“Something had to be done to replenish the coffers”: “Video: The Story of the IBC Act,” Harneys video, 4:52, http://micro.harneys.com/ibcact/.
no public registry of directors: “Law for Sale: A Study of the Delaware Corporation Law of 1967.”
The BVI law passed in 1984: “R. T. O’Neal’s Historic Move in HOA Unforgettable—Mrs. Flax,” Virgin Islands News Online, May 20, 2014, http://www.virginislandsnewsonline.com/en/news/r-t-oneals-historic-move-in-hoa-unforgettable-mrs-flax.
In 1986, there were slightly more than twelve thousand people: Email with Ermin Penn, historian, the British Virgin Islands Tourist Board and Film Commission.
John Christensen was an economic adviser to Jersey: Interview with John Christensen, January 2017; and “John Christensen on Rocking the Boat in Jersey,” Tax Justice Network, December 1, 2015, http://www.taxjustice.net/2015/12/01/john-christensen-reflections-of-a-whistleblower/.
Keith Flax, a local jeweler: “‘Flax Craft’ Fine Jewellery Store Reopens After 28 Years,” Virgin Islands News Online, July 12, 2014, http://www.virginislandsnewsonline.com/en/news/flax-craft-fine-jewellery-store-reopens-after-28-years.
a close friend of both Romney and Peters: Author interview with Ramón Fonseca, Panama, August 2016; and funeral program for Cyril B. Romney, Wickham’s Cay, British Virgin Islands, July 31, 2007, http://dspace.hlscc.org/jspui/bitstream/123456789/1808/1/Romney,%20Cyril%20Brandtford.pdf.
Adelina Mercedes Chavarria de Estribi: “Así viven los empresarios de papel,” Connectas, http://www.abc.com.py/especiales/secretos-en-paraisos-fiscales/empresarios-de-papel-1467612.html.
“The signed blank documents”: Ramón Fonseca, memo to Antoinette Stubbs, November 2, 1990.
Martin Kenney, a Canadian lawyer and fraud investigator: KPMG International, Review of Financial Regulation in the Caribbean Overseas Territories and Bermuda (London: Stationery Office, 2000).
The concept of the trust dates to feudal England: Brooke Harrington, Capital Without Borders: Wealth Managers and the One Percent (Cambridge, MA: Harvard University Press, 2016), p. 39; and “In Trusts We Trust,” Tax Justice Network, July 22, 2009, http://taxjustice.blogspot.ch/2009/07/in-trusts-we-trust.html.
a $50,000 fine or up to six months in prison: “Private Foundations,” brochure, Mossack Fonseca, p. 5.
calling certain trust arrangements a “sham”: Steve Meiklejohn, “Jersey: Sham Trust Finding Upheld in Jersey,” Mondaq, March 4, 2009, http://www.mondaq.com/jersey/x/75470/Trusts/Sham+Trust+Finding+Upheld+In+Jersey.
“When our legitimate revenues are attacked”: Franklin D. Roosevelt, “Message to Congress on Tax Evasion Prevention,” June 1, 1937, http://www.presidency.ucsb.edu/ws/?pid=15413.
grew rich smuggling whiskey: Richard Oulahan and William Lambert, “The Scandal in the Bahamas,” Life, February 3, 1967.
Meyer Lansky looked to the islands: Nicholas Shaxson, “The Truth About Tax Havens: Part 2,” Guardian, January 9, 2011, https://www.theguardian.com/business/2011/jan/09/truth-about-tax-havens-two.
Together they concocted a system: Ronen Palan, Richard Murphy, and Christian Chavagneux, Tax Havens: How Globalization Really Works (Ithaca, NY: Cornell University Press, 2009).
Mossack was familiar with the Liberian ship registry: Author interview with Jürgen Mossack, January 2017.
The Liberians readily assented in return for a cut of the proceeds: Rodney Carlisle, “The ‘American Century’ Implemented: Stettinius and the Liberian Flag of Convenience,” Business History Review 54, no. 2 (1980): 175–91.
A sparsely populated coral outcrop: http://www.niueisland.com/facts/.
