See Who Does Exploit Offshore Tax Havens

Offshore investment is among the murkiest sectors of the financial world. That’s by design — keeping money offshore can help shield money from tax authorities, obscure its origin and conceal the genuine owners. There are many legitimate reasons for opening an offshore banks account. Wealthy people do it to better manage their investment portfolios or protect their assets. Offshore accounts can also help the rich pay less tax — legally.

However, offshore accounts are also the lynchpin in many illegal tax avoidance schemes. Owners go to great lengths to conceal the existence of these accounts from their home governments, and they are often helped by lax disclosure rules in offshore tax havens.

Investors caught trying to hide their accounts can face steep penalties. More here from CNN.

US corporations have $1.4tn hidden in tax havens, claims Oxfam report

Charity analysis of the 50 biggest US businesses claims Apple have $181bn held offshore, while General Electric has $119bn and Microsoft $108bn

Guardian: US corporate giants such as Apple, Walmart and General Electric have stashed $1.4tn (£980bn) in tax havens, despite receiving trillions of dollars in taxpayer support, according to a report by anti-poverty charity Oxfam.

The sum, larger than the economic output of Russia, South Korea and Spain, is held in an “opaque and secretive network” of 1,608 subsidiaries based offshore, said Oxfam.

The charity’s analysis of the financial affairs of the 50 biggest US corporations comes amid intense scrutiny of tax havens following the leak of the Panama Papers.

And the charity said its report, entitled Broken at the Top was a further illustration of “massive systematic abuse” of the global tax system.

Technology giant Apple, the world’s second biggest company, topped Oxfam’s league table, with some $181bn held offshore in three subsidiaries.

Boston-based conglomerate General Electric, which Oxfam said has received $28bn in taxpayer backing, was second with $119bn stored in 118 tax haven subsidiaries.

Computing firm Microsoft was third with $108bn, in a top 10 that also included pharmaceuticals giant Pfizer, Google’s parent company Alphabet and Exxon Mobil, the largest oil company not owned by an oil-producing state.

Oxfam contrasted the $1.4tn held offshore with the $1tn paid in tax by the top 50 US firms between 2008 and 2014.

It pointed out that the companies had also enjoyed a combined $11.2tn in federal loans, bailouts and loan guarantees during the same period.

Overall, the use of tax havens allowed the US firms to reduce their effective tax rate on $4tn of profits from the US headline rate of 35% to an average of 26.5% between 2008 and 2014.

The charity said this had helped firms spend billions on an “army” of lobbyists calling for greater state support in the form of loans, bailouts and guarantees, funded by taxpayers.

The top 50 US firms spent $2.6bn between 2008 and 2014 on lobbying the US government, Oxfam said.

“For every $1 spent on lobbying, these 50 companies collectively received $130 in tax breaks and more than $4,000 in federal loans, loan guarantees and bailouts,” said Oxfam.

Robbie Silverman, senior tax adviser at Oxfam said: “Yet again we have evidence of a massive systematic abuse of the global tax system.

“We can’t go on with a situation where the rich and powerful are not paying their fair share of tax, leaving the rest of us to foot the bill.

“Governments across the globe must come together now to end the era of tax havens.”

Oxfam estimates that tax avoidance by US corporations costs the world’s largest economy some $111bn a year, but said it was also fuelling the global wealth divide by draining $100bn from the poorest countries.

“Tax dodging practised by corporations and enabled by federal policymakers contributes to dangerous inequality that is undermining our social fabric and hindering economic growth,” the report said.

Oxfam also singled out British overseas territories such as Bermuda for their popularity with US firms seeking to slash their tax bill by “profit-shifting”.

In 2012, said Oxfam, US firms reported $80bn of profit in Bermuda, more than their combined reported profits in Japan, China, Germany and France, four of the world’s five largest economies.

The charity called on the US government to pass the Stop Tax Haven Abuse Act, including a requirement for firms to report their tax contribution on a country-by-country basis, there is only one caution when doing this though and that is to not be mistaken that a country is a tax haven when in fact it isn’t, for example many people refer to Andorra as the tax haven of Andorra however Andorra is not actually a tax haven, one way to be sure whether a country is a legally classed tax haven is refer to the FATF blacklist, it lists every country that is recognised by government as an actual tax haven.

