Thursday, May 2, 2013

Cyprus/Romania – Majority of Bank of Cyprus’s deposits in Romania transferred to Marfin Bank (Romania) S.A., but BOC branch in Romania reopens to serve other accounts; Leaked report to CBC examines suspected criminal collusion between Bank of Cyprus and Banca Transilvania in 2009 and provides evidence of mass-deletion of e-mails and computer files by senior management of BOC



    

On 25 April the Central Bank of Cyprus (CBC – Κεντρική Τράπεζα της Κύπρου) issued a decree authorizing Cyprus’s largest commercial bank, Bank of Cyprus Public Co. Ltd. (Τράπεζα Κύπρου Δημόσια Εταιρία Λτδ), to sell a large part of its Romanian operations to a Romanian commercial bank, Marfin Bank (România) S.A., a transaction that was carried out that same day.

As explained by Bank of Cyprus (BOC) itself, the transfer involved “certain assets and liabilities including most customer deposits, certain loan agreements and related collateral and cash and other liquid assets”, while according to the CBC the transfer encompassed “the majority of deposits of retail clients and certain corporate deposits, cash and other liquid assets as well as loans”, and the acquiring bank, Marfin Bank (România), stated that it “took over gross assets of EUR 82 million, deposits of EUR 77 million, as well as all staff related to this transaction.”

First page of the CBC decree of 25 April permitting the sale of
part of BOC’s Romania operations to Marfin Bank (România)


In an ironic twist, the acquiring bank in Romania is, according to the latest information available (30 Sept. 2012), 99.32% owned by Cyprus Popular Bank Public Co Ltd (“Laiki Bank”), which itself is being acquired by Bank of Cyprus in accordance with the Resolution of Credit and Other Institutions Law of 2013 passed by the House of Representatives on 22 March 2013 under pressure from the “Troika”.  But Annex 1 of the law excludes from acquisition by BOC those subsidiaries of Laiki Bank that are incorporated outside of Cyprus.  In its press release regarding the acquisition, Marfin Bank (România) S.A. stated that it would be carrying out a capital increase of € 20 mln to further strengthen its capital base, and the National Bank of Romania stated that the decision to increase share capital was made by the parent bank in Cyprus.

The transfer, however, does not mean the end of all of BOC’s operations in Romania.  As the CBC explains, the BOC branch in Romania will continue “carrying out normal banking operations and servicing the customers whose contracts have not been transferred to Marfin Bank (Romania) SA.”

Bank of Cyprus’s representative office (or “branch”) in Bucharest opened in June 2007, and operates under the name “Bank of Cyprus Public Company Limited Nicosia - sucursala România.”  As of 31 December 2011, the latest date for which financial statements have been published, the branch had total assets (total active) of RON 2,301,935,357 (€ 533 mln), up 54.5% from the figure at end-2010, while deposits from clients other than banks (datorii privind clientela) totaled RON 2,262,546,892 (€ 524 mln), up 52.1% from end-2010.  News reports published within the last month assert that the branch’s total assets in March 2013 amounted to approximately € 450 mln, of which € 350 mln were in loans, but that in late-March the level of deposits began to decline, falling to a level of roughly € 90 mln, with € 3 mln being withdrawn after the 1 April closure.  As reported earlier in this column, Bank of Cyprus as of 30 Sept. 2012 had 10 branches in Romania, and for 9M 2012 the bank registered an after-tax loss of € 7 mln for its operations in Romania

(Disambiguation: The term “branch” is used in English in banking circles to refer both to 1) a representative office that a bank opens in a foreign country, i.e., an office that has no banking license of its own but operates under the supervision of the banking authority in its home country, and 2) a secondary office opened either by such a foreign-based representative office or by a locally-licensed bank.  In the case of Bank of Cyprus, in 2007 the bank opened for the first time a representative office in Romania, which operates as a “branch” of the parent bank headquartered in Nicosia, Cyprus.  Subsequently this representative office in Bucharest opened a number of secondary offices or “branches” in various parts of Romania.  This ambiguity exists in English but not in Romanian, as in Romanian a representative office is referred to as a sucursala, while a local branch is referred to as a filiala.)

