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Wirecard

Wirecard AG was a German financial technology company founded in 1999 near Munich, initially providing payment processing services for online transactions, including high-risk sectors such as gambling and adult entertainment. It specialized in electronic payment solutions, risk management, and issuing prepaid cards, expanding into banking and lending through aggressive acquisitions and partnerships. Headquartered in Aschheim, the firm grew rapidly under CEO Markus Braun, achieving a market capitalization exceeding €24 billion at its peak and earning inclusion in Germany's DAX 30 index in September 2018. The company's ascent was marred by persistent allegations of accounting irregularities, particularly concerning its Asian operations, which were later exposed as largely fictitious. In June 2020, Wirecard filed for insolvency after auditors could not verify €1.9 billion in reported cash balances, primarily held in purported escrow accounts in the Philippines that did not exist, revealing one of Europe's largest corporate frauds. The scandal prompted criminal charges against Braun and other executives for fraud, market manipulation, and falsifying accounts, alongside criticism of auditing firm EY for failing to detect the discrepancies over a decade and of BaFin regulators for inadequate oversight. Trials began in 2022, highlighting systemic failures in corporate governance and financial reporting in Germany, and leading to index reforms and enhanced auditing requirements.

Origins and Early Development

Founding and Initial Business Model

Wirecard was founded in January 1999 in a suburb of , , initially operating as Wire Card, a provider of electronic processing services amid the late stages of the dot-com boom. The company's early operations focused on facilitating transactions for vendors, leveraging to handle the technical aspects of authorization, settlement, and risk assessment in an era when infrastructure was nascent. The initial business model emphasized serving high-risk sectors underserved by conventional banks, including and adult entertainment websites, which required specialized processing for transactions often rejected by mainstream providers due to and regulatory concerns. This niche positioning allowed Wirecard to capitalize on the rapid growth of internet-based commerce, processing payments through partnerships with card networks and acquiring banks while managing associated risks like chargebacks. By 2000, the dot-com market crash strained the young firm, leading to financial distress and a recapitalization effort that preserved its core operations. joined the company around this time, contributing expertise in mobile and wireless payment systems, which complemented the foundational focus but did not alter the primary model until later changes.

Merger with InfoGenie and Public Listing

In December 2004, Wirecard Technologies , a private payment processing firm, entered into a reverse merger with InfoGenie AG, a publicly traded but struggling focused on call center operations and services listed on the Neuer Markt segment of the . The transaction, dated December 14, 2004, involved InfoGenie issuing new shares in exchange for Wirecard's assets, effectively allowing the private entity to assume control and utilize InfoGenie's listing shell without a traditional . This structure was common for faster access to public markets, particularly for tech firms seeking capital amid InfoGenie's declining operations, which largely ceased post-merger. Markus Braun, who had acquired significant influence in InfoGenie earlier in 2004, played a key role in orchestrating the deal, positioning Wirecard's payment processing business at the forefront of the combined entity. On March 14, 2005, the merger was formalized with the entry of the name change from InfoGenie AG to Wirecard AG in the commercial register, marking the official transition. Following this, Wirecard AG's shares began trading on the Prime Standard segment of the in 2005, providing immediate liquidity and visibility to investors. The public listing via reverse merger enabled Wirecard to raise capital efficiently, bypassing the regulatory scrutiny of a full IPO, and set the stage for its expansion into electronic payments and banking services. At the time, the company's was modest, reflecting its early-stage focus, but the structure drew limited contemporaneous criticism despite InfoGenie's prior delisting attempts from the Neuer Markt being blocked by courts in 2002. This transformed Wirecard from a non-listed into a market-listed entity, with assuming CEO duties to drive subsequent growth.

Business Operations and Expansion

Core Products and Services

Wirecard AG specialized in electronic processing, providing acquiring services that enabled merchants to accept and payments, as well as alternative methods like and payment systems, through its proprietary platforms. These services included transaction settlement across multiple currencies and geographies, fraud detection via real-time monitoring, and tools to assess and mitigate financial exposures for clients. A key component involved card issuing through its subsidiary Wirecard Bank AG, which held a banking license and facilitated the issuance of physical prepaid cards, virtual cards, and debit products for corporate and consumer use, often integrated with loyalty programs and e-wallets. The bank also supported deposit management and basic banking functionalities, allowing Wirecard to offer end-to-end solutions, from to issuance and . The company's platforms extended to and gateways, such as the Wirecard Payment Page, which handled customizable checkouts, installment options, and cross-border transactions for over 250,000 merchants globally by 2020. Additional offerings encompassed software for digital retail transformation, including point-of-sale integrations and for transaction optimization. These services were marketed as scalable, technology-driven solutions, leveraging for seamless merchant integration.

