The 'G' in ESG Doesn't Stand for Gaslighting - Singapore's Banking Secrecy
"Gaslighting is the subjective experience of having one's reality repeatedly questioned by another."
Petty, spiteful acts are an important component in whistleblower gaslighting because the general public’s assumption is that it is patently implausible for institutions, especially elite ones, to indulge in high school antics. The multiple minor social aggressions can be explained away, so when targets eventually react to repeated provocation, the depiction of whistleblowers as mentally and emotionally unstable is reinforced (Oransky, 2018)." Whistleblowing When It Hurts: Whistleblower Gaslighting And Institutional Secrecy | European Proceedings
"The other symptom I see in targets of whistleblower gaslighting is a desperate urgency to be believed. This looks a lot like an “obsession,” but as with the “paranoia,” it is not the result of a mental disorder. It is more like the normal response of someone who spent 10 years in jail for crime he didn’t commit. Such a person is indefatigable in pursuit of having his name cleared, as are targets of whistleblower gaslighting who also are intent upon clearing their names and reputations." Institutional gaslighting of whistleblowers « Minding the Workplace (wordpress.com)
I can relate to the above descriptions of whistleblower gaslighting, as I'm sure can so many others. It was almost 10-years ago that I raised concerns about serious corporate governance lapses in a Singapore SGX listed darling, and rather than deal with what was happening which risked leaving a temporary stain on Singapore's reputation, it was easier to cover up what had taken place and gaslight me. One of the main perpetrators of what I saw as gaslighting came from Singapore's Government linked bank DBS. The Board of DBS through their lawyers in January 2022 advised the editor of Asian Sentinel who questioned them about my story, that I had acted with malice. The editor and others commented that it appeared far-fetched. It appeared far-fetched because it wasn't true, but again it was a way to discredit me and protect the bank and its client.
Two years earlier a senior DBS executive wrote and told me: "
You assume things or read so much into things when they are not there"
"I understand healthy skepticism, but you are taking that into a very unusual extreme"
"You have to take a step back every now and then from the single mindedness."
These are forms of gaslighting and it is not uncommon for anyone who blows the whistle to experience this kind of treatment, which could leave one questioning their own sanity.
Bank staff even attempted to convince a prominent third-party who stepped in to assist me, that I was seeing things that just weren't there. For a while I think he may have actually believed them. But then he looked through the evidence, followed the DBS whistleblower investigation closely and said that it had been a whitewash toward a predetermined conclusion. I felt somewhat vindicated.
DBS might have been an innocent bystander in what had initially taken place, when two DBS letters were used in a conspiracy to defraud, but it would be the later actions of DBS that would raise concerns for me. What did I do to illicit such responses and should we blame Singapore's Banking Secrecy laws?
In August 2014 our lawyer had asked DBS Legal if two letters which had been used by their clients in what was a conspiracy to defraud, were authentic. The influential client of the bank had already been implicated in affixing forged signatures to documents and entering a struck off company into legal agreements, so it wasn't that too far-fetched to believe that DBS letters had been tampered with to wipe between A$30 million - A$40 million off a one-week-old valuation of a company which the influential DBS client was attempting to acquire. The letters were full of errors and inaccuracies and appeared to contain contents of a letter sent by DBS a year earlier. A forensic document examiner and a former employee of DBS Compliance stated that the DBS letters lacked credibility. I just want to clarify that DBS publicly confirmed in January 2022 that the DBS letters are authentic, with no explanation for the shoddy communications which were sent to a corporate client.
DBS Legal took almost eight-weeks to respond to our lawyer and in October 2014 refused to authenticate the letters citing banking secrecy obligations. That standard response could have been sent within 48-hours. But during that delay in responding, the influential DBS client would raise almost $20 million from investors, not disclosing that the funds were to be used to purchase assets from a company in which he held a claim to a beneficial interest. A claim to a beneficial interest in a shareholding which was entitled to 99.8% of any dividends declared by the seller of those assets. After the sale of the assets to the purchaser, the seller had to cease to trade due to lack of funds and because its identity had been assimilated by a subsidiary of a company controlled by the DBS client. This left the DBS client with a potential beneficial interest of over A$23 million in dividends, which the investors in his SGX companies were oblivious to.
The writing was on the wall, and when the group of companies headed up by the DBS client went on to collapse, the financial exposure of DBS was estimated to be some S$637 million. I wasn't acting with malice, I was the one raising the flags that something was wrong!
Between August 2014 and up to April 2020, there have been numerous purported DBS investigations which I have highlighted here, each one raising concerns. But I would like to go into more detail with one of them, bearing in mind that I was later informed that the investigations into the authenticity of the two DBS letters would have only taken 2 - 3 hours. Additionally, prior to the investigation referred to below, DBS Legal had already purportedly investigated the same letters for eight-weeks.
16 February 2016 – Following the uncovering of information related to the transaction above, via LinkedIn I reached out to an expat who was the DBS Group Head of Financial Crime and I sent him my concerns in a letter, with accompanying documents.
