The Panama Papers: The World’s Largest Data Breach

Episode Notes

Transcript

 

Lawyer 2 Lawyer: The Panama Papers – 6/17/2016

 

Intro: Now both the law firm, Mossack Fonseca and as politicians wash their hands and say, “We don’t know what’s going on,” people weigh liabilities from the underlying people who have issues the power of attorney. We don’t want to encourage that kind of behavior in our society.

 

It’s fairly clear that from what we seem to know about some of the email trail that this is a compliance failure of an epic level and I don’t think any prosecutor, if it should come to that, should even consider that a defense.

 

Welcome to the award-winning podcast Lawyer to Layer, with J. Craig Williams and Robert Ambrogi, bringing you the latest legal news and observations with the leading experts in the legal profession. You’re listening to Legal Talk Network.

 

J. Craig Williams: Hello and welcome to Lawyer 2 Lawyer on the Legal Talk Network. This is Craig Williams coming to you from Southern California. I write a blog called May it Please the Court.

 

Bob Ambrogi: And this is Bob Ambrogi coming to from Boston, Massachusetts. I write a blog called Lawsites and also co host another Legal Talk Network program called Law Technology Now with Monica Bay.

 

J. Craig Williams: Bob, before we introduce today’s topic, we’d like to thank our sponsor, Clio, an  online practice management program for lawyers at www.GoClio.com.

 

Bob Ambrogi: Two weeks ago, the Washington-based International Consortium of Investigative Journalists started publishing the so-called Panama Papers collection of more than ten million documents leaked from the law firm Mossack Fonseca with information on some 200,000 anonymous shell companies used by world leaders, politicians, and various others including the prime minister of Iceland, whose name I’m not going to start to pronounce.

 

J. Craig Williams: I just wondered whether you were going to try and pronounce that. Sigurður Ingi Jóhannsson. In any event, just this month, a German newspaper announced that 11 and a half million confidential documents from back in 1970 to 2015 have been leaked from the firm to journalists. These so called Panama Papers revealed how clients paid billions of dollars in offshore tax shelters. There are many issues at hand here establishing these offshore entities who paid in taxes laundering money, fraud, overall corruption; sure to be an interesting thing for a long time to come.

 

Bob Ambrogi: So today on Lawyer 2 Lawyer we’re going to take a look at the Panama Papers and some of the legal implications they raise: shell companies, offshore bank accounts, the issues of data security, tax evasion, investigations and even the implications for the law firm Mossack Fonseca.

 

J. Craig Williams: Well, Bob, our first guest to help us with that today is Jessica Tillipman. She is the assistant dean for field placement at George Washington Law School. Jessica is an expert in corruption, government ethics, and the Foreign Corrupt Practices Act. She is a senior editor of the FCPA Blog, which has been following the Panama Papers and all of the revelations that flow from it. You can follow her blog at FCPABlog.com. Thank you for joining us, Jessica.

 

Jessica Tillipman: Thank you for inviting me.

 

Bob Ambrogi: And also joining us today is Professor William Byrnes, a member of the law faculty and an associate dean with Texas A&M University School of Law. William Burns held a senior position of international tax for a Big 6 firm and has been commissioned to consult on fiscal policy by a number of governments. He has written many books and articles and is currently developing a tax and legal risk management online curriculum for professionals. He writes the blog, Byrnes Tax and Compliance Blog at ProfWilliamByrnes.com and also writes the International Financial Law Prof Blog, part of the Law Professor Blogs Network.

Welcome to Lawyer 2 Lawyer, WIlliam Burns.

 

Professor William Byrnes: Hey, thank you for focusing on this really important topic of the Panama Papers.

 

Bob Ambrogi: It’s a really interesting topic for sure. William, maybe we can start with you and just ask what exactly are the Panama Papers about and what’s the big deal? Why are they drawing so much attention?