International Growth and Partnerships

Wirecard's international expansion strategy emphasized acquisitions of local payment processors and strategic alliances to rapidly scale operations in emerging markets, often bypassing the need for direct licensing by leveraging partner networks. Beginning around 2010, the company established bases in and alongside its German headquarters, funding growth through capital raises exceeding €500 million to target , the , and . This approach enabled Wirecard to process transactions in regions without its own acquiring capabilities, relying on third-party partners for compliance and local execution. Key acquisitions included Citi Prepaid Services in March 2017, which facilitated entry into the prepaid card market and formed Wirecard North America; the deal, initially announced in June 2016, expanded its offerings in electronic payments and . In , Wirecard acquired entities such as AllScore Payment Services in , enabling a foothold in with investments in digital payment licenses announced in November 2019. Operations extended to via the Hermes unit and through Moip, supporting claims of diversified revenue streams in high-volume markets like and remittances. Partnerships bolstered this growth, with a prominent example being the 2019 agreement with for up to €900 million in convertible bonds and collaboration to penetrate and , where SoftBank was to provide technological and market access support. Wirecard publicized hundreds of such alliances, including with and Insurance, positioning itself as a global platform; however, many proved superficial or promotional, lacking substantive integration or volume contribution. Subsequent probes exposed that much of the touted Asian partnerships, including escrow arrangements in the , were fabricated to inflate reported revenues, undermining the veracity of the expansion narrative.

Financial Trajectory and Market Position

Revenue Reporting and Valuation Surge

Wirecard's reported expanded rapidly during the mid-2010s, reflecting aggressive growth in payment processing volumes and international acquisitions. Consolidated stood at €601 million in 2014. This figure rose to €799.6 million in 2015, a 33% increase, supported by higher volumes processed through its , which reached €45.2 billion that year. The upward trajectory accelerated thereafter, with annual revenues climbing to €1.02 billion in 2016 (a 28% year-over-year gain), €1.53 billion in 2017 (50% growth), €2.06 billion in 2018 (35% increase), and €2.54 billion in . Much of this expansion was attributed to surging business in emerging markets, particularly , where Wirecard claimed partnerships with local entities drove transaction volumes exceeding €100 billion by 2018. In the first quarter of , quarterly revenue jumped 35% to €567 million, prompting the company to raise its full-year profit forecast amid optimism over digital payment trends. This revenue reporting underpinned a dramatic valuation surge, as investors viewed Wirecard as a high-growth leader. The company's ballooned from under €5 billion in mid-2015 to a peak of approximately €24 billion by early 2020, briefly exceeding that of and positioning Wirecard among Germany's top-valued firms. Between 2004 and 2018, reported revenues had grown roughly 50-fold, enhancing its appeal to institutional investors and contributing to stock price multiples that reflected expectations of continued double-digit expansion. The inclusion of such metrics in earnings releases and analyst coverage reinforced perceptions of operational , despite limited into third-party Asian accounts central to the growth narrative.

Inclusion in DAX Index and Investor Appeal

Wirecard AG was announced for inclusion in the index on September 5, 2018, by , with the change effective September 24, 2018, replacing AG and elevating the company from the to Germany's premier blue-chip benchmark comprising the 30 largest listed firms by and liquidity. This milestone validated Wirecard's reported trajectory as a high-growth , with its shares having surged to overtake Deutsche Bank's valuation in August 2018, reaching a exceeding €21 billion. Leading up to the inclusion, Wirecard's stock delivered strong returns, climbing 151.7% in 2017 and advancing another 35.6% through 2018, amid a broader rally that saw shares rise nearly fivefold over preceding years from lower bases. By 2018, the company's stood at approximately €24 billion, positioning it as one of Europe's most valued processors and fueling perceptions of it as a disruptor in the sector. Investor appeal stemmed from Wirecard's portrayal as a in payments amid the to cashless economies, with reported expansions into emerging markets via acquisitions and partnerships that promised scalable revenue from and services. The firm's narrative of technological innovation in secure online and mobile payments, coupled with consistent positive audit opinions from through 2019, attracted institutional funds seeking exposure to growth stocks comparable to peers like . This combination enabled Wirecard to raise capital readily at premium valuations, reinforcing a feedback loop of stock appreciation and market confidence prior to emerging scrutiny.