3 March – I sent an email asking if he had reviewed the documents.
4 March – His response - “We have started. I will get the team to touch base with an update.”
11 March – Do you have any update?
21 March - I have received no contact from your team with an update, is this likely to be forthcoming soon?
23 March - His response - I apologize for the delay. The team were diverted to another matter. I will get a position to you by end of next week.
7 April - Sorry to keep chasing you for a response. As you may be aware, in 2014 DBS took some eight weeks to respond to the same concerns, which I have now resubmitted to you. So I would have thought that most of the investigative work would have already been undertaken.
20 April – As you can see it is almost a month since I received the response from you below. Can you please let me know if the investigations are continuing or complete?
20 April - His response - The investigations are continuing. I will arrange for a call with you during next week.
29 April - Following up on the email below, when am I likely to hear from you?
4 May - His response - I am travelling during early part of next week. XXXX will coordinate to suit timing for you.
5 May - His PA's response - Can I suggest a call on Wed 18 May 2016 at 4 pm.
5 May - 18th May will be fine
11 May - His PA's response - Apologies, XXXX will need to attend a regulatory meeting on Wed 18 May 2016. We will need to reschedule the call to Tues 24 May 2016 at 5.30 pm
11 May - 24th May at 5.30pm is fine
19 May - His PA's response - Apologies, as XXXX needs to travel overseas for business purpose, can I suggest to reschedule the conf. call to Mon 6 Jun 2016 at 5 pm.
20 May – His PA's response - Reschedule Monday, 6 June, 2016 5:00 PM
13 July - Of course I'm disappointed that you have chosen not to respond to any of my communications since May 2015
26 July - Could you please circulate this email and the attachment to Members of the DBS Board and/or other parties within DBS who may wish to provide clarification on any point I have raised in the attached article.
26 July - Can I arrange a meeting for you and XXXX on this Fri, 29 Jul 2016 at 1 pm. Pls let me know if this suits.
27 July - His PA's response - Meeting arranged with XXXX and Julie on DBS Letters dated 30th July 2013 & 11th September 2013
29 July – The first question I was asked on the call, by what came across as a very nervous DBS Group Head of Financial Crime, was "what DBS letters"? Flabbergasted at this response, I was asked to resend the letters and advised that it would only take 2-3 hours to confirm if they are authentic. But I could not be told of the result!
29 July - Thank you for arranging the call earlier. Knowing the background to our story and having received a significant amount of information to date, I am flummoxed as to the reason for your call and now pleased that I didn't waste the time and expense of travelling to Singapore, for a face-to-face meeting.
29 July - His response - As per our call, I didn’t recall seeing the subject letters. I now have samples from you and I will investigate accordingly.
11 August – I wrote to DBS Audit Committee and Board
30 August – DBS Board authorised an obfuscated response be sent to me which did not confirm if the letters were authentic in content and origin. The letters were full of errors and appeared to contain extracts taken from a letter sent by DBS a year earlier. There were no bank references on the letters and the usual contact information for DBS was missing.
5 September - His response after I sought clarification - As per our recent letter, the bank has completed its investigation and is satisfied that we have acted appropriately. We therefore consider this matter closed and will not entertain any further requests on this matter.
5 September – Automatic response to email 'on leave'. No further responses were received until I was advised that he had resigned.
23 November – letter sent to the DBS Board via his PA asking if the DBS letters were authentic in content and origin.
7 February 2017 – PA advised that XXXX had resigned and shall be leaving the Bank shortly.
His replacement, also a highly lauded individual who this time had been a former UK police officer, commenced in May 2017. I wrote to him in November 2017 and requested that he undertake a cold-eyes review of the earlier investigations. He provided the response given by his predecessor before he had resigned. I then asked DBS SpeakUp if someone at DBS was covering up a fraud. It appeared by April 2018 if not earlier, that the second DBS Group Head of Financial Crime was working out his notice as his emails were being forwarded to other staff members. I was formally advised in June 2018 that he was serving out his notice period.
I hold no grudge against the DBS compliance staff or the PwC Partners in Charge of the DBS Audit, I actually feel sorry for all those involved, if they found themselves having to toe Singapore's Banking Secrecy line
I believe what my experience highlights, as happened in the Wirecard fraud, is if errant or corrupt individuals want to utilize Singapore's banking secrecy loopholes to use bank letters, documents or statements to defraud others they can. This should be a concern for local and international investors who could find themselves up sh!t creek without a paddle. I share my story so others are forewarned and so they might recognize the signs of gaslighting.
"...Mr Bellenhaus created fake bank statements and balance confirmations on behalf of Citadelle, he told the Munich judges, adding that those documents were then passed to Citadelle, which sent them to EY." Wirecard fraud: EY came close to uncovering scandal in 2016 (afr.com).
"At the time, Wirecard’s accounts fraudulently stated that Citadelle Corporate Services in Singapore oversaw escrow accounts in Asia that held about €150 million ($263 million) in cash. EY has previously cited Singapore’s bank secrecy laws and said it was legally required to rely on information from the trustee instead.