Country-by-country reporting has been recommended by a host of non-governmental organisations and charities to prevent companies from artificially shifting their income out of the poorest countries.

Mossack Fonseca Offices Raided, and Spies too?

Panama raids offices of Mossack Fonseca law firm

Reuters:Panama’s attorney general late on Tuesday raided the offices of the Mossack Fonseca law firm to search for any evidence of illegal activities, authorities said in a statement.

The Panama-based law firm is at the center of the “Panama Papers” leaks scandal that has embarrassed several world leaders and shone a spotlight on the shadowy world of offshore companies.

The national police, in an earlier statement, said they were searching for documentation that “would establish the possible use of the firm for illicit activities.” The firm has been accused of tax evasion and fraud.

Police offers and patrol cars began gathering around the company’s building in the afternoon under the command of prosecutor Javier Caravallo, who specializes in organized crime and money laundering.

Mossack Fonseca, which specializes in setting up offshore companies, did not respond to requests for comment on Tuesday.

Earlier, founding partner Ramon Fonseca said the company had broken no laws, destroyed no documents, and all its operations were legal.

Governments across the world have begun investigating possible financial wrongdoing by the rich and powerful after the leak of more than 11.5 million documents, dubbed the Panama Papers, from the law firm that span four decades.

The papers have revealed financial arrangements of prominent figures, including friends of Russian President Vladimir Putin, relatives of the prime ministers of Britain and Pakistan and of China’s President Xi Jinping, and the president of Ukraine.

There are more details. From Joseph FITSANAKIS of IntelNews in part:

The Süddeutsche Zeitung said on Monday that senior intelligence officials from Rwanda and Colombia are listed as Mossack Fonseca customers, but did not report the names of the individuals. It did, however, single out the late Sheikh Kamal Adham, who was director of Saudi Arabia’s General Intelligence Directorate in the 1960s and 1970s. During his 14-year directorship of the GID, the agency became a leading intermediary between the CIA and Arab intelligence agencies, notably those of Egypt and Iraq. Sheikh Adham was also a personal friend of CIA Director George Bush, who was later elected US president.

According to the Süddeutsche Zeitung, Sheikh Adham is one of many individuals with close CIA links whose names appear in the Panama Papers. Another is Farhad Azima, an Iranian-born American businessman, who is rumored to have leased aircraft to the CIA in the 1980s. The American intelligence agency is said to have used the aircraft, which belonged to Azima’s Kansas City, Missouri-headquartered Global International Airways, to transport weapons to Iran. The secret transfers were part of what later became known as the Iran-Contra scandal, in which US officials secretly sold weapons to Iran in return for the release of American hostages held by Iran-linked groups in the Middle East. The funds acquired from these weapons sales were then secretly funneled to the Contras, a medley of anti-communist paramilitary groups fighting the Sandinista-led government of Nicaragua.

 

Panama Papers Snares Another Clinton Tax Haven?

First the Panama Papers revealed the Podesta Group. John and Tony Podesta, the founders have connections to a Russian bank which is blacklisted. John Podesta is the architect of the Hillary presidential campaign.

  John Podesta, a real operative in the White House for years.

John Podesta was an Obama advisor and upon leaving that role, he said his greatest regret not revealing more about UFO’s. Sheesh…

The mailman must be real busy and overworked at the address below.

This Delaware Address Is Home to 200,000 Shell Companies—Including Hillary Clinton’s

FreeBeacon: The address “1209 North Orange Street” in Wilmington, Del., has become known in recent years as the epicenter of U.S. corporate secrecy. The squat, split-level building is the official address of over 285,000 companies, many of which are looking to take advantage of Delaware’s Panama-like secrecy rules, tax incentives, and business-friendly case law.

In the wake of the recent “Panama Papers” scandal, this unassuming brick office has received renewed scrutiny from the Washington Post, the New York Times, the Telegraph, and advocates for corporate tax reform.

But one of its tenants may come as a surprise—a company owned by Democratic presidential frontrunner Hillary Clinton.

Hillary and Bill Clinton quietly set up two shell companies listed at “1209 North Orange Street” in 2008 and 2013, the Washington Free Beacon has found. The names of the companies, but not their location, were first made public in tax filings released by Hillary Clinton last year.

According to records, one of the Clintons’ “1209 North Orange Street” companies is WJC, LLC, which was set up by Bill Clinton in 2008 as a pass-through for his consulting fees.