After Cyprus’s 56-member House of Representatives adopted on Friday, 22 March, a series of nine new laws facilitating bank resolution, the Cypriot central bank ordered a suspension of operations at BOC’s Romanian branch for one week beginning Monday, 1 April, so that a buyer could be found for the Romanian operations.  (ATMs, however, remained in operation for some time, as seen in this 1 April video news report from Ştirile Pro TV.)  On 8 April negotiations were ready to begin with banks that had expressed interest in buying BOCs Romanian operations, and accordingly the CBC extended the suspension of operations for an additional two weeks, to 22 April.  This suspension was subsequently extended two additional days, to 24 April, and then one more day, to 25 April.  With the 25 April decree sanctioning the transfer of some of the accounts and staff of BOC’s Romanian branch to Marfin Bank (România), the BOC branch reopened.

Video: News report on transfer deal broadcast on 26 April by Digi24

In an interview with Mediafax published on 2 April, the director of banking supervision for the National Bank of Romania (Banca Naţională a României – BNR), Nicolae Cinteză, pointed out that the BNR has no supervisory authority over foreign banks operating in Romania via a branch structure except in matters related to mandatory minimum reserve levels and liquidity ratios.  He added that deposits at Bank of Cyprus’s Romanian branch are indeed insured to the EU level of € 100,000, but they are insured through Cyprus’s deposit insurance system rather than Romania’s.  Asked about the risk of the situation with BOC Romania leading to instability in the Romanian banking system, Cinteză stated that the risk was nonexistent because BOC Romania accounts for only 0.7% of total assets in the Romanian banking system, a system whose solvency level and prudential indicators are quite healthy.

  

During the period that BOC’s Romanian branch was closed, the Romanian press revealed that on 17 April the Cypriot central bank had turned down acquisition offers for the branch from two Romanian banks: Raiffeisen Bank and Banca Transilvania.  Sources revealed that both banks were offering less for the loan portfolio than what the Cypriot restructuring committee thought it to be worth, but that these were the only two banks to have submitted complete bids prior to the deadline on 15 April.

A possible additional motive for the rejection of the offer from Banca Transilvania was brought to light by the Romanian press on 17 April.  Writing on HotNews.ro, journalist Dan Popa published a leaked document – marked “STRICTLY PRIVATE AND CONFIDENTIAL” – compiled for the CBC by the British investigative consulting firm Alvarez & Marsal Global Forensic and Dispute Services, Llp (A&M).

A&M had been retained by the CBC in August 2012 to examine the situation that had led to Cyprus’s two largest banks, BOC and Laiki Bank, needing to request state support.  The document published by Popa, dated 26 March 2013 and written in English, consists of the first nine pages of a 42-page section from the full A&M report on the background to the situation at BOC.  The full A&M report on BOC apparently consisted of the following:

  1. Statement of Protocol
  2. Investigation Report: Bank of Cyprus – Holdings of Greek Government Bonds
  3. Investigation Report: Bank of Cyprus – Banca Transilvania Investment
  4. Investigation Report: Bank of Cyprus – Bank of Cyprus’s Acquisition of Uniastrum Bank
  5. Investigation Report: Bank of Cyprus – Marfin Popular Bank Group – Review of Cross-Border Merger

The chapter in question deals with a complicated episode that occurred in 2009 in which BOC attempted – in complete secrecy – to acquire up to a 20% stake in Banca Transilvania (BT), and ended up with a 9.7% stake.  This stock-purchase attempt by BOC led the Cluj-Napoca office of the national Directorate for Investigating Organized Crime and Terrorism (Direcţiei de Investigare a Infracţiunilor de Criminalitate Organizată şi Terorism – DIICOT) to initiate in July 2010 criminal proceedings against various officers of BT and of BOC Romania for activities connected to insider trading, stock manipulation, and money laundering.