 

Professor William Byrnes: What the Panama Papers – why it’s really exciting – it’s not the first time we’ve had a major leak. You won’t know this name but there was the big Portcullis leak which was a couple of years ago and it was several million documents. There was the HSBC leak, the UBS leak and of course the Lux leak. So they’ve all been really exciting – when I say exciting, at least for the academics to engage in research and for government prosecutorial officials that Jessica talks with a lot. Perhaps not exciting for the people named in the papers, but this one is so exciting because it’s 40 years of history that traces back almost year for year, captured legacy information. It’s really incredible. It’s like finding a King Tut’s tomb for a historian and it’s just a really rare circumstance. And what’s inside of it that makes it so interesting? Going back to letters, faxes and of course emails in our modern history in the last, say, 15 or 20 years, this law firm was probably the largest or second to largest law firm operating in this foreign incorporation service area. Now according to the news reports, we now have 14 thousand clients of the law firm have been potentially exposed and over 200 thousand other companies and over literally millions and millions of documents associated with that. That’s a lot of data. It’s going to take literally years to comb through this data and really connect the dots. And when you take this Panama Paper and you match it to the data from the Portcullis leak and the HSBC leak and the UBS leak and all the other leaks plus the new information the governments are going to start getting next year pursuant to the common reporting standards – in the United States we call that FATCA – it’s going to create a window into Alice’s Wonderland. We’re going to see a window into a land that government agencies and regulators have for far too long have not had a real clear picture of. It’s like looking through a real smoky filtered mirror and all of a sudden having it wiped clean and being able to see clearly. Or getting that new 20/20 prescription spectacles and you can all of a sudden see for the first time in your life. I’ve had this experience recently. So it’s really exciting, for Jessica’s world also. Because I’m thinking from the tax perspective, of course Jessica is thinking from the corruption and so forth. But I’d like to hear what she thinks about the papers.

 

J. Craig Williams: And Jessica, can you also comment for us on who are the perpetrators of this? Who are the group of journalists and what connections did they have around the world with any governmental entities who are very interested in this information?

 

Jessica Tillipman: Well, if we’re talking first about the leak, we don’t know the identity of the leak or if it’s an individual or a group of individuals. We know at this point that this has been held confidential for obvious reasons. There’s a lot of important people implicated in the leak and if the identity of this individual were to be exposed, that could cause serious problems for that person’s life or livelihood – probably life. But as far as the journalists, it’s interesting that they seem to go to non-US journalists for this leak or expose. And it’s a consortium of journalists from around the world that are able to report on these stories. What I find fascinating, though, is that because of the international reporting, the magnitude, the scope of the reporting, you’ve seen quite a reaction in many countries. Like we’ve seen in Iceland – and again I’m not going to pronounce the name as well, but a former leader stepping down. You’ve seen this in numerous countries there’s pressure in the Ukraine, there’s pressure on David Cameron in the UK. What I find fascinating is while there’s been so much openness globally, in certain areas like China, it’s been restricted. This information has been banned from Chinese websites. So their citizens don’t have access to the same amount of information. So I think we’re seeing a global reaction from the citizens of these countries from opposition parties, from creditors, from potentially spouses that may have had assets hidden from them, from prosecutors. But you’re not going to see it in certain countries that believe in censorship.

 

Bob Ambrogi: It seems like the biggest thing we’re seeing out of this so far is just how extensively these shell companies are being used and for the various types of reasons that they’re being used. What’s wrong with that? What’s wrong with the companies using shell companies like this? Why should we be concerned about this?

 

Jessica Tillipman: Well there are some legitimate reasons and William may be able to come out of a tax perspective or go into some of the reasons why some companies are used offshore anonymously in certain cases. But for the most part it’s a really wonderful way for criminals to launder their funds, hide a list of assets for drug dealers, mobsters to hide their money. It’s a great way for individuals who are sanctioned, on sanction lists or blacklisted globally to continue to conduct business without having international regulators watching them. It’s a great way – as I said before – for people trying to hide from creditors to conceal funds. It’s a good way for people who are trying to hide assets in a divorce to conceal funds. So there’s a variety of reasons why people can use this because once you enter this illicit system – and again, it’s not always illicit but sometimes it can be – once you enter this shadowy world of anonymous shell corporations, it’s very, very easy to disguise the ownership of companies, to disguise the ownership of certain assets, to hide funds from people who really deserve to see them or want to see them. So overall, it’s been a good way for people for many, many decades to conceal this money and this information.

