"The Company serves as a call center for companies operating in the field of online financial trading (hereinafter: "Brokerage Companies"). The Company provides support services to customers of the Bruges Companies (hereinafter: the "Services"). It should be emphasized that all the services provided are fully dictated by the brokerage companies, including the method of contacting customers, the method of work, etc. The services are provided to the brokerage companies by call centers from the company's offices on Jaffa Street in Haifa. Since the company's customers are brokerage/international companies operating in markets outside of Israel, the company's employees are recruited and divided into desks according to the language they speak."
In addition, the list of the company's customers and suppliers and the addresses of the company's customers were detailed, as well as their licenses. I will note that the licenses that were attached to the companies Realentco and MPF, a printout from the CYSEC website was attached, I will also note that no license of UFX TRADE was attached, however, a valid license of UFX GLOBAL was attached. Also attached were a certificate signed by an accountant of UFX GLOBL, Mr. Tamid Madani, confirming the payment of tax and reporting to the authorities by this company, as well as confirmations of payment and reporting to the tax authorities, with the stamp of the tax authorities, of the companies Rialentco and MPF.
In addition, certificates were attached, according to which the companies pay tax lawfully (in a closed article, I will note that in the framework of the certificates, it is explicitly stated that the authorizer relies in his approval on "information presented by the company and to the best of our knowledge"). A document from Shenhav Law Firm dated November 13, 2016 regarding Paragon EX was also attached, in which the company's shareholders were detailed.
In response to the request and the transfer of all the documents detailed above, on December 13, 2016, Chen Gabbay confirmed the receipt of the documents and announced that he had forwarded them to the Compliance Department.
- On the same day - in the internal correspondence between the bank's employees, which is not reflective of the plaintiffs - there was a loaded e-mail message to Ms. Schiff Tali with a copy to Sadi Mantin Sigal regarding Chaim Toledano - in which Mr. Lotem detailed that during a meeting at the branch that took place a few days earlier, Toledano complained that the bank was not willing to accept receipts from abroad and that funds received into his personal account were returned without his approval. In the same meeting, according to Sigal, Toledano threatened her and Chen Gabbay that he would "settle scores with them." It is also detailed that afterwards, an anonymous complaint was received at the bank against Siegel, which Mr. Lotem believes is related to Mr. Toledano.
Lotem also noted in his application that: "Haim Toledano is engaged in Forex in Cyprus as well as "marketing" and "call center" for other Forex companies. The questions asked by Ms. Schiff by Lotem are: