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Exhibit 

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DEPARTMENT OF THE TREASURY
Internal Revenue Service
Criminal Investigation

Memorandum of Interview
Investigation #:

Location:

Investigation Name:
Date:
Time:
Participant(s):

May 19, 2016
2:00pm-4:05pm
H.J. Von Der Goltz, Taxpayer
, Special Agent
, Special Agent
Kristy Greenberg, Assistant US Attorney,

On the above date, time and location, IRS-CI Special Agents
and
and
Assistant United States Attorney Kristy Greenberg met with H.J. Von Der Goltz (“Von Der Goltz”) and
his counsel
under the terms of a proffer agreement. AUSA Greenberg explained to Von
Der Goltz that lying would not be covered by the proffer agreement and that lying to federal agents is a
crime. Von Der Goltz reviewed, understood and signed the proffer agreement. Von Der Goltz provided
the following information:

1.

2.

3.

4.

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5.

6.

7.

8.

9.

10. In the late 70s, Von Der Goltz’s father met with a young German attorney in
Panama by the name of Jurgen Mossack (Mossack). His father was looking to
move money out of Panama and Mossack helped him arrange that. His father
began investing in Certificates of Deposits (CDs).
11. Von Der Goltz began doing business with Mossack in the mid to late ‘70s. At
the time Mossack was a 30 something young attorney. Von Der Goltz was one
of his first clients. Von Der Goltz said his parents wanted to have a place to
deposit their money and Mossack set up a company. Their relationship evolved
over time and new corporations were formed with Mossack for their investments
in Guatemala, Central America, Mexico and the United States.
12. Von Der Goltz recalled his first meeting with Mossack in the mid ‘70s. He went
to Mossack’s office in Panama and set up a company to move his father’s
money from Guatemala. The money represented his father’s earnings in the
company
. Mossack set up documents and the corporation to
transfer the money. Von Der Goltz thinks he may have either taken back
documents with him for his father to sign or mail the documents to his father.
13. Von Der Goltz met with Mossack several times over the years, their last
meeting took place in late 2009.
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14. Mossack invested his own money in
in funds #3 and
#4. His first investment was $300,000 and his second investment was
$500,000.
15. Von Der Goltz set up the offshore entity as a vehicle that he could use that gave
him advantages. He did not want to do anything illegal. The advantages were
that he could make investments in something and not appear as a person with
a lot of money. In addition, having an anonymous company shielded from
government intervention.
16. Mossack told Von Der Goltz that the company would be anonymous and
discreet. The Guatemalan government would not be able to see his assets. Von
Der Goltz said he wanted to be discreet because he risked being kidnapped.
17. In subsequent meetings with Mossack, Von Der Goltz suggested that he offered
accounting services in addition to offshore companies for his clients. Mossack
eventually established an accounting department in the ‘80s.
18. Von Der Goltz used Mossack’s accounting department for his
funds.
19. Von Der Goltz lived in Germany between 1961 and 1964, then 1970 through
1974. He came to the United States in 1984. Between 1982 and 1984, he
tested the waters by making 4 individual investments. In 1984, he started
and created 4 funds. He used his parents’
money to set up the company.
operated in Boston and the accounting was
done by Mossack in Panama. Mossack did the accounting work for the limited
partnerships that owned the funds. Initially Von Der Goltz would send financial
information to Mossack via mail.
20. Von Der Goltz said
had lots of foreign investors and he used Mossack to
set up foreign companies for each investor.
21. Mossack would prepare financial statements and send the reports to
which in turn issued K-1s to the investors to report the income.

,

22. Von Der Goltz grew concerned that the accounting work by Mossack was
getting sloppy and the Panama office was getting too big. He claimed to have
found errors in the financial reporting that were eventually corrected and that he
was not getting information on time. He was getting a bad feeling with the law
firm and felt they didn’t care about his stuff, they were busy doing other things.
23. About 10 or more years ago, Von Der Goltz decided to change firms to do his
accounting work and switched to a U.S. based accounting firm called
based in Boston. His engagement partner is a former
partner named Dick Gaffey.

