million).7 Within a span of three years,
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Wirecard went from an inconspicuous company headquartered in the suburban backwater of a laid-
back city to a listed firm on the Frankfurt Stock Exchange – the third largest by market capitalisation
in Europe.8 The listing was, however, via a backdoor executed through a reverse takeover of a
defunct call centre company, InfoGenie AG, whose shares had turned into penny stocks. A year later,
the fast-growing Wirecard found its way to TecDAX, a stock market index that tracked the 30 largest
technology firms listed on the Frankfurt Stock Exchange.
tC

At a time when big players like PayPal, Stripe, Google Wallet, and Apple Pay were competing for a
share of the e-commerce market, Wirecard had identified a gap in the payment processing industry
and strategised to offer both conventional and digital payment processing services to large and small
businesses. Wirecard’s multi-channel platform was capable of handling online, mobile, and in-store
point-of-sale transactions not offered by its rivals.
No

With its repertoire of service offerings, Wirecard attracted customers like Aldi and Lidl, the German
discount grocery chains, as well as numerous national and budget airlines, including Air Berlin,
SriLankan Airlines, and Wizz Air. While mainstream players had steered clear of vice industries due
to high risks, Wirecard, ever since Braun took the helm, boldly exploited lucrative opportunities.
Lesser known was the company’s clientele comprising shady businesses, in particular online

6
Magic Circle was an informal term coined by legal journalists to describe the five leading law firms headquartered in the UK, namely
Allen & Overy, Clifford Chance, Freshfields, Linklaters, and Slaughter and May.
7
Bloomberg, “Fraud Allegations Put Wirecard's Shy Billionaire CEO Markus Braun in the Spotlight”, The Straits Times, March 13,
Do

2019, https://www.straitstimes.com/business/banking/fraud-allegations-put-wirecards-shy-billionaire-ceo-in-the-spotlight, accessed

October 2022.
8
Statista, “Largest Stock Exchanges in Europe as of June 2022, By Domestic Market Capitalization”,
https://www.statista.com/statistics/693587/stock-exchanges-market-capitalization-europe/, accessed October 2022.

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 SMU-23-0013 A Whistleblower’s Dilemma in the House of Wirecard

gambling, and pornography websites.9

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Rapid Global Scaling

In the decade that followed, Wirecard expanded aggressively, reflecting Braun’s aspirations for the
company to create a global presence.10 Its first acquisition was of XCOM AG, a German bank.
Moving into the banking sector, Wirecard obtained licenses from Visa and Mastercard to issue debit
and credit cards; it effectively turned itself from an online payment gateway into a full-service

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payment operator.

Apart from its home grounds, Wirecard first set foot in Asia with a buyout of the Singapore-based
payment processing company, E-Credit Plus, in 2009. 11 Singapore eventually became its Asia
Pacific headquarters, and from there, it added neighbouring Indonesia to its Southeast Asian
repertoire in 2012, thereby expanding its portfolio of businesses to include mobile payment. The
Great India Retail Group’s payment business and a technology subsidiary came under its wing in

yo
2015, following yet another acquisition costing £340 million (US$515 million), which opened the
remittance and mobile-wallet consumer markets for Wirecard.12

In 2016, Wirecard ventured westward to South America and snapped up Moip, a Brazilian online
payment service provider for small retailers. A year later, it entered the North American market in a
high-profile takeover, buying over Citigroup’s prepaid card services. That deal alone increased its
earnings before interest, taxes, and amortization or EBITA by an estimated US$20 million.13 In the
op
same year, it also took over Citi’s merchant acquiring business spanning 11 countries in APAC; this
coincided with the American bank’s attempts to exit from unprofitable markets in retail banking.
This purchase boosted Wirecard’s portfolio with an addition of over 20,000 institutional clients in
Australia, Hong Kong, India, Indonesia, Macau, Malaysia, New Zealand, Philippines, Singapore,
Thailand, and Taiwan.14
tC