 

Bob Ambrogi: When you say the word illicit, it’s not in and of itself unlawful to have a shell company. Is it the purposes for which you have the shell company or are there cases in which the company itself or the structure itself is unlawful?

 

Jessica Tillipman: You’re correct. It’s not illegal itself to have one of these companies. It’s when you’re using these companies to conceal illicit funds; that can cause a problem. Not necessarily in the setting up of a company, it can be perfectly legal in the jurisdiction in which you’re establishing the company. The problem again is you’re dealing with sometimes money laundering where perhaps you are a corrupt politician in a country that’s known for corruption and you’ve embezzled funds from your government and you’ve now stashed them into some offshore company that can’t disclose the owner because through a series of transactions you’ve paid your ownership which is quite easy to do in many of these countries. That is a problem in itself, it’s the underlying criminal conduct. And what we’re seeing in many instances is that firms like Mossack Fonseca have essentially aided companies and individuals that have tried to conceal illicit assets. They don’t do any due diligence or minimal due diligence on the people who are trying to establish these companies. So it’s the lack of due diligence to look into who these people are, where these funds are coming from that’s so problematic. And also some of the information that’s come out where they’ve backed information or all of there certain documents in order to comply with certain regulations is also certainly problematic.

 

J. Craig Williams: Well, William, wouldn’t the law firm in Panama have what’s essentially the Nuremberg defense, “We just did what we were told”? What obligations did they have to undertake the due diligence that Jessica’s talking about?

 

Professor William Byrnes: So this is a point that a lot of people are missing about Panama so I think this will be uniquely the first time it’s described right here on your show. Panama has its cork in its civil law system which allows a corporation to the director of the corporation were authorized to operate off of by the company to issue a power of attorney. Now that’s normal, to issue a power of attorney. But the cork in their law allows the corporation’s’ directors not to be responsible in law for the actions of the power of attorney. Now in the United States of course, if a company issues a power of attorney and the power of attorney acts nefariously or money laundering or any number of things, civil liability of the corporation is on the hook and the directors can be on the hook if you pierce the corporate veil; but in Panama, not so. So Mossack Fonseca, as you said they pulled the Nuremberg defense or what have you. Under their legal system in Panama, they would claim that they helped write the law, of course. So they would state that not only don’t we have a requirement to diligence – this would be their argument – certainly in the past we’ve never had a requirement to diligence to the clients. But because of these power of attorneys, we don’t know what’s going on at all. Now you and I and most Westerners would say that’s poppycock and we would hold the corporation and their directors – and in this case the company secretary and that’s the law firm – responsible for the actions of the power of attorney. Why would I bring that up? Well, who are the power of attorneys? So I won’t say specific countries but there have been a lot of reports about a particular well-known global leader. And he’s not named in the documents but an associate, a musician associate of his is named in the documents and that musician associate’s worth a billion dollars and somehow there may be a connection between. So what I suspect is really going on though is that the company has issued power of attorneys to the politician in question or the politician’s closer associates who are acting on behalf of the company, setting up bank accounts, entering in transactions, these contracts. And now, both the law firm Mossack Fonseca and the politician washed their hands and say we don’t know what’s going on because there are these ghosts of these power of attorneys did it and who are these power of attorneys? That’s a real challenge that’s going on in Panama. That practice really does need to be stopped. It’s not that power of attorneys are bad, but when power of attorneys can be used in a way to take away liability from the underlying people who have issued the power of attorney, we don’t want to encourage that kind of behavior in our society.

 

J. Craig Williams: Jessica, Mossack itself was interviewed by the Wall Street Journal and firm leaders said they’ve made mistakes and so has our compliance department, but that’s not the norm. So your statement that they don’t have any compliance or due diligence seems to be belied by what they’re saying. But what do you know about what it is that they in fact do check?