Another company at the same location, ZFS Holdings, LLC, was set up in February 2013, one week after Hillary Clinton left the State Department. Hillary Clinton received $5.5 million from her book publisher, Simon & Schuster, through the company.

The “1209 North Orange Street” building is the headquarters for the Corporation Trust Company. The firm acts as a registered agent for thousands of corporations that are not actually located in Delaware, including the Clintons’ companies.

Anti-secrecy advocates say the building is prime evidence that Delaware has become a corporate haven that’s comparable to more well-known, offshore locales.

“If you imagined a building with 1,000 corporations in it, you’d imagine a building like the Empire State building,” said Richard Phillips, a senior policy analyst with Citizens for Tax Justice. “But apparently 285,000 companies claim [1209 North Orange Street] is their address.”

“What this shows is this is not really the address of companies that are doing real business. This is the address of a lot of companies that are just shell companies,” he added. “In this case, it doesn’t even look like they have mailboxes. They just claim that address as the places they’re doing business, even though they’re not doing business there.”

Similar registered agents have come under scrutiny in recent years. While campaigning in 2008, President Obama slammed the “Ugland House,” a five-story building in the Cayman Islands that is reportedly home to over 18,000 companies.

“That’s either the biggest building in the world, or the biggest tax scam on record,” said Obama.

The Clinton campaign declined to comment on why the Clintons, who live in New York and have no evident residential ties to Delaware, set up companies in the state. But the presidential candidate isn’t alone. Experts say Delaware is the most popular place to register a company in the United States, due in part to its established system of business case law and tax incentives for intellectual property and real estate holdings.

One of the biggest draws may be the state’s lack of disclosure requirements—businesses can be created completely anonymously, allowing the owners to avoid public detection and even hide income from U.S. authorities.

According to advocates for corporate tax reform, Delaware’s laws rival well-known secrecy havens like the Cayman Islands and Panama.

“General secrecy laws and the ability of these corporations to hide the identities of those who own it, that’s what makes [Delaware] an onshore tax haven, and that’s what makes it just as bad as the Cayman Islands,” said Phillips.

Hillary Clinton has promised to crack down on tax havens on the campaign trail. Referring to the Panama Papers last Wednesday, Clinton condemned “outrageous tax havens and loopholes that super-rich people across the world are exploiting in Panama and elsewhere.”

The Clinton Foundation also has three shell companies in Delaware, according to its amended financial disclosures released last year.

One is the Acceso Fund, LLC, which was registered by the Corporation Trust Company at 1209 North Orange Street in 2009. The Clinton Foundation has used the company to channel money to its Colombia-based private equity fund, Fondo Acceso.

The private equity fund, which is run out of the Clinton Foundation’s Bogota office, has invested in telecom and food processing companies in Colombia, the Free Beacon reported last November.

Another Clinton Foundation company, Acceso Worldwide Fund, Inc., was registered in 2013 by the Corporation Services Company, located in Wilmington, Delaware.

A third company, the Haiti Development Fund, LLC, was registered in 2010 by National Corporate Research, Ltd, located in Dover.

In Delaware, limited liability companies such as WJC, LLC, and ZFS, LLC, are not required to file annual statements disclosing their directors or owners. The Clintons also registered both companies in New York after they were established.

There is no evidence the Clintons are using the entities for any nefarious purposes, and it is perfectly legal for non-residents to set up corporations in Delaware. But even if corporations stay within the law, critics say Delaware shell companies can sometimes be used to legally circumvent taxes in other states.

According to a report published last December by the Institute on Taxation and Economic Policy, Delaware’s popularity as a hub for shell companies is “responsible for the loss of billions of dollars in revenue in other U.S. states.”

“It’s legal tax avoidance,” said Phillips. “We would say it’s immoral, or not the best thing for the country.”

Anti-secrecy advocates also say the laws make it easier for criminals to evade federal taxes or finance terrorism, all under the radar of the public and U.S. authorities.

“Some anonymous shell companies have financed terrorism and supported corruption and human trafficking and Delaware is a traditional hub for creating these fake companies,” said Andrew Hanauer, campaign director at the Jubilee USA Network.