Rise of a Fintech Darling

In a 2017 audit, Ernst & Young (EY), Wirecard’s main auditor for nearly a decade, gave the firm a
clean bill of health amid allegations of fraud (refer to Exhibit 1 for the allegations before 2018). The
glowing numbers in Wirecard’s 2017 annual report – a reported jump in revenue by 45% and organic
growth of 25%15 – further restored investors’ confidence and sent its share price soaring.16 A stellar
No

9
Dan McCrum, “Wirecard: The Timeline”, Financial Times, June 25, 2020, https://www.ft.com/content/284fb1ad-ddc0-45df-a075-
0709b36868db, accessed October 2022.
10
Ibid.
11
EQS-News, “Wirecard AG Acquires Asian Payment Processor E-Credit Pte. Ltd., Singapore”, December 17, 2009, https://www.eqs-
news.com/news/corporate/wirecard-ag-acquires-asian-payment-processor-e-credit-pte-ltd-singapore/610899, accessed October 2022.
12
Reuters, “Wirecard Buys Great Indian Retail Group Payments Business”, October 27, 2015, https://www.reuters.com/article/us-
wirecard-acquisition-india-idUSKCN0SL1L520151027, accessed October 2022.
13
Reuters, “Wirecard Buys Citi Prepaid Card Services to Enter USA”, June 30, 2016, https://www.reuters.com/article/us-wirecard-usa-
idUSKCN0ZF26B, accessed October 2022.
14
Jasim Zahid, “Wirecard to Buy Customer Portfolio of Citi’s Asia-Pacific Merchant Acquiring Biz”, SP& Global Marketing
Intelligence, March 13, 2017, https://www.spglobal.com/marketintelligence/en/news-insights/trending/htjlmvqn4sqr75nzappg_a2,
accessed October 2022.
Do

15
Wirecard, “Digitise Now: Annual Report 2017”, April 12, 2018, https://www.wirecard.com/wp-content/uploads/2020/12/Annual-
Report-2017.pdf, accessed October 2022.
16
Dan McCrum, “Wirecard: The Timeline”, Financial Times, June 25, 2020, https://www.ft.com/content/284fb1ad-ddc0-45df-a075-
0709b36868db, accessed October 2022.

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 SMU-23-0013 A Whistleblower’s Dilemma in the House of Wirecard

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performance by a company whose stock price had more than doubled did not escape the attention of
investors and analysts alike. A financial advisor described Wirecard as “an established business in

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an industry marked by many fly-by-night operations” 17 , while equity analysts chipped in to
recommend a buy18. Wirecard was touted as a success story with positive reviews such as: “Should
we bet on Wirecard’s strategy? Yes, definitely.”19

Not only was Wirecard an appealing investment option, but it also stood out as an attractive employer
to work for. Gill, who was headhunted, recalled,

rP
The salary and coverage were good; it was a listed German company. I had autonomy, a team to
grow, and covered all markets in the region with a reporting line to Wirecard’s headquarters in
Aschheim, Munich. It was a step up in my career and pretty exciting at the time. 20

Fuelling that excitement was a trip to Wirecard headquarters in Munich for his first day during the
Oktoberfest celebrations, right after Gill was employed in September 2017. He then joined several

yo
of the company’s top executives including Braun and Jan Marsalek, who had both been reappointed
two months earlier by the board to remain in their roles until the end of 2020, for Wirecard’s
Christmas event in Munich.21

Red Flags
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Edo Kurniawan

Back in Singapore, it did not take long for Gill to find the subsidiary’s hiring practices questionable,
specifically Edo Kurniawan, the then Head of International Finance. “As head of international
finance, he was practically the third-most important finance and accounting employee within the
entire group”, Gill said of Kurniawan, but “his CV (Curriculum Vitae) didn’t add up”.
tC

The 33-year-old Indonesian’s job profile on LinkedIn listed two short 18-month stints with Ardent
Capital and Rocket Internet as their regional finance manager. Prior to that, he started at an unnamed
audit company, apparently based in Singapore and Hong Kong for four years,22,23