 

Jessica Tillipman: Well, I don’t think we know very much and it doesn’t sound like they check very much on what’s been publically released. By any measure of evaluation, it’s a failure of a compliance program if they’re trying to suggest that they have a robust or even remotely effective compliance program. Internationally there’s now a global standard from companies, banks, et cetera in setting up a compliance program and what it should do, how it should comply with laws and regulations, how it should comply with anti-corruption laws and other requirements. And by any stretch of the imagination, even if they’re complying technically as William suggested with certain laws to ensure the privacy of their clients, it’s fairly clear that from at least what we know about this email trail is that this is a compliance failure of an epic level and I don’t think any prosecutor – if it should come to that – would consider that to be a defense.

 

Bob Ambrogi: We hear all the time about enhanced enforcement all around the world of anti corruption laws as you just mentioned. What do these papers tell us if anything about the effectiveness of those laws or to the extent of which they’re being complied with?

 

Jessica Tillipman: They don’t tell us too much when it comes to Foreign Corrupt Practices Act, which is a law that prohibits the bribery of foreign government officials. And we know US passed its law in the late 70’s and in the intervening decades we’ve seen other countries pass similar laws. And at least in the past decade, five to ten years we’ve seen renewed efforts to increase enforcement globally. So we know that this is occurring and this has been quite successful from a prosecutorial standpoint – we’re not only seeing the US take the lead in this but we’re seeing other countries start to similarly enforce these actions. But we’re also seeing companies react to this in a way in which they’re developing more robust international compliance programs. So overall it’s been remarkably successful in changing corporate culture to a certain extent. But what this is showing is the limitations to that. We’ve seen that at least some of the names of companies that have settled a CPA action have connections with companies whose names have been leaked as part of this giant leak of information. Whether that leaks to anything, we don’t know, but at least we know there’s a connection. What I find more interesting is that there is a limitation to these anti corruption laws. The SPCA and laws similar to it that prohibit the bribery of foreign government officials. What they don’t allow is the prosecution of the actual government officials that have accepted the bribes. So what I found interesting about these leaks is that it may expose what some of these officials who have accepted these corporate bribers are doing with the money. So that could be a potential outlet for maybe local politicians or local governments or local prosecutors to maybe eventually have the key that they need to prosecute the corrupt officials that have been accepting bribery. Because what we see in these countries is that the companies that pay the bribes get prosecuted and the officials that accept the bribe, nothing happen to them. In fact, these are the individuals that are defrauding their country, the countries that need to have the services and goods be above board and provided to them in a way that they should have been procured. So what’s interesting to me is that we may actually now see a connection between the funds that have been paid to these individuals and where the money’s actually been going. It’s possible, again, we don’t know that yet.

 

Bob Ambrogi: Before we move on to our next segment we’re going to have to take a short break. Stay with us and we will be back after these words from our sponsors.

 

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J. Craig Williams: Welcome back to Lawyer 2 Lawyer, this is Craig Williams and with us today is Jessica Tillipman and William Byrnes. In our last segment, we’ve been discussing the Panama Papers. What sequence do you see happening here, William? From what I understand there is going to be a big cross referencing that comes out in May along with a listing of all the individuals and the website put up by a journalist seems to be extremely detailed so far with the names of particular leaders across practically every major country in the world; along with the very names of the company they’ve set up. What more are we going to learn?

 

Professor William Byrnes: I’ve already started to cross list, so I’ve been studying. So there’s something called a Foreign Account Tax Compliance Act, FATCA, in the United States. And that requires all foreign financial institutions and intermediaries to register with the IRS to obtain – let’s call it a compliance number to keep it simplistic; so global identification numbers. And by registering, they are certifying that they are going to – for purposes of the United States tax system – fess up when there is an ultimate beneficial United States account holder or owner of a company. So of course, when the first list of thousands and thousands of corporate names and directors was published, I downloaded it. And then I ran a check against the list from the IRS list that you can download every month. And I found so far – just a cursory inspection – I found many, over 35 cross referenced corporate names; and of course Mossack Fonseca itself. So these are corporations and in the firm itself who are stating that they are – as of this year, that’s 2016 – going to inform the IRS of their underlying United States account holders and underlying US owners of business associations and corporate entities. So that begs the question, is Mossack Fonseca telling the truth? And I think that it’s going to these papers to trillion bytes of information. I think they’re going to help the IRS from a verification perspective to determine whether this firm in particular and all these other corporations it’s dealt with are in fact providing the United States that information. Now of course, other governments – as I said next year –  have this common reporting standard, CRS. It’s the same thing as FATCA, just globalized being handled through the OECD, and they’re going to do the same check. They’re going to take their data and compare it against all the other data they have from the other leaks and this new CRS data and it’s going to be really difficult starting next year, especially with artificial intelligence programs and software, for nefarious criminals. And when I say nefarious, I’m not just talking the corruption in Jessica’s world. But in today’s world, that means tax evasion. So it’s going to be very difficult for them to commit the crime in the first place, the tax evasion, to get to the second place of then benefiting from the proceeds of their crime, the money laundering side of this. So brave new world for the criminal.