Cross Trading, based in Niue, purchased the rights for Ecuadorian soccer matches: James Riach and Owen Gibson, “UEFA Offices Raided After Gianni Infantino Named in Panama Papers,” Guardian, April 6, 2016, https://www.theguardian.com/news/2016/apr/06/uefa-offices-raided-swiss-police-panama-papers-gianni-infantino.
By 1994, the BVI hosted 136,112 companies: Secretary of State for Foreign and Commonwealth Affairs, British Virgin Islands: Report of the Constitutional Commissioners 1993 (London: Stationery Office, 1994).
Mossfon accounted for more than 10 percent: Rigoberto Carvajal, analysis performed for the International Consortium of Investigative Journalists.
The BVI’s population had more than doubled: Johnson, “Saint Ursula and the 11,000 British Virgins.”
Today, the new BVI is a place: “BVI Community Board,” https://www.facebook.com/groups/178954908878855/.
3: NAME OF THE GAME
Gordon had graduated from the State University of New York: Author interview with John Gordon, New York, July 2016.
Norman Island, the inspiration for Robert Louis Stevenson’s Treasure Island: John Amrhein Jr., “Treasure Island: The Untold Story,” http://www.treasureislandtheuntoldstory.com/.
one of the largest counterfeit software cases in the country’s history: Rupert Steiner, “Police Investigate £2.5m Microsoft Forgery Racket,” Sunday Times, December 26, 1999.
“He instructs us to resign as Directors”: Fax from Ana Escobar to John Gordon, June 27, 1997.
“The two were idiots”: Author interview with John Gordon, New York, July 2016.
the police seized thousands of copies of pirated Microsoft software: Steiner, “Police Investigate £2.5m Microsoft Forgery Racket.”
“more unwanted and unneeded attention to all of us”: Fax from John Gordon to Ana Escobar, February 17, 1998.
Two years later, police dropped criminal charges: “Computer Fraud Prosecution Is Dropped,” News (Portsmouth, UK), March 12, 2002, http://www.portsmouth.co.uk/news/computer-fraud-prosecution-is-dropped-1-1275845.
“the highest possible degree of protection”: Carmen Haughton and Ramsés Owens email to Brenda Estanislau, March 2006.
“The two things this accomplishes”: Email from Wesley Long to Jennifer Mossack, February 9, 2008.
Fidentia went on to loot a survivors’ fund: Barry Sergeant, “Living Hands Rescued,” Moneyweb, March 5, 2007, http://www.moneyweb.co.za/archive/living-hands-rescued/; and Caryn Dolley, “I Don’t Know What Happened to the Money,” Cape Times, May 14, 2013, http://www.iol.co.za/capetimes/i-dont-know-what-happened-to-the-money-1515362.
Noriega’s usefulness diminished: Stephen Knott, “George H. W. Bush: Foreign Affairs,” Miller Center, University of Virginia, http://millercenter.org/president/biography/bush-foreign-affairs.
An Isle of Man newspaper report: “Panama’s the Place to Be,” November 1, 2001, https://web.archive.org/web/20130330113501/http://www.iomtoday.co.im/news/business/panama_s_the_place_to_be_1_1782652.
“You are an invisible man”: Email from Mossfon Trust, July 25, 2007.
“We must take into account”: Ramsés Owens, memo to Ramón Fonseca and Jürgen Mossack, October 19, 1998.
a population of less than twelve thousand: Jan Lahmeyer, “Liechtenstein: Historical Demographical Data of the Whole Country,” Populstat, November 19, 2003, http://www.populstat.info/Europe/liechtsc.htm; and Tony Paterson, “Liechtenstein: Where the Missing Billions Go,” Independent, February 26, 2008, http://www.independent.co.uk/news/world/europe/liechtenstein-where-the-missing-billions-go-787282.html.
creating a financial vehicle that anyone outside of Liechtenstein could use: Leo Zhang, “Trusts and Foundations: Protecting Your Wealth in Liechtenstein,” China Offshore, http://www.chinainvestin.com/index.php/zh/china-offshore/supplements/trusts-and-foundations/1668.
there was almost no official record of a foundation’s activities: Richard Murphy, “Why Is Liechtenstein a Tax Haven?” Tax Research UK, February 20, 2008, http://www.taxresearch.org.uk/Blog/2008/02/20/why-is-liechtenstein-a-tax-haven/.