Head of International Finance, Wirecard AG, Singapore

No

17
Samuel Rae, “Here's Why Wirecard AG Makes for an Attractive Exposure to Growth in The Payments Processing Space”, Seeking
Alpha, May 24, 2017, https://seekingalpha.com/article/4075958-why-wirecard-ag-makes-for-attractive-exposure-to-growth-in-
payments-processing-space, accessed October 2022.
18
The Economist, “How Wirecard Fooled Most of the People All of The Time”, June 25, 2020, https://www.economist.com/finance-
and-economics/2020/06/25/how-wirecard-fooled-most-of-the-people-all-of-the-time, accessed October 2022.
19
Ground Report, “Wirecard: A Success Story in the Internet Payment Service Providers Market”, March 6, 2016,
https://www.groundreport.com/wirecard-success-story-internet-payment-service-providers-market/, accessed October 2022.
20
Paul Kilby, “Wirecard’'s Whistleblower”, Fraud Magazine, March/April 2022, https://www.fraud-magazine.com/cover-
article.aspx?id=4295017127, accessed October 2022.
21
EQS-News, “Wirecard AG Announces Changes to and Enlargement of Management Board as of 2018”, July 12, 2017,
https://www.dgap.de/dgap/News/corporate/wirecard-announces-changes-and-enlargement-management-board-ag/?newsID=1016353,
Do

accessed October 2022.

22
Paul Kilby, “Wirecard’s Whistleblower”, Fraud Magazine, March/April 2022, https://www.fraud-magazine.com/cover-
article.aspx?id=4295017127, accessed October 2022.
23
Sky Documentaries, “Wirecard – The Million Euro Lie”, https://www.sky.com/, accessed October 2022.

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 SMU-23-0013 A Whistleblower’s Dilemma in the House of Wirecard

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Regional Finance Controller, Ardent Capital, Bangkok
Asia Pacific Regional Finance Manager, Rocket Internet GmbH, Bangkok

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An obvious charlatan to Gill, Kurniawan seemed ill-qualified for a senior management role that
handled billions of dollars.24 Gill wondered, “What did he do to snag this job?”25 Additionally, Gill
had observed Kurniawan could neither speak German nor “string a meaningful email together in
English”.26 Despite his poor command of the two languages, he was hired directly by Wirecard

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headquarters and flew weekly around the world for meetings. Kurniawan also had a penchant for
boasting about how he was married into a drug-dealing family. In particular, he mentioned how his
father-in-law had placed a gun on the coffee table during their first meeting.

Gill travelled with him on a few business trips and would hear him talk about having “a lot of things
to clean up” but he was always vague about what those things were.27 On one occasion, Kurniawan
had asked Gill to prepare a settlement agreement to terminate the employment of two colleagues in

yo
the Philippines office. When prompted, Kurniawan divulged that the dismissal was to mute those
who accused the company of fraud.28 Kurniawan also told Gill: “Wirecard has been known to make
people disappear” but reassured the latter not to worry as long as “they [remained] on the same
page”.29

Internal Whistleblowing

Kurniawan’s propensity to hire young, inexperienced female staff from neighbouring countries to
op
work in his department baffled Gill, who subsequently figured out that this was part of Kurniawan’s
strategy. These staff members would be given senior job titles and high salaries while taking
instructions from him to carry out dubious transactions. However, it was one of Kurniawan’s
subordinates in the finance department who blew the whistle on him. In February 2018, the said
employee confided in Gill at a café away from the watchful eyes in their office.
tC

The reason for choosing a farther location was to avoid being found out by the Vice President of
Human Resources in APAC, who acted as the spy of the local CEO and was formerly the CEO’s
personal assistant. The Human Resources department in Singapore was known to fire staff in the past,
specifically, accountants who raised concerns about potential financial issues.

