We have received and reviewed your email you sent us on 15 March 2016 which is
more relating to the business of Mossack Fonseca (the registered agent that we use)
than to our law firm. Our role as a law firm is to collect the due diligence information
and provide it to the registered agent who will take the decision whether to proceed
with the incorporation of the company or not. Post incorporation services as a law
firm is to assist the registered agent in ensuring that all regulations and laws
pertaining to this business are respected at all times and take necessary measures
when a client defaults in its obligations. We cannot provide responses to questions
that pertain to specific matters, as doing so would be a breach of our policies and
legal obligation to maintain client confidentiality. Although we cannot provide such
information to the media, we have always contributed information to the pertinent
authorities when it has been requested. We encourage you to comprehend the
essence of the industry dedicated to company formation, and understand how this
business has functioned historically versus the changes that have taken place
recently to ensure transparency into the identity of ultimate beneficial owners and
to improve safeguards within the international financial system in which Mossack
Fonseca and we, as a law firm, operate. Nonetheless, we respectfully take this
opportunity to provide additional insights into our business and its role, and to
briefly comment on some of the issues brought by you. Please consider the
following facts: We provide company incorporation and related administrative
services that are widely available and commonly used worldwide and especially in
the United Arab Emirates where for transmission purposes, offshore companies are
legally and widely used to open subsidiary in free zones or to own properties, thus
avoiding the application of sharia law in case of the death of the beneficial owners
amongst other reasons. Incorporating companies is the normal activity of lawyers
and agents around the world. Services such as company formations, registered
agent, and others are frequently used and provided in many worldwide jurisdictions,
including the United States and the United Kingdom. Moreover, it is legal and
common for companies to establish commercial entities in different jurisdictions for
a variety of legitimate reasons, including conducting crossborder mergers and
acquisitions, bankruptcies, estate planning, personal safety, and restructurings and
pooling of investment capital from investors residing in different jurisdictions who
want a neutral legal and tax regime that does not benefit or disadvantage any one
investor. Our services are regulated on multiple levels, often by overlapping
agencies, and we have a strong compliance record. Mossack Fonseca is regulated
by several different oversight and enforcement agencies, including the Banking
Superintendence of Panama and the Intendancy of Nonfinancial Regulated Services
Providers. We are also subject to regulatory oversight and enforcement in all of the
other jurisdictions where we incorporate companies. In addition, we have always
complied with international protocols such as the Financial Action Task Force (FATF)
and, more recently, the U.S. Foreign Account Tax Compliance Act (FATCA) to assure
as is reasonably possible, that the companies we incorporate are not being used for
tax evasion, moneylaundering, terrorist finance or other illicit purposes. The FATF, in
particular, praised Panama in its February 2016 plenary session, saying specifically

 that Panama has made “significant progress in improving its AML/CFT (antimoney
laundering and combating the financing of terrorism) regime.” The FATF,
subsequent to the plenary session, removed Panama from its gray list. We are
responsible members of the global financial and business community. We conduct
thorough due diligence on all new and prospective clients that often exceeds in
stringency the existing rules and standards to which we and others are bound. Many
of our clients come through established and reputable law firms and financial
institutions across the world, including the major correspondent banks, which are
also bound by international “know your client” (KYC) protocols and their own
domestic regulations and laws. If a new client/entity is not willing and/or able to
provide to us the appropriate documentation indicating who they are, and (when
applicable) from where their funds are derived, we will not work with that
client/entity. Our due diligence procedures require us to update the information that
we have on clients and to periodically verify that no negative results exist in regards
to the companies we incorporate and the individuals behind them. Again, the
documents you cite in your reporting show that we routinely resign from client
engagements when ongoing due diligence and updates to sanctions lists reveal that
a beneficial owner of a company for which we provide services is compromised. For
40 years Mossack Fonseca and our firm for nearly 20 years, have operated beyond
reproach in each our home country and in other jurisdictions where we have
operations. Our firms have never been accused or charged in connection with
criminal wrongdoing. However, we are legally and practically limited in our ability to
regulate the use of companies we incorporate or to which we provide other services.
We are not involved in managing our clients’ companies. Excluding the professional
fees we earn, we do not take possession or custody of clients’ money, or have
anything to do with any of the direct financial aspects related to operating their
businesses. We operate in jurisdictions with increasingly stringent financial and
legal controls. All of the jurisdictions where we have operations have made
significant strides in their efforts to comply with global protocols to prevent abuse of
their financial and corporate systems. This includes preventing money laundering,
combatting terrorist financing and preventing tax evasion. Most of the jurisdictions
have formal tax information exchange agreements with several countries that are
approved by the Organization for Economic Cooperation and Development (OECD).
Panama has nine formal OECDapproved tax information exchange agreements,
including with the United States and Canada, and 16 double taxation agreements
(which include provisions for information sharing between authorities) with
countries such as Ireland, Luxembourg and the Netherlands included in this group.
The OECD has recognized Panama for improving the government’s access to
information about beneficial ownership of entities incorporated in its jurisdiction as
well as for improving the sharing of such information with authorities in other
jurisdictions. To quote from the OECD’s most recent peer review of Panama: “The
2014 Supplementary Agreement noted the significant progress made by Panama in
expanding its exchange of information network since the 2010 Phase 1 Report,
which bought the number of signed EOI (exchange of information agreements)