 

Bob Ambrogi: Jessica, what do these papers tell us, if anything, about the complicity of financial institutions in this international shell game of hiding assets and laundering money? Is there some responsibility of due diligence on their part with respect to these shell companies?

 

Jessica Tillipman: Well, there’s certainly responsibility on the part of financial institutions to do due diligence. They also have certain reporting requirements that they have to comply with. Again, the presence of these anonymous shell companies can oftentimes makes some of these things difficult but they do have due diligence obligations themselves. What we’ve seen – at least in recent years with exposes – there’s been amazing work done by organizations like Global Financial Integrity, Global Witness and Transparency International that have been calling for an end to these anonymous shell companies because they have been so successful in shielding criminals from liability – particularly those that engage in corruption, tax evasion, money laundering, et cetera. What we’re seeing is that the role of banks and indeed lawyers can be underplayed. We see this time and time again that they have been quite complicit in assisting in many of these transactions. Recently on 60 Minutes there was an expose where 60 Minutes worked with the organization Global Witness. They sent an individual who had connections to a fake minister in Africa where if you are even slightly familiar with the red flags of corruption was describing what could have been seen as a minister in Africa who had stolen funds and was trying to find a way to essentially conceal the funds in the US and make purchases in the US after concealing these funds. They went to a dozen lawyers or so to see if they could get assistance with this and only one attorney really turned them away. The rest seemed willing to listen and even potentially work with this individual that was so quite clearly bringing to them a scheme that involved red flags of corruption. Willing to work with them potentially to set up or assist them in setting up shell companies to hide this illicit funding. So it’s quite interesting-

 

Bob Ambrogi: Including a former ABA President which was kind of interesting.

 

Jessica Tillipman: That is true, a former ABA president and the ABA had to come out with a statement about it and it’s been quite embarrassing. But it was pretty shocking, especially since this is a legal talk show. As you know, it’s pretty shocking to see what these attorneys’ responses were. But at the end of the day, it really does show the role that both lawyers, banks, and other intermediaries play in these types of transactions.

 

J. Craig Williams: What kinds of criminal penalties are we going to be looking at here in the United States and potentially across the world if you have any idea? We have some acts that are applicable that we talked about today. Are there any criminal aspects to those?

 

Jessica Tillipman: Right now it’s impossible to know. Right now what you’re going to see is are regulators looking to connect the dots. What’s interesting is that most of what we’re going to see were probably legal. If you’re going to look at it from the standpoint of setting up these entities, you’re going to see that a lot of times, the way these are established, they fall into gray areas of the law. You may not ever see prosecutions for probably a majority of the individuals that have been exposed by this leak. What will be interesting is whether or not the investigators in the United States take a look at the connection to any type of crimes that they may be able to connect the dots to something like money laundering which is a criminal law in the United States. Tax evasion which can be criminal, whether there’s corruption involved, fraud, even something like the violation of foreign practices act, oftentimes we see that companies will funnel payments to foreign officials through shell companies so that’s possible we will see a connection there. We’ll even see something from other countries that are also looking into this leak to see if they can find connections. But it’s hard to tell at this point because right now they’re just dealing with raw data.

 

Bob Ambrogi: William, as Jessica had mentioned earlier, the notion that there’s been a call for getting rid of these kinds of shell companies and requiring at least the beneficial owners of these companies to be identified, what do you see here in terms of the need for legal reform coming out of these papers?