The A&M report includes the following:

2.3 Alleged Market Manipulation

2.3.1 In making its investment in BT, the Bank sought to do so through various structures that disguised the true beneficial ownership of the shares (see Section 4 below), a possible consequence of which was to limit the impact on the share price, as the market was not aware of the Bank's interest in purchasing a significant shareholding in BT. The structures used by the bank to obfuscate the true ownership included:

2.3.1.1 Reaching an agreement with one of the founding shareholders to purchase BT shares in the market knowing that he had a guaranteed purchaser (i.e. BOC) at an already agreed premium;

2.3.1.2 Providing a bank loan to a BOC employee as a proxy who was used to purchase shares in the market on behalf of the Bank; and

2.3.1.3 Providing loans on favourable terms to companies beneficially owned by the founding shareholders of BT in return for agreements to sell their shareholdings in BT at a later date.

2.3.2 BOC's original intention was to acquire a 10% stake in BT, which would be further increased to 20% during 2010. However, following BOC's initial acquisition of 9.7% of BT, an investigation into market manipulation and insider trading was instigated by DIICOT, the Romanian Directorate for Investigating Organised Crime and Terrorism. The investigation named, amongst others, two founders of BT and two BOC Romania employees.

2.3.3 There is an on-going criminal case in Romania in which the General Manager for BOC Romania is one of the defendants. It is apparent from evidence submitted in the course of the criminal trial that the actions taken by individuals from the Bank in Romania were done on the basis of instructions from the Head Office of BOC.

2.3.4 The criminal aspects of market manipulation vary between different jurisdictions and the merits of any criminal case are a matter for legal opinion. However, JP Morgan stated in an e-mail dated 30 June 2009, that they were concerned that the proposed structure for the acquisition of BT shares as proposed in the Draft Non-Paper was potentially not compliant with the spirit Romanian regulations (see paragraph 4.4.11 below).

2.3.5 Despite this advice from JP Morgan, BOC continued with its plans to purchase shares in Banca Transilvania through various mechanisms apparently designed to conceal BOC being the ultimate beneficial owner of the shares acquired, until such time as ail of the transactions were completed with BOC owning just under 10% of the share capital and BOC having in place agreements to secure a 20% shareholding (subject to approval from National Bank of Romania).

2.3.6 It is noted that in relation to the case against its employees in Romania the Bank has, so far, been successful in dismissing the allegations put forward by the prosecution. In this regard, as described herein, our investigation has identified that some of the evidence and statements provided to the courts in Romania are inconsistent with the evidence found. Consideration should be given as to whether their potentially contradictory statements should be brought to the attention of the Cypriot and Romanian legal authorities.


2.3.7 As set out above, whether or not the agreements reached between BOC and the founding shareholders and their consequent execution to acquire BT shares constitutes market abuse, is a legal matter. However, we have concerns surrounding the manner in which BOC secured the 9.7% shareholding and these concerns may require further investigation and/or review by the relevant authorities. The areas of concern are:

2.3.7.1 Facilitating one of the founding shareholders, Mr Silaghi, to buy up a 3% stake in BT, for onward sale to BOC at a pre agreed premium to the market price, thereby enabling Mr Silaghi to profit from information not publicly available (i.e. the precise number of BT shares BOC was intending to purchase, and the price for which they were intending to acquire the shares);

2.3.7.2 Entering into an Agreement with Mr Ciorcila whereby Non Performing Loans held by companies under his beneficial ownership were restructured on favourable terms, in exchange for Mr Ciorcila i) agreeing to sell approximately 5% of BT shares under his beneficial ownership to BOC at a pre agreed premium to the market price; ii) agreeing to ensure that BT would undertake a rights issue during 2010 and that BOC would be guaranteed a certain percentage of unsubscribed shares so as to facilitate an increase in BOCs stake to c20%; and iii) signing an exclusivity agreement whereby neither Mr Ciorcila, nor Mr Silaghi, could sell any shares under their beneficial ownership to any party other than BOC until 30 June 2010 (see Section 3 below);

