From Wirecard Whistleblower to Founder: Pav Gill’s Story

Sanctions have been imposed on 82 individuals and 29 companies. German payment provider Wirecard went bankrupt on >> Russia has launched an unprecedented disinformation campaign against >> billions of dollars have been found in various offshore accounts in >> Welcome to Integrity Insights, the Berlin Risk Podcast. Hello everybody. Welcome to the latest episode of Integrity Insights. I sat down today with Pav Gill, a Singaporean lawyer best known for being the whistleblower who exposed the Wirecard

scandal, one of the largest financial frauds in German history. He was the former head of legal for Wirecard's Asia Pacific region based in Singapore. In August 2023, he founded the Confide platform, a technology-driven whistleblowing and risk management platform designed to help organizations detect and manage misconduct. He's now a recognized expert and speaker on topics related to whistleblowing, corporate ethics, and regulatory compliance. Pav's career journey is really unique, uh to say the

least, and I really enjoyed talking to him, so I I hope you enjoy the conversation as well. Pav, welcome on the podcast. >> Thank you for having me. >> Pav, can we can we start with a with a brief intro? Can you tell our listeners uh a little bit about your career background? >> Yeah, I'm a lawyer. Um I started my career at Allen & Overy, Clifford Chance, and King & Spalding. Found myself in the fintech space after that. Um and as a lot of people know, one of the

companies I ended up in was Wirecard, so I was a head of legal for the Asia Pacific region. Uh a lot of fun stuff happened there. Um resulted in me blowing the whistle after I left the company. Uh I then joined Wise as its APAC counsel, and then you know, made it to uh the crypto scene, where I was the general counsel of a crypto exchange. Um and now I'm the founder and CEO of my own tech startup. >> And you are you are originally from Singapore, right?

>> Yeah, yeah. I'm born here. Uh, also did the military service and stuff. So, I I better be Singaporean. >> Yeah, okay. That's that's that's really that's really interesting. Um, and yeah, so obviously this this whole Wirecard story, uh, there is for everyone who's listening to this, there's a lot of a lot of background information on this. You can you can listen to other podcasts where Pavo went into little like detail uh, um, exactly what happened there. So, we will kind of go just quickly through it, but um,

uh, maybe just a basic question like how did you you know, how did you got this job offer? Like, what I find interesting is that I think you you mentioned that also elsewhere that you were basically headhunted by the company. >> Yes. >> Uh, and I I wonder like why did they why do you think they reach out to you specifically? >> I don't know. I mean, they generally hire um, people that were good in their jobs. Uh, I don't think I mean, Wirecard was a fraud that was coordinated by the very

top level, right? So, I think from my kind of hiring a company which has thousand plus two thousand employees, I think um, it would just be someone who's hired for the role in this other country and he needs to just do what he needs to do. I don't think they ever envisioned or even in their wildest imagination, I don't think that that level of top senior execs thought that you know, information would cascade down someday to this person in the Singapore office.

>> So, if I understand you correctly, you're basically saying that the people that actually hired you weren't even necessarily aware of the this fraudulent scheme taking place at the company. >> Yeah, I mean, I was hired directly by the legal team. So, um, they were very focused because, you know, they just purchased Citibank's merchant acquiring business in Asia Pacific. They needed to get licensed in 13 countries. Uh most of the legal and compliance work was being done out of Munich. And as the company was growing with the City Bank deal, they actually

needed someone on the ground to help them with all these things. So, I think it was a more practical and um just sound decision. I The person that hired me yet I don't He was relatively new himself. He was with the company for 1 and 1/2 years. So, you know, my job was really to help that person out. >> And what was actually the role of the Singapore office in the in the entire company structure? >> It was the headquarters for Asia Pacific. So, it looked after It was a comm center of all the ops um that happened here. So, for example, finance

was run out of uh the Singapore office um on the Asia Pacific level. So, it was disbursed from here. And of course, from here it was received from headquarters in Munich. >> Okay. Uh and you and you and you basically So, you basically were based in Singapore and you kind of like traveled around the these 13 countries in the region and coordinated those offices. >> Yeah. So, that was why it was very great like in terms of autonomy. It was very exciting. The colleagues were generally very very nice people. Um fun It It had

