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After the Nazis were finally defeated, many of the surviving children had come to Switzerland in search of their family’s secret bank accounts. But they had no way to prove that they had any rights to them. After all, there were no names tied to the accounts, only numbers. Unless the surviving children knew exactly in which bank their parents had kept their money and precisely which banker they had been doing business with, there was no possible way for them to lay claim to the money. To this very day, billions upon billions of dollars were still unaccounted for.

And then my mind wandered to a darker side. How many of these Swiss bastards had known exactly who the surviving children were but chose not to seek them out? Even worse—how many Jewish children whose entire families had been wiped out had shown up at the correct Swiss bank, and had spoken to the correct Swiss banker, only to be lied to? God!What a fucking tragedy! Only the most noble of the Swiss bankers would have had the integrity to make sure that the rightful heirs received what had been left for them. And in Zurich—which was full of fucking Krauts—you would be hard-pressed to find many Jew-lovers. Perhaps in French Geneva things had been a bit better, but only a bit. Human nature was human nature. And all that Jewish money had been lost forever, absorbed into the very Swiss banking system itself, enriching this tiny country beyond imagination, which probably accounted for the lack of beggars on the streets.

“…and so you see why,” said Saurel, “it is now required that every account opened in Switzerland has a beneficial owner attached to it. There is no exception.”

I looked over at Danny. He nodded imperceptibly. But the unspoken message was: “This is a fucking nightmare.”

On the ride back to the hotel, Danny and I hardly exchanged a word. I stared out the window and saw nothing but the ghosts of a few million dead Jews, still searching for their money. By now the back of my leg was literally on fire. Christ! If only I wasn’t in such terrible chronic pain I could probably beat my drug habit. I was feeling sharp as a tack. It had been more than twenty-four hours since I’d taken any pill, and my mind was so acute I felt like I could work through any problem, no matter how insurmountable it might seem. But how could I work around Swiss banking laws? The law was the law, and having watched Al Abrams go down had only served to reinforce that age-old cliché of how ignorance of the law is no excuse for breaking it. The simple fact was that if I were to open an account with Union Bancaire, I would have to give them a copy of my passport, which would then be kept on file at the bank. And if the U.S. Department of Justice issued a criminal subpoena related to stock fraud—which, of course, was also a crime in Switzerland—then my goose would be cooked. Even if the feds didn’t know which account was mine or, for that matter, which bank I was doing business with, it still wouldn’t slow them down. Their subpoena would go directly to the Swiss Department of Justice, which would then send out a blanket request to every Swiss bank in the country, demanding that they turn over all records for any accounts belonging to the individual referenced in the subpoena.

And that would be that.

Christ—I would be better off sticking with my own ratholes in the United States. At least if they were ever subpoenaed they could simply lie under oath! It wasn’t a pleasant thought, but at least there was no paper trail.

Wait a second! Who said that I had to give the bank mypassport? What was to stop me from having one of my ratholes come to Switzerland and open an account with their passport? What were the chances that the FBI would hit upon the name of my U.S. rathole within my Swiss rathole? It was a rathole within a rathole! A double layer of protection! If the United States issued a subpoena for records relating to Jordan Belfort, the Swiss Department of Justice would send out their request and come up with nothing!

And now that I thought about it, why would I even want to use one of my current ratholes? In the past I had chosen my ratholes based not only on their trustworthiness but also on their ability to generate large amounts of cash in ways that wouldn’t alert the IRS. That was a difficult combination to find. My primary rathole was Elliot Lavigne—who was rapidly turning into a nightmare on Elm Street. Not only was he my primary rathole but he was also the man responsible for introducing me to Quaaludes. He was the President of Perry Ellis, one of America’s largest clothing manufacturers. But this exalted position of his was slightly misleading. In point of fact, he was ten times crazier than Danny. Yes, as impossible as it might seem, next to him, Danny was a choirboy.

Besides being a compulsive gambler and a drug addict of the highest order, Elliot was also a sex fiend and a compulsive marital cheat. He was stealing millions of dollars a year from Perry Ellis—having secret deals with his overseas factories, which were overcharging Perry Ellis an extra dollar or two per garment and then kicking back that cash to Elliot. The numbers were in the millions. When I made Elliot money in new issues, he would then settle up with me using the very cash he had received from his overseas factories. It was a perfect exchange; no paper trail to be found anywhere. But Elliot was starting to go bad on me. His gambling and drug habits were getting the best of him. He was falling behind on his payments to me. As of now he owed me almost $2 million in back profits from having ratholed new issues for me. But if I were to cut him off completely, I would lose that money for sure. So I was in the process of slowly phasing him out, continuing to make him money in new issues while he paid down his debt.

In spite of that, Elliot had served his purpose well. He had kicked me back more than $5 million in cash, which was now safely tucked away in safe-deposit boxes in the United States. Just how I was going to get all that money over to Switzerland, I still wasn’t so sure—although I had some ideas. I would discuss that matter with Saurel when we met in a few hours. Anyway, I had always assumed that replacing Elliot with another rathole who could generate that much cash without leaving a paper trail was going to be a problem. But now, having Switzerland as my primary rathole layer, the issue of generating “clean” cash would no longer be a concern. I would simply keep the money in my Swiss account and let it collect interest. The only issue I hadn’t been able to address at today’s meeting was how I was supposed to go about using all the money I would be keeping in my Swiss account. How was I supposed to spend any of it? How would I be able to funnel the post-laundered money back into the United States to make investments? There were still many questions to be answered.

But the most important thing was that by using Switzerland, I could now choose my ratholes based solely on trustworthiness. This opened up a much larger universe of prospective ratholes, and my mind quickly turned to my wife’s family. None of them were U.S. citizens; they all lived in Great Britain—outside the prying eyes of the FBI. In fact, there was a little-known exemption in the federal securities laws that allowed non-U.S. citizens to invest in public companies under much more favorable terms than U.S. citizens. It was called Regulation S, and it allowed foreigners to buy private stock in public companies, while avoiding the two-year holding period required under Rule 144. Instead, under Regulation S, a foreigner had to hold their stock for only forty days. It was a ridiculous law, giving foreigners an incredible advantage over U.S. investors. In consequence—like most regulatory brain farts—it had resulted in a massive wave of abuse, as savvy U.S. investors struck up under-the-table deals with foreigners and illegally used Regulation S to make private investments in public companies, without having to wait two full years to sell their stock (under Rule 144). I had been approached numerous times by foreigners who, for a modest fee, had offered to act as my nominee—allowing me to use their non-U.S. citizenship to do Regulation S business. But I had always declined. Al Abrams’s warning was in the back of my mind, always. And, besides, how on earth was I supposed to trust some foreigner with something so inherently illegal? After all, using a foreign nominee to do a Regulation S stock purchase was a serious criminal offense, one that was sure to tweak the interest of the FBI. So I had always shied away from it.