Jubilee USA Network and other groups have been advocating for legislative reform. Sen. Sheldon Whitehouse (D., R.I.), Rep. Peter King (R., N.Y.), and Rep. Carolyn Maloney recently put forward legislation that would force U.S. companies to disclose their actual owners.

The Clinton campaign did comment on whether Hillary Clinton supports the legislation. The campaign also did not comment on whether she or Bill Clinton have any other companies registered in Delaware.

But the concerns over corporate secrecy and tax avoidance have trickled into the Democratic presidential race, with Sen. Bernie Sanders incorporating it into his stump speeches. Clinton has also railed against tax havens on the trail and vowed to take action.

“Some of you may have just heard about these disclosures about outrageous tax havens and loopholes that super-rich people across the world are exploiting in Panama and elsewhere,” said Clinton during a campaign event last Wednesday.

“Now some of this behavior is clearly against the law, and anyone who violates the law anywhere should be held accountable,” she added. “But it’s also scandalous how much is actually legal.”

It Continues, Panama Papers Proves the Elite’s Dark World

Panama Papers: How German Biz May Have Empowered Venezuela to Forge Passports for Hezbollah

The massive legal firm data leak known as the Panama Papers have exposed business dealings that allowed the government of Venezuela under Hugo Chávez to use Cuban money to purchase advanced passport technology from Germany. Venezuela would later be accused of falsifying passports for Hezbollah terrorists.

Breitbart: The revelation surfaced as part of the 11.5 million documents leaked to the German newspaper Süddeutsche Zeitung from the Panamanian law firm Mossack Fonseca, later handed over for aid in analysis to a number of journalistic outlets, most prominently the International Consortium of Investigative Journalists (ICIJ). The ICIJ has set up a website to help parse the information in these documents, and one website specifically for the revelations surfacing on the government of Venezuela.

It is there that the ICIJ has revealed in a Spanish-language report that Mossack Fonseca helped the governments of Cuba and Venezuela establish a shell corporation to engage a German technology company to buy state-of-the-art passport printing technology.

According to the report, late dictator Hugo Chávez established a project in 2005 to update the Venezuelan passport system, which would first require identifying a seller of the appropriate technology to approach. Venezuela, then as now, enjoying patronage from the government in Havana, would use Cuban money to buy the new technology. This made the purchase much more difficult, as few respectable corporations would feel comfortable doing business with the communist dictatorship.

Venezuela found a vendor: the German company Bundesdrukerei. In an email surfacing as part of the Panama Papers, a representative of that corporation makes clear: “the fundamental reason why this company does not want to sell to Cuba and Venezuela directly is because of the reputational issue. They fear their competition will create adversarial propaganda against them for selling to totalitarian governments.”

Mossack Fonseca then stepped in to design an elaborate currency exchange system to disassociate Cuba with the funding, a system known in Latin America as a “financial bicycle,” because the money is peddled through so many different currencies as to render its origins barely recognizable. Many corporations use this system to generate income, switching into cheaper currencies with higher interest rates and waiting for the money to grow before returning the money to its original form. In this case, Mossack Fonseca cycled the money through the currencies of at least four countries in addition to Cuba and Venezuela, then put the money in a shell corporation: Billingsley Global Corp. Billingsley bought the technology after receiving an influx of 64 million euros.

Venezuela got its passports, and Cuba retained the right to access and control the software that creates the passports.

Like most of the known revelations in the Pentagon Papers, this exchange is of questionable legality at worst, completely acceptable for a global banking lawyer at best. What makes this particular discovery notable is the years of evidence mounting that Venezuela and Cuba used the Venezuelan passport system to fabricate false documents for Hezbollah terrorists.

A 2015 report estimated that the government of Venezuela has issued over 500 passports to members of the Shiite terrorist group Hezbollah. The terrorists would then use the passports to travel more freely through the Western Hemisphere, as their real identities and nationalities would trigger more thorough investigations into their backgrounds. Spanish reporter Emili Blasco found evidence that current Venezuelan strongman Nicolás Maduro met with Hezbollah leader Hassan Nasrallah in 2007 to discuss an agreement for distributing the fake passports.

A former diplomat in Venezuela’s Baghdad embassy, Misael López Soto, testified before fleeing the embassy in a video posted online that he was forced to flee after receiving multiple death threats for attempting to notify Caracas that his embassy was distributing dozens of falsified birth certificates, passports, and other government documents to known members of Hezbollah. The terrorists would pay between $5000 and S15000 for each document.