 

Professor William Byrnes: It’s going to happen that the beneficial owners and their actual directors – as I mentioned, this power of attorney hide and seek game – that they’re all going to be in corporate registries. They already have to be reported to the treasuries. Not doing that is already an evasion of law. However, that’s the tax side of it. For the criminal side of it, these company registries are going to be accessible and this is what european union is calling for, and I suspect it’s going to go through on a real time basis. So it’s not an annual spreadsheet, it’s going to be a real time accessible – and then the question is whether it’s going to be accessible to the public or not. So it’s one thing to have what we call FIU’s – the intelligence units in each domestic government, even Panama has one of those – every country in the world has an FIU like here with the attorney general of the United States. And they have the potential access obviously to US records. Of course, we all know that’s a myth and they don’t have access to by example, the Delaware beneficial owners. And that’s a huge challenge for the rest of the world because they state that we, the rest of the world, are trying to clean up this mess; and you, the United States, are actually the one that’s perpetuating it. With a little country like Panama, we could take care of them, but the United States is really putting in the road blocks, so that’s one interesting challenge. But we haven’t mentioned yet suspicious activity reports, or what we call overseas, suspicious transaction reports. Financial intermediaries, including Mossack Fonseca, are required by law in every country in the world, to file when they have an incident that rises to suspicious activity. And that doesn’t mean criminal, it means the potentiality of criminal, so it’s suspicious. You have to, by law, file a suspicious activity report within the United States. In some countries like the United Kingdom, lawyers also have that requirement to file. In the United States, lawyers don’t have the requirement to file a suspicious activities report but they do have to file currency transaction reports if they receive cash from their clients in excess of $10,000. Attorneys In the United States have been prosecuted. If you remember the very famous case in Florida of Al Gore’s attorney for the election and he was really drug through the mud and prosecuted criminally, very aggressively, for his case of defending drug lords. So one possibility to come out of this is that attorneys will be required to file not just in the UK but globally suspicious activity reports on their clients. And of course, the US attorneys will say attorney client privilege. But the UK also has attorney client privilege and has managed to work through those issues to a point where there is a peace between the Bar and the government investigatory. So you’re going to have access to the beneficial ownership information on a real time basis – at least for the regulatory authorities, possibly for the public. And secondly, I think you’re going to see law firms being required going forward maybe from 2017 in most countries. Maybe not the US, maybe we’ll drag our feet again just like we do on the beneficial ownership information. But for most countries of the world, law firms will be required to file suspicious activity reports on their clients.

 

J. Craig Williams: It looks like we’ve just about reached the end of our program and we’d like to take this moment to invite our guests to share their final thoughts as well as their contact information. So Jessica, let’s start with you. Wrap it up and please give us your contact information.

 

Jessica Tillipman: Sure. Thank you for having me today, I think this is a fascinating topic but I think we’re just at the tip of the iceberg. I think we’re ready to see what else stems and flows from this amazing leak of information. You can reach me through my Twitter handle, @JTillipman, and you can also check out my blog at the FCPABlog.com. Thanks.

 

J. Craig Williams: And William?

 

Professor William Byrnes: Jessica and I are both academics doing a lot of research on these issues. She primarily from the political corruption, myself from the tax and tax evasion. So feel free to Google me, William Byrnes. I have plenty of contact details online and if you’re interested in this topic from a research perspective, send me your research or let’s talk and see about opportunities for collaboration.

 

Bob Ambrogi: Thanks a lot. We’ve been talking with Jessica Tillipman, assistant dean for field placement at George Washington Law school and senior editor of the FCPA Blog and with William Byrnes, member of the law faculty and an associate dean with Texas A&M University School of Law. Thanks to both of you for your time and insights on this topic today, I really appreciate it.

 

Jessica Tillipman: Thank you.

 

Professor William Byrnes: Thank you kindly.

 

J. Craig Williams: Thank you. That brings us to the end of our show for today. This is Bob Ambrogi and thanks for listening. Join us next time for another great topic. When you want legal, think Lawyer 2 Lawyer.
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