a startup kind of vibe um you know, in a way. So, yeah. And it was a reputably list You know, it was a reputable company. It was listed. And there were no reasons to um have any kind of real serious red flags when I first joined. >> Mhm. And so, how much time did you spend there in total? Was it about a year? >> Yeah, it was exactly 1 year. Like to the day. It was 1 year to It was I think 18 September to 18 September the next year. >> Uh-huh. That's uh that's very exact. And

um I mean, as I said, we are not going through uh what exactly happened at Wirecard. Again, there are plenty of resources online where people can learn about this, but what I'm what I was wondering when I was kind of researching your story is that you obviously provided all this information to the Financial Times originally as an anonymous whistleblower and it was only about a year later, I believe, that they disclosed your name. Can you kind of explain this process?

Like when why did you stay anonymous at the beginning and why and when did you give the permission to disclose your identity? >> So, the FT knew I was from day one. Um since I reached out to them, they always knew who I was. It's just that the instructions were very clear that as a whistleblower, I need to be anonymous all the way until I decide it's time to come out, right? Because it's super critical that you are anonymous and not exposed because

the challenge most whistleblowers face is that once their identity is out, that's where they suffer a great deal of retaliation. Um and most whistleblowers as individuals do not have resources to take on a company in these kinds of legal and reputational battles. So, that's why it was very important for the FT and for my side to control anonymity. But then a year after the company crashed, that's where I told the FT, I told Suddeutsche Zeitung uh that

okay, because the Sky documentary is releasing on that day, uh you guys can also publish on that day who the whistleblower is because the documentary would have been revealing it anyway. >> But you you I guess you needed to give a permission even to the people behind the documentary to disclose your name, right? >> Yeah, so I had specifically chosen Gabriela Sperl uh who had reached out because she was working with

she was recommended by you know this other journalist Melanie Bergmann I think her name is from We Will so Melanie wrote the book she was very involved in Wirecard's reporting as well so Melanie had actually reached out because she knew I was from the whistleblowing standpoint and she said look this is a different documentary it's actually going behind the scenes from the people's perspective it's not really like a Wirecard fraud story but what happened behind the scenes over the last few years that finally led

to its crash right like the various people that suffered and who tried to blow the whistle and so because of that we agreed that okay if that's the direction this documentary is going to take then we will be part of it so that's where we worked closely with Gabriel Pearl and yeah it on the day of its release a year after the company crash was when we also decided to tell the FT I think Bill also did an interview prior to that leading up to it that okay this is I mean you got to

control the narrative but it's still very scary right it's still a big unknown you don't know what's the outcome from these kinds of disclosures of who you are yeah so it was a very interesting time >> talking about the specific documentary one question that just sprung to my mind is something because I would say there's so much content you know in terms of documentaries books uh is there something you know specific that you that you when you watched or when you like consumed when you read

that you found like particularly kind of accurate or that that you found like you know the best representation of the actual story is there something you would like recommend someone to to watch or to to read >> I think they should watch the Sky documentary and it's not because I'm in it but because it's got people element to it. Um I would definitely recommend that. Uh I would recommend Dan McCrum's book, the FT reporter's book called Money Men, because that's very detailed in terms of

uh what happened um in a more historical uh and then leading up event and post Wirecard crash event. Uh so, for someone that wants in-depth detail, uh that would be one. And also, the Süddeutsche Zeitung article on the day that they disclosed my identity. I think it was about 46 pages long. One of the longest in their history. So, that's really intensive reading as well. So, those would be the three that I recommend. >> Great. This is really interesting. Thanks for sharing those recommendations, Pav. Um

another thing I wanted to ask you is uh like your post-Wirecard uh time. Like, how did you find the process of, you know, applying for new jobs and kind of getting back into uh into the industry after such a kind of what I could imagine was a pretty traumatic experience. >> Yeah, I mean, it it wasn't difficult because, again, like, no one knew I was a whistleblower and the company hadn't crashed then. Um so, what was more challenging is kind of

explain why you only lasted 1 year in this company. So, that was more uh challenging. And Wirecard was also setting up fake interviews for me uh with their friendly firms. Um and those interviewers would just ask me why I left Wirecard, did something bad happen? And I knew why they were doing that. It's so that I breach like an NDA or confidentiality aspect and Wirecard can make my life hell again. So, it was that, but I think I got a job pretty soon after. I think it was 4 months later. Uh I joined Wise as their