Emergence of Doubts and Investigations

Early Allegations of Irregularities

In June 2008, the German shareholder protection association SdK accused Wirecard of falsifying its 2007 accounting figures, prompting a special audit by that ultimately cleared the company of major irregularities. Shortly thereafter, German authorities prosecuted two individuals for failing to disclose Wirecard stock positions, highlighting early governance concerns but not directly validating fraud claims. More substantive doubts emerged in April 2015 when journalist launched the "House of Wirecard" investigative series on Alphaville, alleging a potential €250 million hole in the company's tied to dubious third-party acquiring (TPA) operations, particularly in where client volumes appeared inflated through fictitious merchants. Wirecard responded aggressively, issuing legal threats via law firm Schillings and hiring consultancy to defend its practices, while dismissing the reports as short-seller driven misinformation. Concurrently, U.S.-based research firm J Capital published a report questioning the scale of Wirecard's Asian business, estimating operations far smaller than reported and flagging inconsistencies in revenue from high-risk partnerships. By 2016, anonymous short-seller group Zatarra escalated claims of linked to Wirecard's international payment processing, prompting Germany's financial regulator BaFin to investigate the accusers for suspected rather than probing Wirecard's books directly. These early allegations, often centered on opaque overseas subsidiaries handling high-risk transactions for and adult , were repeatedly rebutted by Wirecard's management as competitive , with the company leveraging aggressive and legal tactics to maintain investor confidence amid persistent but unproven doubts. Internal red flags, such as system crashes traced to executive desks, were reportedly suppressed, foreshadowing deeper issues without triggering regulatory intervention at the time.

Media Scrutiny and Short Seller Reports

targeting Wirecard intensified in April 2015 when reporter launched the "House of Wirecard" series on FT , highlighting discrepancies in the company's Asian operations, including unverifiable client relationships and inflated revenue claims from third-party acquirers. The series drew on leaked documents, whistleblower tips, and on-the-ground checks in and the , revealing patterns of round-tripping transactions and fictitious partnerships that suggested systematic accounting manipulation. Wirecard dismissed these reports as baseless attacks coordinated by short sellers, threatening legal action against the FT and commissioning counter-investigations that portrayed critics as market manipulators. By January 2019, scrutiny escalated with articles alleging and at Wirecard's office, prompting a sharp share price drop and prompting Germany's BaFin regulator to impose a two-month ban on short selling Wirecard stock on February 18, 2019, citing threats to market confidence. BaFin's action, extended temporarily, shielded Wirecard from further downward pressure but drew criticism for prioritizing company stability over investor protection, as later analyses showed it delayed reckoning with underlying issues. Concurrently, German outlet published reports questioning Wirecard's escrow balances and audit reliability, amplifying doubts about the firm's €2 billion in claimed Asian cash holdings. Short seller reports paralleled media efforts, with J Capital Research issuing a November 2015 analysis recommending a short position, asserting Wirecard's Asian profits stemmed from non-existent operations and fabricated merchant acquiring. In 2016, under the pseudonym Zatarra Research & Investigations, Viceroy Research (led by Fraser Perring) released a report detailing alleged criminal activities, including fake contracts and trustee manipulations in the Philippines, which Wirecard refuted as speculative and funded by competitors. These disclosures, often sourced from forensic accounting and local verifications, faced aggressive pushback, including Munich prosecutors' 2019 probes into short sellers for alleged manipulation—later dropped—yet proved prescient as independent probes confirmed the critiques' validity post-collapse. Despite institutional resistance, such reports underscored short sellers' role in unmasking fraud where auditors and regulators faltered.