Being the company’s only lawyer in APAC, Gill worked closely with that finance colleague. The
informal, startup-like work culture also provided plenty of opportunities for building rapport through
No

daily lunches and after-work drinks. Over time, he managed to gain her trust and persuaded her to
confide in him. While speaking with Gill, she was noticeably under stress and fearful for her life and
that of her family, especially since she had received instructions from her boss to cook the books.

24
Dan McCrum, Stefania Palma, and Olaf Storbeck, “Wirecard’s Reluctant Whistleblower Tells His Story: ‘They Tried to Destroy
Me’”, Financial Times, May 20 2021, https://www.ft.com/content/1d74221e-1321-4f8c-9ca9-a4371629f178, accessed October 2022.
25
Paul Kilby, “Wirecard's Whistleblower”, Fraud Magazine, March/April 2022, https://www.fraud-magazine.com/cover-
article.aspx?id=4295017127, accessed October 2022.
26
Ibid.
Do

27
Sky Documentaries, “Wirecard – The Million Euro Lie”, https://www.sky.com/watch/title/programme/d706053f-fdd7-41cf-a0b5-
9720905ede4b/wirecard-a-billion-euro-lie-d706053f-fdd7-41cf-a0b5-9720905ede4b, accessed October 2022.
28
Ibid.
29
Ibid.

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 SMU-23-0013 A Whistleblower’s Dilemma in the House of Wirecard

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At that time, as a condition for the acquisition of Citigroup’s merchant businesses in Asia, Wirecard
had to obtain regulatory approvals and/or requisite licenses in the respective countries. A criterion

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was to demonstrate positive cash flow generation, which posed a problem to Kurniawan as nearly all
the company’s Asian subsidiaries were loss-making.30

Specifically in the Hong Kong market, Wirecard first submitted accounts of a dormant local
subsidiary which was not only loss-making but had no operating business and therefore there were
no projections. After being informed by the local compliance about the slim chances of approval

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using such a subsidiary as a license applicant, Kurniawan’s subsequent turnaround with profitable
projected earnings was enough to rouse suspicions.31

Gill learned of the workings behind the scenes from the whistleblower’s account of a meeting held a
month earlier. Kurniawan demonstrated his game plan to his team members:

Kurniawan called half a dozen colleagues into a Singapore meeting room. He picked up a

yo
whiteboard pen and began to teach them how to cook the books. [He] then sketched out a practice
known as “round-tripping”: a lump of money would leave the bank Wirecard owns in Germany,
show its face on the balance sheet of a dormant subsidiary in Hong Kong, depart to sit
momentarily in the books of an external “customer”, then travel back to Wirecard in India, where
it would look to local auditors like legitimate business revenue.32

Project Tiger
op
Following the meeting with the internal whistleblower, Gill informed Royston Ng, Singapore's head
of regulatory compliance. Ng was not part of the legal team at Wirecard but was recruited by and
reported to a business department, Global Financial Services, to ensure Wirecard obtained the
regulatory licenses to operate in Asian countries within the planned timeframe under the Citigroup
deal. Ng, a former public prosecutor, joined Wirecard about a month before Gill.
tC

Gill quickly decided to escalate the matter immediately and informed his direct supervisor in Munich
headquarters about his meeting with the internal whistleblower. It was midday in Singapore at that
time, Gill recalled. What followed seemed like a long wait for Munich, seven hours behind Singapore,
to wake up to the breaking news. As soon as the duo got through to Gill’s supervisor, the latter invited
Daniel Steinhoff, then Deputy General Counsel, and Vice President of Group Compliance, to the
conference call.
No

Responding promptly to the gravity of the situation, Steinhoff instructed Gill to launch an internal
investigation. Gill was concerned that the Asian operations might implicate the entire group of
companies and wished to expel the corrupt few to revive Wirecard like a phoenix rising from thea

30
Dan McCrum, Stefania Palma and Olaf Storbeck, “Wirecard’s Reluctant Whistleblower Tells His Story: ‘They Tried to Destroy
Do

Me’”, Financial Times, May 20, 2021, https://www.ft.com/content/1d74221e-1321-4f8c-9ca9-a4371629f178, accessed October 2022.
31
Ibid.
32
Dan McCrum and Stefania Palma, “Wirecard: Inside an Accounting Scandal”, Financial Times, February 7, 2019,
https://www.ft.com/content/d51a012e-1d6f-11e9-b126-46fc3ad87c65, accessed October 2022.

