I will note that a restriction similar to the restriction imposed on the accountant in accordance with the rules of ethics that apply to them, also exists with regard to lawyers, and therefore, I am of the opinion that the directive as given by the Supervisor of Banks is also valid with respect to these approvals [see Decision 255/14 of the National Ethics Committee, "Rule 10: Signing Details Confirmation Forms," Professional Ethics 58 (2015); Decision 237/12 of the National Ethics Committee, "Rule 10: A lawyer must not guarantee a client's undertaking" Professional Ethics 53, 5 (2014); Decision 156/10 of the National Ethics Committee "A lawyer representing a company in a non-permanent manner who is required to issue a certificate to the bank on its behalf, Professional Ethics 41, 7 (2011);" Authentication of Documents and Minutes on Behalf of Banks" Professional Ethics 3, no. 4 (2002) - all of which were attached as Exhibit 1 to the plaintiffs' summaries].
As such, I determine that the requirement for documents in the form required by the bank is unreasonable and that it is sufficient to provide the certificates in which the lawyer or accountant confirms the information and specifies the sources of their knowledge. In this context, I find it necessary to note that I cannot accept the Bank's argument and accordingly we should not listen to the argument based on the Supervision Department's instructions or the rules of ethics, given that it was not raised in real time, and this, since these are instructions that were clarified and instructed only recently, and therefore, it is clear that they could not be relied upon in real time.
Since the aforesaid - as a starting point - has been clarified, I will detail below the documents, information and evidence as they were produced with respect to these suspicions.
Thus and first, with regard to these suspicions, documents were submitted - as detailed above - supporting the fact that Paragon E X is paying tax lawfully. Moreover, Mr. Toledano was asked why Paragon E X was incorporated in the State of Off Shore and explained that such incorporation stemmed from advice received by lawyers, and since the intention was that the company would operate with non-Israeli clients [see page 112 of the discussion of May 24, 2018, lines 20-24]