The Fraud Revelation and Collapse

EY Audit Failures and Missing Funds

(EY) acted as Wirecard AG's from 2009 through 2018, issuing unqualified opinions on the company's consolidated each year despite mounting evidence of irregularities in its Asian subsidiaries. These opinions certified that Wirecard's reported revenues and assets, including purported escrow balances exceeding €1 billion annually by the late , were fairly presented in accordance with . EY's audits overlooked systemic issues such as inflated third-party acquiring volumes and unverified cash positions, relying excessively on management representations and forged confirmations from entities in the Philippines and Dubai. A whistleblower alerted EY to potential fraud as early as 2016, citing fake contracts and revenue round-tripping, but the firm did not escalate these concerns or adjust its audit approach accordingly. Five different EY partners signed off on the unqualified opinions between 2009 and 2018, with rotations failing to introduce sufficient scrutiny amid repeated red flags from short-seller reports and media investigations. The critical breakdown occurred during the 2019 audit, when could not obtain independent confirmation for €1.9 billion in cash balances—about 25% of Wirecard's reported —that were claimed to be held in trustee accounts at two Philippine banks, including . On June 18, 2020, Wirecard delayed its 2019 annual report and Q1 2020 results, attributing the holdup to the banks' alleged refusal to provide , a claim deemed insufficient after multiple attempts to corroborate the assets. By June 25, 2020, Wirecard admitted the funds "likely do not exist," revealing them as fabricated to conceal losses from fictitious transactions and schemes involving executives and complicit local partners. This disclosure triggered the withdrawal of from 2015 onward, a market capitalization plunge of over €11 billion, and insolvency proceedings with €3.5 billion in liabilities. Post-collapse probes, including by and German authorities, confirmed 's procedural lapses, such as inadequate testing of internal controls over high-risk arrangements and failure to challenge management's explanations for discrepancies. In April 2023, Germany's Audit Oversight Body (APAS) imposed a two-year ban on auditing public-interest entities for new mandates, citing "repeated grave violations" of professional duties in the 2016–2018 audits, alongside a €500,000 fine on the firm and penalties up to €300,000 on individual auditors. maintained the fraud's sophistication evaded detection but acknowledged shortcomings in skepticism and evidence gathering. The episode underscored vulnerabilities in auditing complex structures, where reliance on opaque third parties masked manipulations totaling billions in overstated profits over a decade.

Executive Arrests and Insolvency Filing

On June 19, 2020, Wirecard's CEO resigned following the company's disclosure that auditors from could not verify the existence of €1.9 billion in cash balances reported in its Asian operations, prompting a suspension of trading in its shares. By June 22, 2020, Wirecard stated that these funds likely did not exist, escalating the crisis and leading to the dismissal of COO , who subsequently fled and remains at large. Markus Braun turned himself in to prosecutors on June 23, 2020, and was arrested on charges of aggravated , false accounting, and related to the fabricated balances, which prosecutors alleged were used to inflate Wirecard's financial position. Braun denied the accusations, claiming the missing funds were held in legitimate trust accounts, but investigations revealed evidence of systematic falsification spanning years. Two days later, on June 25, 2020, Wirecard filed for at the Munich District Court after failing to secure emergency funding, with liabilities exceeding €3.5 billion against verified assets of approximately € million. The filing marked one of Germany's largest corporate collapses, triggering claims processes and the appointment of Michael Jaffe as administrator to manage asset and investigations into preferential payments. Subsequent arrests included former executives such as Stephan von Erffa in July 2020 on related charges, underscoring the breadth of alleged internal complicity in the scheme. BaFin, Germany's financial regulator, faced criticism for prior leniency toward Wirecard despite whistleblower reports, though it cooperated in the criminal probes post-collapse.