Goodwin had bribed a fund manager: “Fidentia’s Goodwin Goes to Jail,” News 24 Archives, April 20, 2009, www.news24.com/SouthAfrica/News/Fidentias-Goodwin-goes-to-jail-20090420.
Goodwin was clearly a victim of circumstance: Steven Goodwin, Contact Report, Ramsés Owens, Mossfon Trust, March 18, 2007 (Contact Date:
March 12, 2007).
The South African press dubbed him the “missing man”: “Missing Man Features in Fidentia Indictment,” Mail & Guardian (Johannesburg), February 13, 2008, http://mg.co.za/article/2008-02-13-missing-man-features-in-fidentia-indictment.
“In this manner officially and truthfully”: Letter from Ramsés Owens, November 2003.
may have been Mexico’s first narcotics billionaire: Dolia Estevez, “Was Mexican Fugitive Caro Quintero the First Billionaire Drug Lord?” Forbes, October 1, 2013, http://www.forbes.com/sites/doliaestevez/2013/10/01/was-mexican-fugitive-caro-quintero-the-first-billionaire-drug-lord/#14de129c3a25.
Mexican soldiers destroyed product likely worth several billion dollars: David Luhnow, “Mexico Finds Large Marijuana Farm in Baja California,” Wall Street Journal, July 15, 2011, http://www.wsj.com/articles/SB10001424052702304521304576446441269265276.
Consumed by fury and paranoia: Paul Lieberman, “Agents Say Mexico Officials Stymied Raid,” Los Angeles Times, May 23, 1990, http://articles.latimes.com/1990-05-23/news/mn-151_1_marijuana-raid.
In January 1985, the two friends mistakenly walked into the Crazy Lobster: United Press International, “Two Bodies Unearthed in Mexico Forest,” Los Angeles Times, June 18, 1985, http://articles.latimes.com/1985-06-18/news/mn-3197_1_caro-quintero; and Jaime Ramírez Yáñez, “La caída de Rafael Caro Quintero,” El Economista, August 9, 2013, http://eleconomista.com.mx/sociedad/2013/08/09/caida-rafael-caro-quintero.
A doctor was on call to keep the DEA agent alive: Héctor Aguilar Camín, “Narco Historias extraordinarias,” Nexos, January 1, 2009, http://www.nexos.com.mx/?p=12886.
Caro Quintero boarded a Falcon executive jet: “Prime Suspect in Murder of U.S. Drug Agent Is Extradited to Mexico,” Los Angeles Times, April 6, 1985, http://articles.latimes.com/1985-04-06/news/mn-18337_1_drug-trafficker.
the U.S. embassy suggested they deliver the papers to Pla Horrit: https://www.wikileaks.org/plusd/cables/1976SANJO00550_b.html.
On April 4, Costa Rican authorities arrested Caro Quintero: “Costa Rican Police Seize Suspect in the Slaying of U.S. Drug Agent,” New York Times, April 5, 1985, http://www.nytimes.com/1985/04/05/world/costa-rican-police-seize-suspect-in-the-slaying-of-us-drug-agent.html.
Pla Horrit died on Christmas Eve in 2004: Tribunal Supremo de Elecciones, Consulta Civiles, Costa Rica.
a Mossfon lawyer sent an email to the partners: Rigoberto Coronado, email to Ramón Fonseca, Jürgen Mossack, and Chris Zollinger, March 18, 2005.
The Costa Rican government had given the committee: José Meléndez, “Sociedad de Mossack fue dueña de casa de Caro Quintero,” El Universal, April 15, 2016, http://www.eluniversal.com.mx/articulo/mundo/2016/04/15/una-sociedad-de-mossack-fue-duena-de-casa-de-caro-quintero. The house is located in Vasquez de Coronado, San José, Costa Rica. See “Comité Olímpico Nacional de Costa Rica-CONCRC,” Facebook.com, https://www.facebook.com/con.costarica/.
