Hackers leaked approximately 13.4 million confidential client documents from Appleby, Estera, and Asiaciti Trust to the International Consortium of Investigative Journalists.
The leaked files, known as the “Paradise Papers,” show that Appleby set up companies and bank accounts in low tax jurisdictions. The client list is reportedly dominated by U.S. companies and individuals, including “politically exposed persons,” Fortune 500 companies, financial institutions, and high-net worth individuals. The leak resulted from a hacker attack last year. It is unclear when reporters first got the hacked files, or if governments had early access. Similar leaks, such as the Panama Papers, have led to investigations.
Offshore accounts and investments are common, but U.S. law requires reporting and recordkeeping. For example:
- Financial institutions, hedge funds, private equity firms, and trust companies have reporting, record-keeping requirements, and know-your-customer obligations under antimoney laundering regulations, including newly revised Customer Due Diligence (CDD) rules.
- Foreign financial institutions have reporting requirements under the