Post-Collapse Proceedings

Criminal Trials and Outcomes

Former Wirecard CEO Markus Braun and former chief accounting officer Oliver Bellenhaus faced trial in Munich starting December 8, 2022, on charges including aggravated commercial fraud, breach of trust, and market manipulation related to the fabrication of €1.9 billion in fictitious Asian escrow accounts. Braun, who has denied wrongdoing, has remained in pretrial detention since his arrest on June 23, 2020, with the trial extended by the Munich Regional Court to December 2025 due to its complexity involving over 100 witnesses. In February 2025, prosecutors dropped certain charges against Braun, including those for falsifying 2015 annual results and 26 counts of market manipulation, narrowing the case but maintaining core fraud allegations that could yield up to 15 years imprisonment if convicted. The trial has highlighted alleged orchestration of a multiyear scheme to inflate Wirecard's balance sheet, with prosecutors claiming Braun led a "gang" that falsified financial statements to sustain the company's valuation. Bellenhaus, who turned state's witness, received a reduced sentence prospect in exchange for testimony detailing internal manipulations, though his final penalty awaits the main verdict. No convictions have been issued in the German proceedings as of October 2025, amid criticisms of prolonged proceedings in Germany's post-WWII largest fraud case. Internationally, courts delivered the scandal's first criminal convictions. In June 2023, Wirecard's former manager James Wardhana received 21 months' , and regional head of payments Chai Ai Lim got 13 months, both pleading guilty to conspiring to misappropriate over S$2 million in client funds via falsified transactions. In September 2025, former Wirecard subsidiary executives Paul O'Sullivan and Avinash Rajaratnam were convicted on charges of falsifying accounts; O'Sullivan on five counts and Rajaratnam on 13, tied to fraudulent invoices and transfers exceeding S$10 million, with sentencing pending. Fugitive former COO , accused of coordinating the Asian fake accounts and activities, remains at large as of 2025, subject to an international arrest warrant; Austrian authorities charged him with in 2021. Separately, operative Aviram Azari pleaded guilty in U.S. federal court in 2022 to wire and for critics on Wirecard's behalf, receiving a sentence of plus restitution. These outcomes underscore the scandal's global scope, though core German prosecutions against top leadership persist without resolution.

Civil Liabilities and Regulatory Reforms

In September 2024, the Regional Court ruled that former Wirecard CEO and two other executives—chief operating officer and accounting head Stephan von Erffa—must pay a total of €140 million in damages plus interest to the company's administrator, holding them liable for breaches of managerial duties that contributed to the €1.9 billion . The judgment, stemming from claims that the executives failed to ensure accurate financial reporting and internal controls, represents one of the largest civil penalties against corporate leaders in the scandal, though appeals are anticipated given the defendants' prior criminal convictions. Investors pursued civil claims against auditor EY, alleging negligence in certifying Wirecard's financial statements from 2014 to 2018, with demands exceeding €700 million in compensation for losses tied to the inflated valuations. In February 2025, the Bavarian Higher Regional Court rejected a test case under the pre-2024 Capital Markets Model Case Act, ruling that EY's audit opinions did not constitute direct "capital market information" attributable to the auditor rather than the company, forcing investors toward individual suits and marking a setback for collective recovery efforts. Separate U.S. class actions by shareholders were voluntarily dismissed in October 2025, limiting potential recoveries there. Claims against BaFin for supervisory failures were dismissed by a German administrative court in January 2022, which held that BaFin's mandate prioritizes systemic stability over individual investor protection, shielding it from liability despite criticisms of its delayed response to early signals. Some shareholders escalated related disputes to Germany's in October 2025, seeking clarification on loss quantification amid ongoing proceedings. The Wirecard collapse prompted the Finanzmarktintegritätsstärkungsgesetz (FISG), enacted in June 2021 and effective from July 1, 2021, which bolstered BaFin's enforcement tools by granting exclusive authority over financial audits and spot checks starting January 2022, alongside powers for direct account access, executive summons, and hiring forensic experts to detect irregularities preemptively. The mandates listed companies to maintain robust systems and , reintroduces oversight of material arrangements, and enables BaFin interventions in third-party banking services, including fines for non-compliance. BaFin underwent structural reorganization, including a strengthened presidential role in budgeting and management, creation of specialized Focus Units and a rapid-response in August 2021, and a ban on staff trading in financial instruments (with limited exceptions) to address conflicts exposed by Wirecard-related trades. Further, FISG introduced for from 2022 and discontinued prior fragmented models, consolidating BaFin's financial reporting supervision to prevent recurrence of unchecked . These measures, informed by ESMA's 2020 of German reporting practices, aimed to enhance early detection without expanding BaFin's headcount disproportionately.