A report in February at the UK-based Asharq Al-Awsat cited a former Venezuelan diplomat as alleging that a “Cuban company” had made an agreement with Venezuela to issue the contracts. No details were provided, but such an agreement fits the Panama Papers description of the incident.

The governments of either nation have yet to remark on this particular allegation.

****

The Dark Art World, remember the movie the Monuments Men? Seems the art that was looted but some was never recovered or was it?

This is a long yet quite detailed summary of the art world where owner’s names are never mentioned or buried in layers of obscure companies all performed by the Mossack Fonseca law firm. Below are but a few paragraphs. To read the whole summary, go here.

  • Panama Papers provides unprecedented look at connection between international art trade and offshore secrecy
  • Billionaire art dealers use offshore company to shield painting allegedly looted by Nazis
  • Identity revealed of the man secretly behind the 20th century’s most important modern art auction

ICIJ in part: When high-dollar art changes hands, it often lands in a free trade zone known as a freeport. As long as art is housed in the freeport, owners pay no import taxes or duties. Critics worry the freeport system can be used to dodge tax or launder money since precise inventories and transactions are not tracked. According to the international professional services firm Deloitte, 42 percent of art collectors it surveyed said they would likely use a freeport. The oldest freeport, with the most art, is in Geneva. Its complex of storage facilities is said to contain enough treasure to rival any museum in the world.

The Nahmads began as a banking dynasty of Sephardic Jews from Aleppo, Syria. In 1948, Hillel Nahmad relocated his wife and eight children to Beirut.

Three of his sons — Giuseppe, David and Ezra — eventually moved to Milan and, by the early 1960s, had become active art dealers. Giuseppe, the patriarch of the family, had a taste for expensive sports cars and, according to his brother David, once dated Rita Hayworth. He also pioneered treating the art business like a stock market, buying and holding paintings until exactly the right time to sell to maximize profit.

He died in 2012. David assumed the mantel of family leader. He and his older brother Ezra both named their sons Hillel after their grandfather. The two sons both go by Helly. Together the four continue the family business.

The two surviving brothers are worth a combined $3.3 billion, according to Forbes. They live in Monaco, among other locales. In addition to currency trading and art dealing, David Nahmad is also a championship backgammon player. Each son has a namesake gallery. Ezra’s son has the Helly Nahmad Gallery in London and David’s offspring, an identically named one in New York.

The Mossack Fonseca records indicate the Nahmads were early adopters of the benefits of offshoring art.

articles/05Art/160407-art-06.jpgFine art dealer and billionaire David Nahmad. Photo: AP Photo / Lionel Cironneau

Giuseppe Nahmad registered International Art Center S.A. in 1995 through the Swiss bank UBS and the Geneva office of Mossack Fonseca. It may have existed in another form prior to that date. A document in the Mossack Fonseca files mentions International Art Center acquiring the pastel “Danseuses” by Edgar Degas in October 1989.

 

 

 

More Hillary Collusion Surfaces

This is the time we need the NSA to produce some meta data on cell phones and honestly the actual conversations.

Panama Papers Scandal Hits the Clinton Campaign

Hillary Clinton’s campaign chairman, John Podesta, has ties to Russia’s Sberbank, which has been implicated in the “Panama Papers” tax-avoidance scandal.

A report parsing through what is currently known to be included in the Mossack Fonseca data leak about Russian corporations found that Podesta’s eponymous Podesta Group lobbying firm took on Sberbank as a client only a month ago. John Podesta’s brother Anthony, who bundles campaign donations for Clinton, is listed as the lobbyist for the Sberbank account.

According to the Washington Free Beacon reportthe Podesta Group’s lobbying registration form lists three other entities affiliated with Sberbank: “Cayman Islands-based Troika Dialog Group Limited, Cyprus-based SBGB Cyprus Limited, and Luxembourg-based SB International.”

Both Sberbank and the Troika Dialog Group are linked with companies used by members of Russian president Vladimir Putin’s inner circle to shift government funds into personal offshore accounts, according to allegations leveled by the International Consortium of Investigative Journalists (ICIJ), the group managing the Panama Papers story – for example, leaked documents from Panamanian law firm Mossack Fonseca that showed Troika Dialog secretly signing away interest in a Russian truck manufacturer to an offshore company called Avto Holdings, owned by close Putin friend Sergei Roldugin.