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24. Von Der Goltz recommended many people from Guatemala, El Salvador and
Colombia to Mossack. He did not recommend American citizens because that
would be cheating on your taxes, it would not be correct to recommend
Americans. To his knowledge, Mossack did not ask him for any clients. There
were no referral fees paid.
25. Von Der Goltz set up about 100 corporations for
. Mossack also set up 4
corporations for his parents, not for Von Der Goltz personally. The entities are
called Union Properties, Goldbean, Emjo Investments and World Wide
Investment Services & Holdings. Mossack came up with the names for the
entities.
26. Von Der Goltz said Mossack has a roster of company names that are
established and a client can buy anyone of those entities. Mossack showed him
a list of about 20-30 names of companies and told him clients can choose any
name they want.
27. Von Der Goltz has used Mossack to set up entities. He did not remember what
documentation he brought to Mossack, he just bought the entities. He heard
from a friend that more thorough and detailed questions were asked when
setting up a company, including asking for the passport compared to 10 years
ago.
28. Von Der Goltz dealt with Ramses Owens (Owens), a high level employee at the
law firm that was assigned to take care of people that had companies. Owens
was a manager and attorney. Von Der Goltz claimed Owens was not being
treated properly by the law firm at the time. Mossack and Fonseca were the
senior partners and Owens wanted to become a partner in the law firm. Instead,
Mossack and Fonseca hired another partner, a financial guy who was either a
German or Suisse national. Von Der Goltz did not deal with him.
29. Owens was around 40 years old at the time and wanted to be a partner. Von
Der Goltz recommended he leave the law firm and set out on his own. Owens
had a classmate in law school who was a litigator. His name was
.
Owens and
got together and started their own firm about 7-8 years ago.
30. Von Der Goltz’s family switched law firms on his recommendation from
Mossack Fonseca to
. Von Der Goltz went to Mossak Fonseca
and told Jurgen Mossack he was leaving as a client. He then received a call
from Fonseca trying to persuade him not to leave the firm. Fonseca offered that
his son, who now worked at the firm, would be handling his accounts. Von Der
Goltz told him he was not happy and the attention was not great.
31. Fonseca called him a couple of times. They met in person about 8 times.
32. Von Der Goltz spoke to Jurgen Mossack and dealt regularly with him, not with
Ramon Fonseca. He speaks German to Mossack, Spanish with Fonseca.

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33. Von Der Goltz met with Owens a lot. The companies were moved from
Mossack Fonseca to
. Owens handled the move and Von Der
Goltz didn’t sign any paperwork. Owens prepared the paperwork for the
transfer. His companies were formed by Mossack Fonseca and transferred to
.
34. Von Der Goltz paid fees to the law firms that were taken out of the accounts.
The funds were managed in bank accounts in Panama. Mossack Fonseca held
the money in bank accounts owned by the entities.
35. Von Der Goltz said the entities have had no money in the accounts for the past
6 years. 2 of the entities are in the process of liquidation. The other 2 vehicles
hold the family assets, including Limited Partnerships in the U.S. and Ecuador.
36. Emjo and World Wide are entities that Von Der Goltz manages and provided
investment advice. Gaffey is also an advisor.
37. Owens prepares the corporate minutes of the entities.
38. Von Der Goltz would either call or email Mossack Fonseca or have Gaffey do
so to manage the entities.
39. Gaffey’s phone number is

.

40. Von Der Goltz still has contact with Owens, who is still handling the paperwork
for his family. They meet in person either in Miami or Panama. The last time
they met was 6 months ago in Panama.
41. Von Der Goltz filed the FBARs after his accountant Gaffey informed him he has
signature authority over the accounts. Von Der Goltz has signature authority
over an account, belonging to Emjo, at Bank Rothschild.
42. The assets of the Von Der Goltz family are structured in a foreign trust set up by
Mossack Fonseca with his mother as the beneficiary. 3 out of the 4 entities are
part of the trust, World Wide Investment Holdings, Emjo Investments Limited
and Goldbean, Inc.
provided a chart showing the Von Der
Goltz’s family structure.
43. Mossack Fonseca set up the entities and they suggested the structure,
including the countries used. The list Mossack Fonseca provided to clients had
names and jurisdictions for each company.
44. Von Der Goltz originally met with Jurgen Mossack at a small office, the law firm
is now located in the Arango-Orillac Building in Panama where they eventually
took over the entire building.
45. Von Der Goltz is not a U.S. Citizen but a green card holder.

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46. In 1984-86, Mossack knew Von Der Goltz lived in the United States.
47. Von Der Goltz liked Owens, who handled his day to day affairs when Mossack
became more detached and doing other things.
48. Originally Jurgen Mossack set up 1 or 2 entities, the others were set up by
Mossack Fonseca when Von Der Goltz’ business got bigger.
49. Their only business relationship was when Mossack invested personal money
in the
funds.
50. Jurgen Mossack did not handle the accounting of Von Der Goltz’ entities. The
law firm had an accounting department that handled his accounting needs. Von
Der Goltz spoke to them less than once a year. He could tell the quality and
professionalism of the people there was not good. He also thought they were
growing too big. He voiced his concerns to Mossack who told him mistakes
were going to be fixed.
51. Owens took clients that Von Der Goltz recommended. He now gets paid for
managing the entities, appointing officers and directors.

52. Von Der Goltz said there were inaccuracies in an article posted by a news
organization called La Prensa in Panama about his affairs. He claims that when
they refer to a $100 million US Investor that is grossly inflating the value of his
assets. In addition, he claimed the companies are owned by his mother who is
a Guatemalan citizen and has nothing to do with the United States.
53. In addition, the statements in the article about tax evasion are not true since
they did not know he filed FBARs.

I prepared this memorandum on May 23, 2016, after refreshing my memory from notes
made during and immediately after the interview with H.J. Von Der Goltz.

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