The first documentation of such correspondence can be found on July 4, 2016, the date on which Toledano submits the approval of Paragon EX regarding the dividend and is answered by the bank that it is not an accountant's approval but rather the company's approval, and therefore, he is asked to submit an accountant's approval. Further to this request, on July 14, 2016, the approval of the accountant from Toledano was forwarded to Dganit, and this confirmation was forwarded by Chen Gabbay, on July 17, 2016, to Amos Lotem, noting that he appeared to be in good condition. On the same day, Amos Lotem replies to Chen Gabbay that: "I agree that it looks normal, to remind you that you still need to understand the sources of the money (+ the approval of an accountant/lawyer) before receiving it."
Chen Gabbay's answer to Amos Lotem, from that day, is: "The source of the money = it is to receive a dividend. From Paragonos - not the first time he has received dividends. Regarding the approval of an accountant/attorney - we checked and because it is a dividend, you do not have to pay tax immediately."
In response, Lotem responds to Chen Gabbay: "Where did the money for Fergonax come from? This is the money that needs to be understood. The tax certificate refers to the funds in the Fergonex account, were the transferred funds properly reported to the authorities and taxed on them? Obviously, if Haim Toledano puts money into his account in Israel, he will report it, but did Fragonax pay?"
There is no documentation in the bank's documentation of the contact with Toledano in this regard, and at the same time, on July 18, 2016, an e-mail message was sent as follows from Gabay Chen to Amos Lotem, with copies to Shaulzon and Ms. Sadi Mantin Sigal: "Amos is attached with a confirmation that Paragonos pays tax legally. Presented confirmation of the distribution of the dividend + attached confirmation in previous correspondence about shareholders in Fregons. From our examination, the customer is liable for tax within a month of receiving the dividend. In my opinion, a client presented everything that was required of him. Is it possible to enter the receipt? (My emphasis 32).