Before the United States could extradite him, he disappeared: Elaine Shannon, “A Drug Lord Walks Free in Mexico,” Los Angeles Times, August 18, 2013, http://articles.latimes.com/2013/aug/18/opinion/la-oe-0818-shannon-camarena-quintero-mexico-20130818.
his name sits atop the DEA’s list of fugitives: “DEA TOP Wanted Fugitives,” U.S. Drug Enforcement Administration, https://www.dea.gov/fugitives.shtml.
4: RISE OF THE GLOBAL BANKSTERS
HSBC ordered more than twenty-three hundred companies from Mossfon: Rigoberto Carvajal, analysis performed for the International Consortium of Investigative Journalists.
Guerrero’s top banking client was Luxembourg-based Safra Republic Holdings: Gerard Ryle, Will Fitzgibbon, Mar Cabra, Rigoberto Carvajal, Marina Walker Guevara, Martha M. Hamilton, and Tom Stites, “Banking Giant HSBC Sheltered Murky Cash Linked to Dictators and Arms Dealers,” International Consortium of Investigative Journalists, February 8, 2015, https://www.icij.org/project/swiss-leaks/banking-giant-hsbc-sheltered-murky-cash-linked-dictators-and-arms-dealers; and Associated Press, “Swiss Leaks Show Deposit by Daughter of China’s Ex-Premier,” February 11, 2015, https://cn.nytimes.com/china/20150211/c11lixiaolin/en-us/.
a combined $56 billion in assets under management: Richard Roberts and David Kynaston, The Lion Awakes: A Modern History of HSBC (London: Profile Books, 2015), p. 332.
set a fire inside a waste basket in his Monte Carlo penthouse: Dominick Dunne, “Death in Monaco,” Vanity Fair, December 2000, http://www.vanityfair.com/culture/2000/12/dunne200012.
Switzerland’s bank secrecy: Sébastien Guex, “The Origins of the Swiss Banking Secrecy Law and Its Repercussions for Swiss Federal Policy,” Business History Review 74, no. 2 (Summer 2000): 237–66.
In 1934, Switzerland made it a crime: Juliette Garside, “HSBC Files: How a 1934 Swiss Law Enshrined Secrecy,” Guardian, February 8, 2015, https://www.theguardian.com/business/2015/feb/08/hsbc-files-1934-swiss-law-secrecy.
based it in Hong Kong: Roberts and Kynaston, The Lion Awakes, p. 2.
a reputation as excessively conservative, secretive, and arrogant: Ibid., p. 430.
an opportunity for the wealth management industry: Ibid., p. 223.
Rumors that the bank served the criminal class: Gary Weiss, “The Mystery Man of Finance,” Bloomberg, March 6, 1995, https://www.bloomberg.com/news/articles/1994-03-06/the-mystery-man-of-finance.
testifying before a committee of the House of Lords: Martin Arnold, “Former HSBC Chief Admits Mistakes over Acquisitions,” Financial Review, July 15, 2015, http://www.afr.com/business/banking-and-finance/former-hsbc-chief-admits-mistakes-over-acquisitions-20150714-gichli.
Dedicating the resources needed to fix Republic: Roberts and Kynaston, The Lion Awakes, p. 340.
The deal was finalized a month after Safra’s funeral: Paul M. Beckett, “Fed Approves HSBC’s Acquisition of Republic New York for $9.9 Billion,” Wall Street Journal, December 9, 1999, https://www.wsj.com/articles/SB9445062058905250.
increasing assets under management to $122 billion: Roberts and Kynaston, The Lion Awakes, p. 227.
Prior to his death, Safra had shaved $450 million off the asking price: Andrew Anthony, “The Strange Case of Edmond Safra,” Guardian, October 28, 2000, https://www.theguardian.com/theobserver/2000/oct/29/features.magazine47; and Noelle Knox, “Pending Bank Settlement Raises Questions of Timing,” USA Today, November 15, 2001, http://usatoday30.usatoday.com/money/finance/2001-11-15-hsbc.htm.
slapped the bank with a $700 million fine: Jathon Sapsford, “Safra Accepts Less Cash to Finish Republic Deal,” Wall Street Journal, November 10, 1999, http://www.wsj.com/articles/SB942250896962729313.
profits soared to $440 million: Roberts and Kynaston, The Lion Awakes, p. 406.