2.3.7.3 On 7 December 2009, via the various mechanisms employed to purchase shares, BOC was the beneficial owner of 9.1% of BT (see Section 7); however, only on 8 December 2009 did BOC approach the Romanian regulator to notify their intent to purchase more than 5% of BT, and only on 16 December 2009 was an announcement made of a significant investment, when such a disclosure was required to be made within 3 days of the acquisition per Romanian National Securities Commission ("CNVM")185 resolution 1/2006 (see Section 7).

2.3.7.4 The sequence of events leading up to the purchase of BT shares by BOC, and the nature of the agreements reached between BOC and the founding shareholders, were not disclosed to the Romanian Court. Instead an alternative description of events has been presented which creates the impression that BOC executives were not aware that the BT shares they acquired were purchased, indirectly, from Mr Silaghi and Mr Ciorcila. Further, evidence has been discovered and detailed herein that directly contradicts the statements made to the court by Mr Nicolas Karydas ("Mr Karydas") in his witness statement.

The leaked file published by journalist Dan Popa contains scanned images of a fax of the first nine pages of the chapter of the A&M report that deals with the BOC-BT transaction.  The images are of a two-hole-punched original, slightly tilted in a counterclockwise direction.  This would seem to be based on an original copy of the A&M report, as another section of the report – the initial section consisting of a “Statement of Protocol” (the scope of work for A&M) – was published on 4 April by the Cypriot website “SigmaLive”, and it too consists of scanned images of a two-hole-punched original, although in this case without any consistent rotation or fax header.  The rest of the report can be filled in from a file published on 17 April on the Cypriot website DefteriAnayNosI.com.  This 108-page PDF text file would appear to be generated by OCR from a scan of the entire A&M report.

In the 108-page text file contains the entire chapter dedicated to the BOC - Banca Transilvania share transactions.  The chapter concludes as follows:

10. Recommendations for further investigation

10.1.1 It appears from the Investigation that BOC sought to acquire an interest in BT through various structures that were intended to initially disguise the true beneficial ownership of the shares.

10.1.2 Based on suspicions of market manipulation the Romanian authorities instigated a criminal investigation, which included the General Manager of BOC Romania as one of the defendants. As part of this legal case Mr Karydas, as Group General Manager Risk Management and Markets at BOC, provided evidence to the Romanian court which contradicts some of the documentary evidence found during the investigation.

10.1.3 Based on the findings of the Investigation, legal advice should be sought to establish whether the alleged market manipulation in Romania is relevant to the Cypriot authorities and whether the findings from the Investigation should be presented to the Attorney General.

Although Horia Ciorcila, CEO and 5% shareholder of BT, was acquitted of charges in July 2011 by the Bucharest Court (Tribunalul Bucureşti), the decision has been appealed by the prosecutor.  In the course of its investigation A&M examined a great deal of internal BOC documentation that had not been available to the Romanian prosecutor (including thousands of e-mails), discovering evidence that was “inconsistent” with the statements and evidence provided to the Romanian courts, and consequently recommended to the CBC that it consider the possibility of prosecution in Cyprus.

If BT were to acquire BOC Romania, then there might be a danger of some of this incriminating evidence being eliminated before Romanian or Cypriot prosecutors would have an opportunity to examine it.  This might be one additional reason – aside from the low offering price for the BOC Romania loan portfolio – for CBC to have rejected BT’s bid to acquire BOC Romania.

In fact the danger of e-mail deletion on the part of BOC is not entirely hypothetical.  In the Statement of Protocol that begins its report, A&M writes the following:

3.2 Deletion of data

3.2.1 On 21 August 2012, the CBC issued a letter to each of CPB and BOC advising that an Investigation had commenced and that all books, records and documents, physical and electronic, were to be preserved and that all routine document destruction and deletion was to be suspended. On 24 August 2012, the CBC transmitted a similar letter to the employees of the CBC. Copies of each of these letters are attached hereto (Exhibit 2).