 agreements from one to 25.” In addition, Panama, the British Virgin Islands (BVI),
and the United States have agreed to terms for financial institutions in their
jurisdictions to comply with the U.S. Treasury’s Foreign Account Tax Compliance Act
(FATCA). This act ensures that American citizens with accounts in these territories
declare and pay any taxes on income or investments earned in them that are due to
the U.S. Internal Revenue Service. We regret any misuse of our services and actively
take steps to prevent it. We regret any misuse of companies that we incorporate or
the services we provide and take steps wherever possible to uncover and stop such
use. If we detect suspicious activity or misconduct, we are quick to report it to the
authorities. Similarly, when authorities approach us with evidence of possible
misconduct, we always cooperate fully with them. We would like to further comment
as follows: (a) Tax Evasion and Avoidance: Our company does not advise clients on
the structuring of corporate vehicles and the use they may make of same; and we
likewise do not offer solutions whose purpose is to hide unlawful acts such as tax
evasion. Our clients request our services after being duly advised by qualified
professionals in their places of business. Moreover, it should be made clear that tax
avoidance and evasion are not the same thing. For example, a client can use the
structures provided by us for tax optimization of his/her estate, such as taking
advantage of provisions in treaties for avoiding international double taxation. Such
behavior is perfectly legal. (b) Due Diligence on Clients: To begin with, most of our
clientele is comprised of professional clients, such as international financial
institutions as well as prominent law and accounting firms, who act as
intermediaries and most of them are regulated in the jurisdiction of their business.
In the case of Panama, Law 2 of 2011 allows the information and documentation on
the final beneficiary to be held in custody by the professional regulated client.
Likewise, BVI’s 2008 AML Act allowed the information regarding the final beneficiary
to be held in custody by such regulated client until December 2015. Due diligence
procedures were carried out in accordance with the laws in place at the time the
companies and cases you made reference to were incorporated and in existence.
Also, be aware that a significant percentage of our clients are banking institutions,
lawyers, and accountants who are also obliged to perform due diligence on their
clients in accordance with the KYC and AML regulations to which they are subject. In
addition to the above, we do have some enduser clients—we have never denied this
fact, and in these cases, as in all others, we have complied with all applicable due
diligence procedures. (c) Politically Exposed Persons (PEPs): We have duly
established policies and procedures to identify and handle those cases where
individuals either qualify as PEPs or are related to them. As per our Risk Based
Approach, PEPs are considered to be high risk individuals. Hence, enhanced due
diligence procedures apply in these cases. Also, periodic followup is conducted to
assure that no negative results are found. Lastly, you should bear in mind that
according to international KYC policies, PEPs do not have to be rejected just for
being so; it is just a matter of proper risk analysis and administration. (d) Sanctions
Lists and Convicted Criminals: Our company does not foster or promote unlawful
acts. The companies you cite in your email (except for Market Emerging