first APAC counsel, for example. Uh and then moved to the crypto space. It was during my time in the crypto space where the the came out and everybody knew who I was. But the company took it very positively because they um used it as a positive PR that look, you know, in a space such as crypto, we would not have hired half kill uh if we wanted to do something wrong, right? So, that kind of also gave assurance to regulators as well as customers to some extent um that the company was taking

legal and compliance very seriously. >> Mhm. And then uh just last question on this topic, I find interesting in this whole story the the role of the the the short sellers. Uh and I wonder how you view, you know, their role in this particular context and also how do you view short selling in general? Like, do you view it as a, you know, force for for good or more like the opposite? >> I think everything has a good and bad

side to it. Um even like Panadol. If you take too much it's it's really bad uh for you. But I think uh you know, weird way uh short sellers are are like the same, right? Cuz what they're doing is acting as a check and balance on the system. Um and they're constantly looking out for, uh you know, companies that are inflating the books or doing other kinds of dodgy stuff and then reporting with it. And this is directly in the benefit of uh investors

who are putting money in these companies. Um the question then always goes into because these money these people are making money for themselves in the process. Um we is that moral or is that ethical and all these stuff, but you know, as long as you're not faking it, as long as you're not engaging in short selling to do pump and dump type uh bets uh and make money off those move those that kind of volatility um and destroying, you know, good value

child the value in the process. I think then it's fine. It's a it's a useful part of the system. >> And were you actually because I think so some of some of these reports were published was it in 2015, 2016 so even before you joined the company like had you been aware of of this information or or not not not that you you you didn't really come across this? >> No, I was I have never owned stocks in my life. So I was never uh I just have no interest like I'm very bad in uh emotionally dealing with volatility.

So if I put money in something and if I saw it lose even like one or 5% I just want to get out of it. So I'm just not someone that's very good in um in those topics from an investing standpoint. Uh so that's why I just never invested in stocks and all these things and it was actually post Wirecard where I had my experience in these things. Like okay, that's when I understood what this whole short-selling thing was about um what is it actually. Uh and yeah, it was a learning process for

me as well. And it's also after leaving the company that I realized like okay, Wirecard had this massive short seller report against it called the Zatarra report. Um and that's when I came across it and I started looking into it. But you know, when you're in the when I was in the company I was just so busy on my day-to-day stuff. Um I was not looking for dirt against the company and I think that should be the way people should ideally operate. Like I would never I don't think it's normal for any employee to go into a a new company and

start sniffing around for wrongdoing. Um it's usually when this the smell is so bad or someone comes to you, that's where I think uh things tend to kick off. >> I hope I hope by the way that you didn't change your mind and and started investing in stocks recently because there's been a lot of volatility. You would you wouldn't you wouldn't like it. >> No, no. I'm a startup founder now. So uh still pretty poor. >> [laughter] >> So, talking about the the the startup, uh if I have the correct information,

you founded a company named Confide Platform in 2023. Uh can you maybe walk us through what your motivation behind this was and what the com- company uh does? >> Yeah, for sure. I mean, uh after I came out publicly, I was doing a lot of global keynote speaking events. Um I think what I said, I've done about 50 in 2 and 1/2 to 3 years. And a lot of these was discussing things like the EU whistleblowing laws uh that was rolled out um because of Wirecard, you know,

triggering or accelerating its implementation, for example. Um and just these things, right? Governance, corporate ethics, uh corporate governance and responsibility and all these various elements within that sphere. Uh and I was always also asking myself, what's the bigger reason behind having exposed Wirecard? Like, why me and not someone else? And then it just hit me, like, look, I've seen how organizations kind of challenge a a challenge from an internal reporting

standpoint, you know, whether it's a HR reporting, like, bullying, harassment, Me Too, or it's financial crime whistleblowing, or even things like data breach, right? Like, should we tell our customers? Should we tell uh regulators? So, I've seen it from that side as general counsel. I've also seen it as a whistleblower. So, then it hit me, why not put all that experience a product that would benefit companies, and lawmakers. And that's how the Confide Platform was founded based on that. Um I think