3.2.2 The e-mail data provided by the BOC to the Investigation team appears to be incomplete, with certain key custodians having little or no e-mail data during the period of 2009 and 2010. It was only possible in limited instances to determine the reasons for gaps in the electronic data collected. Potential explanations include deliberate deletion of data, poor archiving or inadequate data management by certain individuals. Furthermore, we are unable to confirm whether or not some or all of the absent critical data exists elsewhere.

3.2.3 The Investigation team received written approval from the CBC to obtain and analyse forensic images of the computers of the BOC employees on 8 November 2012. Based on an initial review of this data, our computer forensic technologists have found that the computers of two employees, Mr Andreas Eliades ("Mr Eliades") and Christakis Patsalides, have had wiping software loaded which is not part of the standard software installations at the BOC. Mass deletion of data appears to have been undertaken on the Patsalides computer on 18 October 2012. It appears that some deletion was undertaken after a data preservation notice was issued to BOC by the CBC on 21 August 2012.

3.2.4 There are no e-mail files, mailboxes or user documents on Mr Eliades' desktop computer. We have been unable to recover or identify any such documents from the hard drive of this computer, which would suggest that either:
  • the computer was not used by Mr Eliades; or
  • the hard drive was formatted and/or wiped by BOC IT after Mr Eliades left the bank; or
  • the hard drive was wiped using data removal / wiping software such as CCIeaner installed on the desktop.

And in a later section of the full A&M report, dealing not with BOC’s acquisition of Banca Transilvania shares in 2009 but with BOC’s own  internal governance, A&M adds this:

7.7.19 Following approval to obtain forensic images of BOC computers, it was found that on 18 October 2012 over 28,000 files (including almost 1,300 documents148) were deleted from Dr Patsalides' desktop using wiping software installed and executed from a portable device (e.g. a memory stick).

It is worth noting that “Mr. Eliades” was CEO of the entire BOC Group, and “Mr. Patsalides” was BOC’s Senior Manager Group Treasury and Private Banking.

========

One noteworthy finding of the A&M report is that a particular EU directive, one which Cyprus as an EU member had duly incorporated into its own legislation, effectively left the Central Bank of Cyprus and the Cypriot government with no means at their disposal to block a private business decision that would result in the effective transfer of well more than a billion euros of bank liabilities from the Greek banking system to the Cypriot banking system.

The final part of the A&M report on BOC is entitled “Investigation Report: Bank of Cyprus - Marfin Popular Bank Group - Review of Cross-Border Merger”, and consists of a 14-page recapitulation and analysis of the steps that led up to the 2011 merger of Marfin Popular Bank (“MPB”), based in Cyprus, with its subsidiary in Greece, Marfin Egnatia Bank S.A. (MEB – Marfin Eγνατία Τράπεζα Α.Ε.).  As a result of this merger, the Greek operation ceased to be a Greece-based subsidiary and became instead a “branch” of the parent bank in Cyprus.

Just fifteen months after the merger, on 2 July 2012, the Cypriot parent bank – MPB – needed to be recapitalized by means of a € 1.8 bln bailout from the Cypriot government, making the government owner of a 84% stake in the bank, i.e., effectively nationalizing the bank (and its liabilities).  Yet even after the recapitalization the bank’s situation continued to be poor, and on 22 March 2013 the House of Representatives felt it necessary (under pressure from the “Troika”) to pass a law shutting down the parent bank – now known as Cyprus Popular Bank or “Laiki Bank” – and splitting it into a “good bank” (to be absorbed by BOC) and a “bad bank”.