This, and many similar transactions, are characterized by the Panama Papers journalists as examples of how “offshore companies affiliated with Putin’s friend had privileged rights to control large stakes in strategic Russian enterprises, to receive dividends, and to buy these stakes for laughable sums.” A must read of the rest here from Breitbart.

*****

Hold on there is more……

Clinton Foundation Donor Ensnared in Kickbacks Probe

FreeBeacon: A major Clinton Foundation donor company that has been granted millions in U.S. federal loans has been linked to a corruption probe in Pakistan, according to reports.

The Abraaj Group, a Middle Eastern investment fund that contributed between $500,000 and $1 million to the Clinton Foundation, has not been charged in the case, but its name has surfaced in Pakistani media reports. Authorities in Sindh province have accused a prominent government official of providing illegal favors to K-Electric, a power company owned and managed by the Abraaj Group since 2009.

Former Pakistani oil minister Dr. Asim Hussain was arrested last year amid allegations that he helped harbor terrorists in a string of hospitals he owned and doled out illegal contracts to companies, including K-Electric. Both Hussain and K-Electric have denied the allegations.

The investigation has not impacted the U.S. government’s ongoing partnership with the Abraaj Group, which dates back to at least 2012. That year, the Overseas Private Investment Corporation—a federal agency that dispenses corporate loans under the guidance of the U.S. State Department—selected the Abraaj Group to manage its $150 million Middle East investment fund.

Two weeks later, the Abraaj Group co-sponsored the Clinton Global Initiative’s annual meeting.

Last October, the Overseas Private Investment Corporation again pledged up to $250 million to help fund the Abraaj Group’s K-Electric operations. The announcement came less than a month after the Sindh Rangers, a Pakistani law enforcement agency, reportedly issued a 12-page report accusing Hussain of passing illegal favors to K-Electric.

According to the Sindh Rangers, Hussain was “involved in various acts of corruption, corrupt practices and misuse of authority as public office holder.” The paramilitary group claimed he also embezzled money that was “subsequently used in terror financing and funding target killers.”

The Rangers’ report claimed that “Dr Asim [Hussain] gave favours and illegal gas connections to KESC [K-Electric], which was owned by Abraaj Group with links to [former Pakistani president] Asif Zardari and [Zardari’s sister] Faryal Talpur to the tune of Rs100 billion,” according to a summary by the International News.

A spokesperson for the Overseas Private Investment Corporation told the Washington Free Beacon that its board approved the project with the Abraaj Group and K-Electric before news of the investigation emerged.

“We are aware of the situation and are following up with the borrower,” OPIC press secretary Sandra Niedzwiecki said.

A spokesperson for the Abraaj Group referred the Free Beacon to an Oct. 2, 2015 statement on the K-Electric website, which strongly denied the charges.

“K-Electric has categorically refuted and denied the false and defamatory allegations that have been referenced in a few publications regarding undue favors taken by the company and/or the provision of illegal gas connections and supply,” the statement said. “K-Electric is a publicly listed company and operates in strict compliance with national laws and regulations and adheres to the highest standards of ethics and corporate governance.”

A spokesperson for the Abraaj Group said K-Electric “has not been contacted by any government or judicial agencies on this matter.”

Dr. Asim Hussain has pleaded not guilty to separate charges of aiding terrorists and corruption.

Hussain appeared in Karachi’s Accountability Court on Thursday, where he was expected to be indicted, according to reports. However, jail authorities brought him to the courthouse over an hour late, and the hearing was rescheduled for a later date.

Last month, Pakistan’s anti-corruption agency, the National Accountability Bureau, filed a corruption reference against Hussain. “In this case, the accused persons were alleged to have illegally fraudulently and with the connivance of officials of OGDCL [Oil and Gas Development Company, Limited] and SSGCL [Sui Southern Gas Company, Limited] awarded gas contracts,” the bureau’s executive board wrote in a March 2 statement.

K-Electric is not the only part of the Abraaj Group entangled in a corruption case. The CEO of PetroTiger, a Colombian petroleum company in the Abraaj Group’s portfolio, pleaded guilty to bribing a foreign official last June. He was sentenced to probation. PetroTiger reportedly cooperated in the case and the company was not charged.