Some sources such as this U.S. Department of Commerce survey from January 1940 indicate that U.S. exports to the Third Reich dropped by as much as 97% in late 1939. Such data are highly misleading. On the contrary, U.S. capitalists employed tricks and structures in 1939 and elsewhen to prevent any possible scandals or legal action against their transactions:

The cloaking techniques in hostile countries or countries perceived to be potential enemies resembled those in neutrals. Here, too, [Fascist] firms transferred ownership to holding companies whose ownership was nominally in the hands of other institutions and individuals, who pledged, at times with written agreements, at times supported merely by oral assurances, to run the subsidiaries on behalf of the [Fascist] parent.

There were two main differences, however, between perceived neutrals and potential enemy nations. The first is that the holding company structure for companies in countries such as Britain sometimes went through a second neutral country, a cut-out, so to speak, to further confuse regulators.

The second was that [Fascist] companies, understandably, avoided holding ‘excess’ assets in those countries. In contrast to friendly or neutral countries, political issues, such as the threat of boycotts or even expropriation, provided the driving force for cloaking activities in hostile countries. This evolution will be discussed in greater detail below.

However, in all three cases, it is important to remember that the German companies depended on the approval of the Reich’s authorities. Even though it is difficult to distinguish between economically and politically motivated cloaking activities, we will show that in times of crises the latter aspect prevailed and determined the degree to which the Reich’s authorities got involved in the camouflaging process.

The holding company structures usually entailed three ‘layers’ of camouflage. First, the ownership of foreign subsidiaries was transferred to Swiss holding companies. Second, the shares of the holding company were placed in the hands of a ‘non-German’ trustee, who pledged to act in the ‘interests’ of the ‘original’ owner and transfer back the shares to the [Fascist] company or anyone else designated by the [Fascist] company.

Lastly, the [Fascist] company set up supply and royalty agreements among the subsidiaries, usually centred in the United States, which would allow the foreign subsidiaries to act independently should they be cut off from Germany. The ‘trustees’ took on this rôle with [Fascist] companies for many reasons. Some had long-standing business relationships (there are examples of [Fascist] companies doing the same for foreign firms),⁴² some hoped to develop a long-term relationship with the [Fascist] firms; others were merely paid for performing a service.⁴³

In some respects, too, these structures were remarkably successful. Even in the United States, where German assets had been seized, during the 1920s many German companies continued to get value from their trademarks and patents by working with American companies and trustees.⁴⁴ Also, in countries where foreign ownership was restricted, such as Czechoslovakia, German companies created subsidiaries.⁴⁵

After September 1939, when war broke out [against Poland], for over two years foreign subsidiaries of [Fascist] companies continued to function, sometimes even in combatant countries and their colonies, due in large part to the cloaking and supply structures set up in the United States.⁴⁶

The cloaking activities of [Fascist] firms involved a substantial amount of that country’s investment in foreign countries, but the sources are not clear about when amounts were transferred into camouflaging structures and exactly how much wealth was subject to camouflaging. The latest estimations speak of approximately 775 camouflage cases approved by the [Third Reich’s] authorities during the first six months after the war started. Around 200 to 300 of these companies can be found in Switzerland, the majority of the rest in the Netherlands.⁴⁷

In 1938, the Reichsbank estimated, however, that approximately two-thirds of the nearly U.S. $16 million in [Third Reich] assets in the United States were already cloaked. By 1940, that had climbed to U.S. $20 million of cloaked property in the United States, but this figure seems to have excluded those [Fascist] assets still officially owned by neutral parties and cloaked in the U.S. According to Reichsbank and U.S. government official estimates, by 1943, a total of approximately 130 [Reich] companies had employed camouflaging techniques accounting for U.S. $40 million in assets.⁴⁸

Some estimates are much higher (one in the U.S. Memo talked about U.S. $500 million), but it is not clear whether the Reichsbank or U.S. authorities shifted from book value to market value and to what extent they integrated the assets of companies outside of the United States. In 1945, the U.S. Alien Property Custodian administered 469 [Reich] companies, worth approximately U.S. $110 million.⁴⁹ Even in Argentina, whose overall economy was by comparison far smaller, the British Embassy estimated that the value of [Reich] assets in 1945 was around U.S. $100 million.⁵⁰

According to Aalders and Wiebes, who quote a 1947 source, Switzerland was holding U.S. $250 million in cloaked assets, Sweden U.S. $105 million, Spain U.S. $90 million, and Portugal U.S. $27 million, but given the overlapping and integrated holding structures, it is impossible to know the basis of the valuations and how much double counting was involved.⁵¹