“The banks knew why they wanted to buy companies and for whom”: Author interview with Adrian Simon, Geneva, September 2016.
“therapist, lightning rod, friend”: Marie Maurisse, “HSBC Suisse, pour l’amour des femmes,” Le Temps, February 10, 2015, https://www.letemps.ch/societe/2015/02/10/hsbc-suisse-amour-femmes.
the former Grand Hôtel Bellevue: https://saentys.com/work/quai-wilson-37.
“The MEDIS accounts were disproportionately more often the subjects”: Translation of interview with David Garrido by federal police in Brussels, October 29, 2014.
the Israeli billionaire Daniel Gertler: Elsa Buchanan, “DRC: Israeli Billionaire Dan Gertler Probed by UK Serious Fraud Office over Mining Deals,” International Business Times, December 5, 2016, http://www.ibtimes.co.uk/drc-israeli-billionaire-dan-gertler-probed-by-uk-serious-fraud-office-over-mining-deals-1594961; and Uri Blau and Daniel Dolev, “Israeli Diamond Tycoons Listed in Leaked Panama Papers,” Haaretz, April 7, 2016, http://www.haaretz.com/israel-news/1.713130.
another Israeli billionaire, Benjamin “Beny” Steinmetz: Silas Gbandia, Cooper Inveen, Khadija Sharife, Will Fitzgibbon, and Michael Hudson, “Diamond Mine with Offshore Ties Leaves Trail of Complaints,” International Consortium of Investigative Journalists, July 25, 2016, https://panamapapers.icij.org/2016072
5-sierra-leone-diamonds.html.
In 2016, he was arrested in Israel: Ian Cobain and Peter Beaumont, “Israeli Tycoon Beny Steinmetz Arrested over Guinea Bribery Claims,” Guardian, December 19, 2016, https://www.theguardian.com/world/2016/dec/19/israeli-tycoon-beny-steinmetz-arrested-over-guinea-bribery-claims.
An Interpol alert for his arrest: Ryan Chittum, “Diamond Dealers in Deep Trouble as Bank Documents Shine Light on Secret Ways,” International Consortium of Investigative Journalists, February 9, 2015, https://www.icij.org/project/swiss-leaks/diamond-dealers-deep-trouble-bank-documents-shine-light-secret-ways.
Michael Geoghegan began his HSBC career in 1973: Roberts and Kynaston, The Lion Awakes, p. 453.
“this was a special case for their senior executive”: Fax from July le Feuvre to Manuela Fogarty, March 14, 1997.
a house in London’s posh Kensington neighborhood: Holly Watt and David Pegg, “Former HSBC Boss Tried to Avoid Tax on £8m Kensington House,” Guardian, April 7, 2016, https://www.theguardian.com/news/2016/apr/07/ex-hsbc-boss-michael-geoghegan-panama-papers-tried-to-avoid-tax-kensington-house.
Stuart Gulliver succeeded Geoghegan as HSBC’s chief executive officer in 2010: Jill Treanor, “HSBC Chief Mike Geohegan Ousted After Brutal Boardroom Battle,” Guardian, September 23, 2010, https://www.theguardian.com/business/2010/sep/23/hsbc-mike-geohegan-replaced-stuart-gulliver.
Gulliver had started his career as a relationship manager in 1981: Roberts and Kynaston, The Lion Awakes, p. 389.
Gulliver used the company to receive his HSBC bonuses: James Ball, Juliette Garside, David Pegg, and Harry Davies, “Revealed: Swiss Account Secret of HSBC Chief Stuart Gulliver,” Guardian, February 23, 2015, https://www.theguardian.com/business/2015/feb/22/swiss-account-secret-of-hsbc-chief-stuart-gulliver-revealed.
Then they tried Tesler: Will Fitzgibbon, “Files Open New Window on $182-Million Halliburton Bribery Scandal in Nigeria,” International Consortium of Investigative Journalists, February 10, 2015, https://www.icij.org/project/swiss-leaks/files-open-new-window-182-million-halliburton-bribery-scandal-nigeria.
in a Nigerian hotel parking lot: United States of America v. Jeffrey Tesler and Wojciech J. Chodan, Indictment, United States Southern District of Texas, February 17, 2009.
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