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 SMU-23-0013 A Whistleblower’s Dilemma in the House of Wirecard

shes.33 Initially codenamed Project Phoenix, the investigation was later renamed Project Tiger, a

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reference to Singapore as one of the four Asian Tiger high-growth economies.

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By mid-April, Steinhoff had ordered the mailboxes of Kurniawan and his two subordinates and
collaborators, James Aga Wardhana and Irene Chai Ai Lim,34 both senior finance executives, to be
replicated and given to Gill and Ng. After working through the weekend, Gill found what he
described as indisputable evidence – falsified accounts, backdated invoices, and fake company names
and logos on letterheads.35

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Wardhana was found to have emailed himself the logo of a hydraulics and piping company named
Flexi Flex in March, and the same brand name would then appear on invoices sent to Wirecard.36 He
did the same for two other companies, including one called Right Momentum LLC. The tell-tale sign
of forgery was that the design and format of the customer’s invoices were identical to Wirecard’s. In
April, Wardhana continued his deception. In his email replies to EY, Wirecard’s appointed auditor
on that year’s accounts, he had declared £4 million (US$5.2 million) of revenue earned by Wirecard

yo
Malaysia from Flexi Flex and another £3 million (US$3.9 million) for Wirecard in Hong Kong.37

Steinhoff had also given the green light for Gill to engage an external, independent team of lawyers
to probe deeper. To avoid any suspicion of conflict or bias, R&T solicitors specialising in white-
collar crime were chosen. Two weeks later, R&T’s 30-page preliminary report confirmed Gill’s
suspicions:
op
We may draw strong and irrefutable inferences from the documentary evidence there have been
at the very least several accounting irregularities which take the shape of forged agreements. In
the best-case scenario, the purpose behind these deliberate acts may be limited to the false
creation of revenue, with no wrongful misappropriation of monies. 38

R&T’s initial investigations revealed, among other things, that a round-tripping of £37 million
(US$48 million) was transferred from a Wirecard-owned bank in Germany to an inactive account
tC

belonging to a Hong Kong subsidiary. The money was then moved to an external company, before
appearing in Wirecard in India.39,40 In replies to auditors, non-existent companies were named as

33
Paul Kilby, “The Power of the Small: A Conversation with Wirecard Whistleblower Pav Gill”, Fraud Conference News, June 20,
2022, https://www.fraudconferencenews.com/home/2022/6/20/the-power-of-the-small-a-conversation-with-wirecard-whistleblower-pav-
No

gill, accessed October 2022.

34
In June 2023, James Wardhana and Irene Chai were convicted in Singapore. Shaffiq Alkhatib, “Two Wirecard Asia Ex-employees
Jailed for Offences Including Criminal Breach of Trust”, The Straits Times, June 20, 2023,
https://www.straitstimes.com/singapore/courts-crime/jail-for-2-wirecard-asia-ex-employees-for-offences-including-criminal-breach-of-
trust, accessed July 2023.
35
NewsBeezer, “Wirecard Whistleblower: The Uncoverer Comes Out of Cover”, May 19, 2021,
https://newsbeezer.com/austriaeng/wirecard-whistleblower-the-uncoverer-comes-out-of-cover/, accessed October 2022.
36
Dan McCrum and Stefania Palma, “Wirecard: Inside an Accounting Scandal”, Financial Times, February 7, 2019,
https://www.ft.com/content/d51a012e-1d6f-11e9-b126-46fc3ad87c65, accessed October 2022.
37
Ibid.
38
Ibid.
39
Prisca Ang, “Wirecard Foiled Staff Attempts to Speak Out: Whistle-blower”, The Straits Times, May 31, 2021,
Do

https://www.straitstimes.com/business/companies-markets/wirecard-foiled-staff-attempts-to-speak-out-whistle-blower, accessed October

2022.
40
Dan McCrum and Stefania Palma, “Wirecard: Inside an Accounting Scandal”, Financial Times, February 7, 2019,
https://www.ft.com/content/d51a012e-1d6f-11e9-b126-46fc3ad87c65, accessed October 2022.