Confide is a very powerful word because every time you're in a situation where you want to raise a concern, or you want to speak up, you don't know who to confide in, or you're confiding in the wrong person, or you're not allowed to confide, for example, because of legal privilege or confidentiality reasons and whatnot. So, that's why I think it's a powerful name and that was what went into the development of the product. >> And the and the So, the company is based in Singapore, but I I suppose you operate globally, right? You are you have clients all over the world. >> Yeah, that's right. So, we were very

lucky to get a lot of global media attention when we launched. For example, we were covered by the FT, Wired US, Business Insider, and so on, right? I think what the media found fascinating is the fact that I've turned very negative experience into a product and trying to make it positive. Because what I didn't want or what I'm trying to achieve what the goal is is to really have less wire cards. So, if you have something like the Confide whistleblowing solution, for example,

which is the world's first and only end-to-end whistleblowing product, um then hopefully companies will be given the opportunity to deal with cases before they explode. Um and hopefully deal with whistleblowers internally the right way instead of going after them because you don't know who they are, for example. Um you know, it's really telling organizations like, "Look, have something your employees trust in place that actually works, that it's end-to-end. It's not just a receiving

channel, but it also enables you to carry out the whole investigation on the platform itself. Um and just bulletproof yourself. Don't wake up one day, find yourself in the news, um and then be like, "How come I didn't know about this? If I knew about this, I would have done something." Right? So, that was the original motivation and idea behind Confide, and that's why we launched with the whistleblowing product. But, as of today, we have expanded into other

operational compliance workflows, like, you know, grievances, for example. Grievances, HR grievances should not be going in the the platform because they are not whistleblowing cases in that sense. They are grievances, they are employee concerns, issues and stuff, right? Or or unhappiness in general. Um And then you have conflicts of interests. These shouldn't be going in a grievance or into a whistleblowing channel. These are conflict of interest scenarios. And

then you have gifts and bribery and entertainment and all the various different aspects. AML investigations, fraud and scams. You know, if you are a fintech, you if you are a customer of a fintech, if you look for example at Revolut, they've been in the news very often for scams, being very high on their cars. So if you have this kind of organization, at the end of the day, what all these different products are trying to achieve is the ability to receive or have an issue or concern in that topic raised,

being able to manage it from start to finish, and then bulletproof yourself as a company because it's all there. So if anything happens, you know how something started, who dealt with it, and then how it was concluded. So that's the Confide Confide platform with its various solutions as of today. >> And are your typical clients more like smaller organizations that don't I don't know, don't have the you know, capabilities to build such platforms in-house, or do you also have like larger organizations that work with you? >> No, we have very big clients. We have

like energy grids of countries using us. We've got top five gambling companies using us. Fintechs, of course. And then we've even got a English Premier League team that's come to us now because they're looking at this from a safeguarding angle, which if you think about it is really big, right? Safety in sports. How can we protect the youth? How can we protect women in sports? How can they raise concerns against abuse, against all kinds of bullying,

and those topics. And And we also have regulators that are coming to us saying, "Look, we are doing investigations. We need information from members of the public. They don't want to show their face to us, and we don't want to use our existing web form and inbox or email system. It's just too cumbersome and clunky." >> And and you mentioned since you mentioned the regulators, how do you view the these regulatory developments in the EU and like how would you you know how would you say that the EU

whistleblower directive compares to other similar regulatory directives in in other parts of the world? >> Yeah, it's hard to compare cuz it's very holistic and it's very game-changing the EU's directive. Um it's also not financial incentive driven, say for example like the US. Um and it and the the level and extent of protections and who it covers is quite extensive, right? It's very it goes to like interns, family members of uh executives and employees and third

parties and stuff. So, that's good. Um it's got a good It's a good start for the EU. Um then the question is how do different countries implement it locally. And of course, you have very strong um uh implementation for example by Spain where the fines are up to a million euros for non-compliance. And then you have very weak ones by big European company I mean countries like Germany who only would find you say 50,000 euros and also give you the option to be

to have anonymous reporting as optional, right? Uh and so companies can choose not to deal with cases that are anonymous, which goes against the whole idea of this thing. So, uh that's why from an implementation angle, each member state has a different approach. Uh but I think from an overarching perspective, it's really good. Um if you think about a country like Singapore, it's a financial hub. We don't have a overarching whistleblowing law at all. So, I think there's a lot of work to be done here. And then you have, for example, Malaysia which has a

whistleblowing law since for quite many years now. But in order to qualify for that law, the very first point of contact a person in a company needs to go to is the regulator or one of the enforcement agencies. If you even told your boss at the office, you don't qualify anymore. So, it's just like, you know, that these very different whistleblowing laws globally and how you qualify, do they have the right idea behind them? Is it practical? These are things that I discuss.