The A&M report discusses the impact of one particular EU directive, the “Mergers Directive”:

5. Relevant Legislation and Powers

5.1 Relevant Legislation

5.1.1 External legal advice in respect of the conversion of MEB from a subsidiary into a branch of MPB has highlighted three key areas of legislation that are relevant in considering the requirements of the regulators and the bank wishing to convert its subsidiary into a branch.

[...]

5.1.1.2 EU Directive 2005/56/EC on cross-border mergers of limited liability companies (the "Mergers Directive")

[...]

5.1.2 The Mergers Directive has been integrated into Cypriot company law and sets out the requirements in respect of a cross-border merger of two or more limited liability companies within the EU. Although this is relevant to the merger of MPB in respect of the transfer of assets and liabilities and registering and consolidating the existence of the merged entity, it does not relate to the transferring of a subsidiary's banking licence into a licence for the parent company to operate a branch in another member state.


A&M states that it was the “Mergers Directive” – perhaps aided by a lack of specific Cypriot legislation – that kept the Central Bank of Cyprus from having any voice in the proposed merger:

7. Conclusions and Recommendations

7.1.1 It is apparent from the Investigation that the CBC did not take any actions to stop the cross- border merger which essentially transferred the liability of the former Greek subsidiary to Cyprus. The lack of action on the part of the CBC is due to the following key factors:

7.1.1.1 The structure of the regulation and legislation is such that under the Mergers Directive the bank did not require any authorisation from the CBC, this resulted in the bank being able to transfer the assets and liabilities to Cyprus without approval from the CBC.

7.1.1.2 The subsequent notification of the conversion of the Greek subsidiary into a branch of the Cypriot bank left the CBC with the option of accepting the conversion, and therefore notifying the BOG, or forcing the bank to cease operations in Greece. Given the desire to maintain the bank's headquarters in Cyprus and the perceived regulatory benefits, the CBC notified the BOG of the creation of MPB's branch in Greece.

7.1.2 Based on the findings of the Investigation it would appear that the current regulation and legislation does not provide sufficient support to the CBC where a Cypriot bank wishes to convert an existing foreign subsidiary into a branch. We recommend the performance of a review of the legislation and consideration of amendments that would enable and require the CBC to consider the impact of such transfers and what powers should be given to the CBC, or other relevant authorities, in respect of the approval or rejection of such transfers.


The only approval necessary to the merger was a decision from the Nicosia District Court (Επαρχιακό Δικαστήριο Λευκωσίας), which was duly obtained on 15 December 2010:

3.1.11 On 15 December 2010, the District Court of Nicosia approved the completion of the cross-border merger of MEB and MPB, in accordance with EU Directive 2005/56, with the merger being finalised on 31 March 2011.

(An examination of the text of the decision itself indicates that the requirement for court approval was merely pro forma, as the court merely judged whether the proposed merger was in conformity with the EU’s “Mergers Directive”, Cyprus’s “Law on Companies”, and Greek legislation on limited liability companies.)

The report makes clear what was at stake for Cyprus in the conversion-via-merger of the Marfin subsidiary in Greece into a branch:

6. Consequences of the Proposed Merger

[...]

6.2 Transfer of Greek Liabilities to Cyprus

6.2.1 One of the key concerns raised in relation to the approval of the cross-border merger was that by converting MEB from a subsidiary to a branch it was no longer a separate legal entity from MPB and therefore all assets and liabilities of the former subsidiary were subsumed into MPB.

6.2.2 Based on company law a subsidiary and parent are two separate legal entities and therefore the parent company does not, unless there are cross-guarantees in place, have the obligation to recapitalise a subsidiary based in another member state.

6.2.3 A branch, as distinct from a subsidiary, is inseparable from the parent and therefore any losses or financial commitments of the branch are the legal obligation of the parent.


And while A&M does not attempt to put a precise figure on the impact of the merger on the capitalization of Cyprus’s banking system, the impact was clearly sizeable:

4.13 Post finalisation of the merger, the CBC undertook a SREP review, following which it required MPB to hold €1.56 billion of additional capital against its sovereign bond portfolio and €2.1 billion against its loan portfolio (51% of which was concentrated in Greece).