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 SMU-23-0013 A Whistleblower’s Dilemma in the House of Wirecard

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customers that paid Wirecard subsidiaries in Hong Kong and Malaysia some £7 million (US$9
million).41

os
The Inconvenient Truth

In the absence of Steinhoff, who was away in Bali, Indonesia for two weeks, the internal
whistleblower became increasingly fearful for her safety and wanted to take the evidence to the police.
As a result, Gill felt compelled to speak to Andrea Görres, the General Counsel in Munich. Unaware

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that she was clueless about the happenings in Singapore, Gill then shared the draft findings of R&T’s
preliminary report, and Görres immediately took them to the Wirecard Board.

Wirecard’s management board demanded Görres take control of the investigation and initially sought
Marsalek to take over the probe. But Marsalek himself was alleged to be involved in the controversy.
Kurniawan had later admitted to R&T that the signed contracts and payments made were instructed
by Marsalek.42 The investigation was subsequently delegated to the Singapore CEO, who reported

yo
to Marsalek. It came as a total surprise to Gill that the trio in the finance team got off scot-free while
Kurniawan43 was subsequently promoted to Vice President of Controlling and Finance. On the other
hand, Ng was served a stern warning in a strongly worded message by Steinhoff, who had displayed
a turnaround in attitude by then. The latter’s email sent in June 2018 read,

As compliance, we still need to be a partner of the management. Our compliance role is to keep
damage away from the company and ensure that we can control the ‘grey areas’. We are not
op
prosecutors that try to make single people accountable and get them in jail (apart from real
misconduct).44

Görres subsequently came back to Gill and Ng and instructed them to stand down from the inquiry.
Ng eventually chose to heed the instruction, leaving Gill to fight for justice on his own.
The investigation without Gill’s involvement continued. The management did not halt the probe
because they saw it as a ‘gap analysis exercise’ that alerted them to issues that could expose their
tC

wrongdoings. In addition, the Wirecard Board introduced an internal whistleblowing channel

disguised as anonymous but according to Gill, it was in fact accessible by Marsalek who would then
proceed to weed out whistleblowers whom he perceived as troublemakers.

One Year in the House of Wirecard

No

From then on, Gill’s relations with the executives in Munich went sour. Soon, threats from the local
management started pouring in. Wirecard Singapore’s local CEO would barge in on Gill, shouting
at him in the office, and pressing him to withdraw from his involvement in the issue if he knew what

41
Ibid.
42
NewsBeezer, “Wirecard Whistleblower: The Uncoverer Comes Out of Cover”, May 19, 2021,
https://newsbeezer.com/austriaeng/wirecard-whistleblower-the-uncoverer-comes-out-of-cover/, accessed October 2022.
43
Kurniawan fled Singapore before police investigations began and was put on the Interpol red notice in 2022. Jessie Lim, “Interpol
Red Notice Issued Against Former Wirecard Director”, The Straits Times, September 7, 2022,
Do

https://www.straitstimes.com/singapore/courts-crime/interpol-red-notice-issued-against-former-wirecard-director, accessed July 2023.

44
Christoph Giesen, Klaus Ott, Nicolas Richter, Jan Willmroth and Nils Wischmeyer, “The Phoenix from Aschheim”, Sueddeutsche
Zeitung, https://www.sueddeutsche.de/projekte/artikel/wirtschaft/wirecard-the-phoenix-from-aschheim-e722975/, accessed October
2022.