>> And is there is there like one specific country or, you know, like organization that you consider to be really like the role model in that space? You mentioned Spain. Uh Is there Is there Would you say that they are really have the They have the best regulation in place or is there some Is there some other countries? >> I mean, it's hard to say who has the best. And it also then boil becomes harder as you go down on a case-by-case basis because as I as I always tell companies, like not every And I also tell, you

know, control functions like lawyers, you know, auditors, compliance people, legal people, and all that stuff that you Not all whistleblowers are with clean hands, right? Not everyone has a good intention behind it. Some of these people are actually trying to blackmail companies. Some of these people are compliance experts who go into companies, they quietly take note of all the the flaws in the business, make themselves kind of

difficult to fire in the process. So, how do companies navigate with these things is also very challenging. These are topics which people don't like to discuss. But I think it's important to discuss them because if you don't [clears throat] discuss them, it actually works against real whistleblowers. Um So, ignoring them is not the solution, but actually having open conversations and finding ways to fix these issues or address them at least is is in everyone's best interest.

>> Mhm. And we just just one last question regarding the kind of like the possible future of this uh regulatory developments in the space because uh we obviously we have been paying a lot of attention to what has been happening in the United States with the the recent Trump administration kind of pushback against these anti-bribery laws talking about the foreign corrupt practices law which has been act which has been I think paused for 6 months in February 2025. Do you Do you expect to

see something similar happen in the whistleblowing regulatory space as well or have you already been seeing signs of that? >> No, because I think I think what's driving the administration currently is the fact that the US has just so much regulation in every single aspect. I mean, if you think about the tax code, it's got thousands of pages and most people can't even understand it. So, I think the the motivation behind that is to deregulate because there's just just too many of these things. I don't think

they want to get rid of it completely. I think they're just looking to find ways to make that a bit more lean and less cumbersome because if it's so cumbersome, the the cost is eventually going to be passed on to consumers, right? And the only people making money from these things will be the law firms, all the consulting firms because they would be the ones that companies need to engage, which means their compliance costs are always constantly very high. Uh so, I don't know what the plans are with

the whole FCPA and stuff. As we know with Trump something could be said today, but a few days later or sometimes even a few hours later it's changed. Uh so, it's just it's just a wait and see game uh with the current administration and even with the tariffs, right? Like everybody knew it's not going to be a long-term thing. So you know, there's a quick pause after a few days. I think also because every market was tanked.

We also saw the bond markets tank together with the stock market which is probably like an extremely rare occurrence because one's supposed to go up the other one's supposed to generally go down. And and vice versa, right? But the fact that he actually tanking both is a it's it's literally a lifetime achievement for him in that way. >> [laughter] >> But yeah, I think it's from what I what what I like to tell what my approach is and I'm very firm on this is we should never allow politics to influence our roles as legal risk

compliance people. I mean legal and compliance people. Risk of course, that's a geopolitical risk. But if you're legal if you're compliance, your job is to really understand what the existing regulations are and apply them. So whether you agree with the political motivations behind them or not, that's a philosophical question. But I think we need to be focused in advising businesses or our clients and just applying what the law of the day is

whether you like it or not. So I think that's where we need to remain focused whether it's in the whistleblowing space or in the AML space, right? That's just the reality of the situation. Do not get dragged into into the political aspect of it. >> Okay, I understood Pav. Thank you very much for joining the podcast. I really appreciate you finding the time. It's been a pleasure and I wish you the best of luck with the Comply platform and yeah, also make sure to stay away from the stock market. It's a it's a

dangerous place. >> Yeah, thanks so much for having me. Yeah, truly an honor.