Governance Failures and Systemic Lessons

Auditor and Internal Control Breakdowns

() served as Wirecard's from 2009 to 2019, issuing unqualified opinions on the company's despite persistent red flags in its Asian operations, where much of the fraudulent activity occurred. 's audits failed to adequately verify significant cash balances claimed in third-party accounts, particularly in the and , relying instead on forged bank confirmations and management representations without direct contact with the institutions involved. For instance, in verifying over €1 billion at in , accepted falsified documents rather than obtaining independent confirmations, contravening auditing standards that require substantive testing in high-risk areas. This oversight persisted even after internal probes like Project Ring in 2016-2017 uncovered evidence of manipulation, which Wirecard executives halted mid-investigation, yet proceeded to approve the 2017 accounts without resolution. The breakdowns escalated in 2020, when conducted a special of Wirecard's third-party acquirer (TPA) following KPMG's April questioning authenticity from Asian partners. Despite testing sample transactions—such as a €9.95 porn site subscription and $23.08 coin purchase in December 2018— overlooked that these were fabricated using prepaid cards controlled by Wirecard insiders, failing to perform deeper risk assessments. On June 18, 2020, disclosed its inability to confirm the existence of €1.9 billion in purported cash reserves, admitting the balances were likely fictitious due to an "elaborate and sophisticated " involving multiple parties, prompting its and Wirecard's filing a week later. Subsequent investigations by Germany's Auditor Oversight Body deemed 's work grossly negligent, citing failures to identify risks and adhere to professional standards, resulting in a two-year from auditing public interest entities in starting in 2023. Wirecard's internal controls exhibited systemic weaknesses that enabled the , including inadequate segregation of duties and overreliance on unverified TPA revenues, which accounted for a disproportionate share of reported profits but lacked substantive or corroboration. A McKinsey review commissioned by Wirecard highlighted a deficient framework, with poor IT security, processes, and structures that allowed executives to engage in round-tripping—funneling funds through subsidiaries and clients to inflate sales—without detection. German law under § 317 HGB mandated only a basic rather than robust internal audits, leaving the with limited independent access to information and no required , facilitating management override of controls. These lapses extended to subsidiaries in and , where fictitious accounts were created without on-site verification or reconciliation, exacerbating the opacity that external auditors like failed to penetrate. The interplay of these breakdowns underscored a reliance on over , with internal mechanisms unable to flag the €1.9 billion discrepancy until external pressure mounted. Philippine banks, for example, denied any relationship with Wirecard's claimed trustees, revealing fabricated partnerships that internal should have scrutinized. Post-collapse analyses, including KPMG's special , confirmed that uncooperative subsidiaries and absent proofs from 2016-2018 stemmed from foundational failures, not mere isolated errors.

Regulatory Lapses and Market Corrections

The German financial regulator BaFin exhibited significant lapses in overseeing Wirecard AG, despite repeated public allegations of irregularities dating back to 2015, including reports from the questioning the existence of third-party client cash balances in . BaFin prioritized defending Wirecard's reputation over rigorous investigation, authorizing probes into short sellers and journalists for alleged rather than scrutinizing the company's accounting practices, which delayed substantive regulatory action until after the fraud's exposure. These failures stemmed from structural weaknesses in BaFin's supervisory framework, including insufficient resources for on-site inspections and over-reliance on self-reported data from supervised entities, contributing to the undetected inflation of Wirecard's by approximately €1.9 billion in fictitious assets. In the market domain, Wirecard's share price, which had peaked at over €190 in September 2018 amid rapid growth narratives, underwent a precipitous correction as doubts intensified. On June 18, 2020, following the postponement of annual results and admission of unverifiable balances, shares plummeted more than 60% in a single trading session, erasing substantial . Trading was suspended multiple times by the amid volatility, and by June 25, 2020—after Wirecard disclosed the €1.9 billion shortfall and filed for insolvency—shares opened below €3, reflecting a near-98% decline from levels a week prior and a total evaporation of over €20 billion in since early 2020. This collapse triggered broader market repercussions, including heightened scrutiny of valuations and a temporary dip in confidence in equities, though no systemic ensued due to Wirecard's isolated position. Post-collapse, these lapses prompted targeted regulatory corrections in , culminating in the Finanzmarktintegritätsstärkungsgesetz (FISG) enacted on July 28, 2021, which expanded BaFin's enforcement powers, mandated enhanced , and introduced stricter penalties for false financial reporting to prevent recurrence. BaFin underwent internal restructuring, including bans on staff trading in supervised companies and increased on-site verification requirements, while a 2020 government overhaul aimed to bolster the agency's and resources amid of its prior deference to stakeholders. Courts later affirmed BaFin's non-liability for investor losses, attributing primary responsibility to company executives and auditors, though the scandal underscored the need for proactive, evidence-based supervision over reactive measures. These reforms have since led to more aggressive BaFin interventions in other cases, signaling a shift toward prioritizing over entity protection.

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