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 SMU-23-0013 A Whistleblower’s Dilemma in the House of Wirecard

t
was “good for him”.

os
Adding to his woes, Kurniawan insisted that Gill should go on a business trip to Jakarta, the capital
city of Indonesia. One of Wirecard’s Indonesian entities was undergoing rebranding and Gill was
told to attend an in-person presentation by representatives from Indonesian law firms. However, he
saw no good reasons for him to be physically present as he had seen the proposals. Recalling that
Kurniawan had boasted about his wife’s family association with drug lords in Jakarta, Gill felt
intimidated.45 Two anonymous tip-offs from Munich had also urged him not to proceed, telling him,

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“We would strongly recommend you don’t go because you will not come back”.46

Fearing for his life, Gill’s mother forbade him to travel. His rationale was: “It makes no sense as to
why I need to be physically present for two simple proposals on a rebranding change from law firms
I had selected on my own. Something wasn’t right, so I didn’t want to go”. The consequence of his
refusal came soon after. Four days later, he was told by Wirecard Singapore’s local CEO to either
tender his resignation or face dismissal on unnamed grounds.

yo
Meanwhile, in September 2018, Wirecard replaced Commerzbank, the second largest bank in
Germany, to clinch a place in DAX, the country’s main stock index. That a fast-growing fintech had
surpassed an established, traditional banking institution was enough excitement for investors to snap
up Wirecard’s stocks, drive prices north, and turn the 49-year-old Braun into a billionaire.47

In that same month, Gill left Wirecard. But little did he imagine that in the months that followed,
op
Wirecard would continue to pursue him. Gill and his mother were stalked by people unknown to
them and neighbours reportedly saw strangers loitering near their apartment. Job interviews that Gill
went to would end up fishing for insider information at Wirecard and were in fact, as he had found,
a decoy to lure him to break his non-disclosure agreement with the company.48 Frustrated to the point
of exasperation, Gill was torn between exposing the scandal and keeping mum. What should he do?
tC
No

45
Paul Kilby, “Wirecard’s Whistleblower”, Fraud Magazine, March/April 2022, https://www.fraud-magazine.com/cover-
article.aspx?id=4295017127, accessed October 2022.
46
Ibid.
47
Jack Kelly, “Wirecard’s Former Billionaire CEO Markus Braun Arrested Over Allegations Of Fraud”, Forbes, June 23, 2020,
Do

https://www.forbes.com/sites/jackkelly/2020/06/23/wirecards-former-billionaire-ceo-markus-braun-arrested-over-allegations-of-
fraud/?sh=7377129634c1, accessed October 2022.
48
Paul Kilby, “Wirecard's Whistleblower”, Fraud Magazine, March/April 2022, https://www.fraud-magazine.com/cover-
article.aspx?id=4295017127, accessed October 2022.

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 SMU-23-0013 A Whistleblower’s Dilemma in the House of Wirecard

t
EXHIBIT 1: ALLEGATIONS MADE AGAINST WIRECARD BEFORE 2018

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The FT has compiled allegations put forth by various parties:

Year Source What the allegation was What happened thereafter

2008 A German Balance sheet irregularities Wirecard appointed EY to conduct a

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shareholder special audit, and the German
association authorities prosecuted two men in
connection with the allegation.
2015 FT €250 million (US$290 Wirecard responded with letters
million) suspected missing from Schillings, a UK law firm.
in accounts

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2015 J Capital Wirecard Asian operations Wirecard retorted that short sellers
Research smaller than it claimed paid for the report and arranged for
investment bank analysts to tour the
group’s Asian offices.
2016 Zatarra report Money laundering Wirecard denied everything. The
Federal Financial Supervisory
Authority (better known as BaFin),
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the German financial regulator
stepped in to investigate.

Source: Dan McCrum, “Wirecard: The Timeline”, Financial Times, June 25, 2020,
https://www.ft.com/content/284fb1ad-ddc0-45df-a075-0709b36868db, accessed November 2022.
tC
No
Do

10/10

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or 617.783.7860