Principal sources:
CBC decree of 25 April 2013: “Sale of Certain Operations of Bank of Cyprus Public Company Limited Sucursala Romania Decree of 2013” – Greek original: Περί της Πώλησης Ορισμένων Εργασιών στη Ρουμανία της Τράπεζας Κύπρου Δημόσιας Εταιρείας Λτδ Διάταγμα (2013-04-25, pp. 937-941)
CBC press release – English: Deal reached for Bank of Cyprus in Romania (2013-04-25)
BOC press release – Romanian: Operatiunile Bank of Cyprus in Romania (2013-04-26)
BOC press release – English: Bank of Cyprus operations in Romania (2013-04-26)
BNR press release: Comunicat de presă (2013-04-25)
DIICOT press release regarding charges against Banca Transilvania and BOC officers, and others: Comunicat de presa - 12.07.2010 (2010-07-12)
Banca Transilvania press release regarding DIICOT decision – English: NOTICE (2010-07-12)
Laiki Bank Group – Subsidiaries: International Operations as of 30 September 2012
 “The Resolution of Credit and Other Institutions Law of 2013” – Greek original: Ο περί Εξυγίανσης Πιστωτικών και Άλλων Ιδρυμάτων Νόμος του 2013 (2013-03-22, pp. 117-176)
“Bailing-in of Bank of Cyprus Public Company Limited Decree of 2013” – Greek original: Διάταγμα περί Διάσωσης με Ίδια Μέσα της Τράπεζας Κύπρου Δημόσιας Εταιρείας Λτδ Διάταγμα του 2013 (2013-03-29, pp. 769-780)
“Sale of Certain Operations of Cyprus Popular Bank Public Co Ltd Decree of 2013” – Greek original: Διάταγμα περί Πώλησης Ορισμένων Εργασιών της Cyprus Popular Bank Public Co Ltd Διάταγμα του 2013 (2013-03-29, pp. 781-788)
CBC press release on the commissioning of Alvarez & Marsal (A&M) to investigate circumstances that have BOC and Laiki Bank to seek state support in Greek  in English (2012-08-24)
Alvarez & Marsal report on BOC (2013-03-26): Statement of Protocol in image format, an attachment to the article Αυτούσια τα συμπεράσματα της Alvarez & Marsal (2013-04-04 13:00)
Alvarez & Marsal report on BOC (2013-03-26): Investigation Report: Bank of Cyprus – Holdings of Greek Government Bonds: the first 13 pages of the sub-report in image format, uploaded to Scribd by user Olympia Gr on 2013-04-20, an attachment to the article ALVAREZ & MARSAL: Το olympia.gr αποκαλύπτει τη μυστική έκθεση που στέλνει φυλακή τραπεζίτες και πολιτικούς σε Ελλάδα και Κύπρο. (2013-04-21)
Alvarez & Marsal report on BOC (2013-03-26): Investigation Report: Bank of Cyprus – Banca Transilvania Investment: the first 9 pages of the sub-report in image format, an attachment to the article Raport confidential: Operatiunea Beatrice, sau de ce era ingrijorat JP Morgan de relatiile Banca Transilvania- Bank of Cyprus (2013-04-17 08:51)
Alvarez & Marsal report on BOC (2013-03-26): Investigation Report: Bank of Cyprus – Marfin Popular Bank Group – Review of Cross-Border Merger in image format, an attachment to the article Cyprus, where the vicious circle stopped (2013-04-05 19:10)
Alvarez & Marsal report (2013-03-26): Complete report in text format generated from a scan using OCR, an attachment to the article Η ΕΚΘΕΣΗ ΤΗΣ ALVAREZ & MARSAL (2013-04-17 00:54:54)


Mark Pleas
Eastern Europe Banking & Deposits Consultant