 Development Export which is, by the way, a company which owns a personal real
estate property in Dubai) show specific instances demonstrating that once these
types of situations are identified, we routinely discontinue the provision of our
services. The Service Provision Agreements signed with our clients impose on them
the obligation to notify us as soon as they have knowledge of a client of theirs
having been either convicted or listed by a sanctioning body. Likewise, we have our
own procedures in place to identify such individuals, to the extent it is reasonably
possible. Bear in mind that we have an obligation to follow an orderly administrative
process when resigning from client engagements. The time it takes for us to resign
as registered agent and as a law firm from the involved companies varies
depending on our internal procedures and the regulations of the respective country
or jurisdiction. Also, sometimes the authorities require the registered agent not to
file any resignation in order to prevent obstructing their investigation. In any case,
our company always complies with the filing of the respective reports according to
the governing laws of the specific country or jurisdiction. Notwithstanding the
above, we would like to take this opportunity to clarify that we have never
knowingly allowed the use of our companies by individuals having any relationship
with North Korea, Zimbabwe, Syria, and other countries mentioned by you that
might have been considered as a threat to any other country’s national security or
that have been listed by a sanctioning body. If for some reason, unbeknownst to us,
some company formed by us ended up in the hands of people having such relations
for whatever criminal or unlawful purpose, we strongly condemned that situation
and took and will continue taking any measures that are reasonably available to us.
(e) Provision of Company Secretarial Services: Company Secretarial Services are
legal services that allow a professional company provider to act on behalf of a
company that is owned by third parties. Company Secretarial Services are not used
to hide the identity of the real owners of the company as for instance, a director is
not in its nature the owner of the company. These services often include
directorships and facilitate document filings before the authorities and registry of a
company’s jurisdiction. For example, a secretary might help a company register for
taxes and file for licenses, manage patents and trademarks, tax returns and other
documentation to be handled and filed. Company Secretarial Services are provided
by many firms to professional clients and investors all over the world. The same
director or company secretary can act on behalf of many different companies in
different jurisdictions. That is widely accepted and perfectly legal, especially in
cases where the purpose of a company is to be a holding company or own
immovable or movable property. The fact that many companies have the same
directors and/or address does not mean that such companies are connected in any
way, as is commonly assumed. In the case of professional service providers, usually
a director or company/corporate secretary has no economic interest or commercial
link to the company’s activity and he/she does not endorse, participate or assist in
the commercial or passive roles of a company in any way. Following the preestablished guidelines, the secretary appoints agents and attorneys that then carry
out the administration of the company. Our company is not the only one providing

 this type of service. You can take a look at UK law firms’ websites and you will find
more information about the provision of this service. Below please find a small
sample of companies that offer company secretarial services:
• Elemental CoSec, London, UK
• CT Corporation, New York, USA
• The Corporation Service Company, Delaware, USA
• National Registered Agents, Inc., USA
• InCorp Services, Inc., Nevada, USA
• My LLC, California, USA
• Northwest Registered Agent LLC, WA, USA
• Swift Formations, UK
• DeMontford Bell, UK
• CG Incorporations, UK
• TCS Group International, UK
• MILS Corporation Ltd., UK
• HGN Limited, UK
• A & P Intertrust Corporation, Canada

Finally, we will not make any reference to the statistics and other “factual”
information about numbers since they are far from being accurate. You may
consider this document as our response to your email. However, it should not be
considered as a validation of the information contained therein, and especially to
the method by which said information was obtained. From the way you present your
“facts”, it appears that you have had unauthorized access to proprietary documents
and information taken from either the registered agent or our law firm and have
presented and interpreted them out of context. We trust that you are fully aware
that using information/documentation unlawfully obtained is a crime, and we will
not hesitate to pursue all available criminal and civil remedies.
Sincerely,
Helene Mathieu Legal Consultants
T: +971 (4) 3644333 │ F: +971 (4) 3644343

 E: info@hmlc.ae
Office 2103, Ontario Tower, Al A’amal Street, Business Bay, Dubai, United Arab
Emirates P.O. Box 28845