London Stock Exchange Group (LSEG) has launched its blockchain-based Digital Markets Infrastructure (DMI) and completed the first live fundraising for a private fund. On the same day, Trade Republic unveiled a move from brokerage to wealth management, giving retail clients access to private markets from €1 via partnerships with Apollo and EQT with monthly sell windows on an internal marketplace. Together, these initiatives signal Europe’s acceleration toward DLT-enabled private markets across institutional rails and retail distribution (Sources: Businesswire.com, lseg.com). Key Points LSEG DMI (institutional rails): A Microsoft Azure-powered DLT platform covering the full asset lifecycle (issuance, tokenisation, distribution, post-trade servicing) for private funds; first transaction completed with MembersCap; Archax among the first participants; discovery via LSEG Workspace; secondaries are on the roadmap (Sources: MarketScreener.com) Trade Republic Private Markets (retail on-ramp): TR expands into wealth management; clients can invest from €1 in Apollo/EQT strategies with monthly liquidity via an internal marketplace; company cites 10M customers and €150B AUM (Source: businesswire.com). Two strategies, one trend: LSEG is building neutral market infrastructure for GPs/LPs; TR is packaging fractional private-markets exposure for retail in an app-native UX. Both target scale and liquidity in historically illiquid markets. Short Narrative LSEG’s DMI positions the group as the first major exchange operator with an end-to-end blockchain system aimed at the operational pain points of private markets—manual workflows, costly administration, and slow settlement. The inaugural deal with MembersCap gives the platform proof of life and a template for primary fundraising on chain. Trade Republic, by contrast, tackles the distribution problem: lowering ticket sizes to €1, offering monthly exit windows, and outsourcing asset selection to top-tier GPs (Apollo, EQT). The result is a complementary push—institutional plumbing from LSEG and mass-market packaging from TR (Source: ft.com) Extended Analysis Infrastructure vs. product. LSEG DMI is an infrastructure play: regulated workflows, permissioned access, and integration with Workspace to match GPs and professional investors. Running on Azure addresses scalability and enterprise governance, while planned secondary capabilities aim to unlock liquidity beyond primary issuance. Early participants include MembersCap and Archax (FCA-regulated digital asset venue), with press commentary noting a major web3 foundation as an investor in the first raise. MarketScreener+2lseg.com+2 Trade Republic is a distribution/UX play: it extends beyond brokerage into wealth, using fractionalisation and an internal monthly marketplace to reconcile retail liquidity expectations with inherently illiquid assets. The Apollo/EQT partnerships bring brand, origination, and portfolio management credibility; governance (suitability, disclosures, fee clarity) will be critical under EU rules (MiFID II/PRIIPs/AIFMD). businesswire.com Why it matters for crypto & tokenisation Normalising enterprise tokenisation: DMI advances blockchain from pilots to live, regulated market infrastructure for private funds—key for institutional adoption of tokenised RWAs. Reuters+1 Retail democratisation—carefully: TR’s model showcases fractional private-markets access with scheduled liquidity—potentially a template for broader retail distribution, provided risk labelling and valuation cadence are robust. businesswire.com Liquidity is the bottleneck: LSEG’s forthcoming Secondaries and TR’s monthly windows are different answers to the same question: credible price discovery and orderly exits in assets designed to be illiquid. Execution quality (valuation methods, market-making, cut-offs) will determine investor trust. lseg.com+1 Comparative Snapshot Target users: LSEG → GPs/LPs, institutions; TR → retail/wealth clients. lseg.com+1 Value prop: LSEG → cost/time efficiency & compliance-grade rails; TR → low minimums, branded strategies, scheduled liquidity. MarketScreener+1 Scalability levers: LSEG → Workspace distribution + interoperability; TR → app reach (10M users) + partnerships. lseg.com+1 Call for Information We’re collecting practitioner feedback on onboarding, valuation cadence, liquidity windows, and fee transparency for both DMI and TR’s Private Markets. Insiders or early users: what works—and what doesn’t—in live operations? (Submit securely via Whistle42.) Share Information via Whistle42

A federal jury in Miami convicted Carl Alan Zaglin (70), owner/CEO of Atlanco LLC (Georgia), for orchestrating a nearly five-year scheme to bribe Honduran officials to win >$10 million in police-uniform contracts and to launder the bribe proceeds through U.S. and offshore accounts. Counts: Foreign Corrupt Practices Act (FCPA) conspiracy, substantive FCPA, and money-laundering conspiracy. Max penalties: 5 years (each FCPA count) and 20 years (laundering). Co-conspirators Aldo Nestor Marchena, former TASA officials Francisco Roberto Cosenza Centeno and Juan Ramon Molina previously pleaded guilty (Source: justice.gov). Key Points Scheme (2015–2019): Bribes (via “commissions/fees”) funneled through Marchena to Honduran officials at TASA, securing >$10m in contracts for uniforms/accessories; payments masked with sham invoices/“Brokerage Agreements.” Money Flows: From Atlanco → Marchena front company (U.S.) → accounts for officials in the U.S., Belize, elsewhere; coded comms and encrypted apps used. Charges & Exposure: FCPA conspiracy + FCPA (max 5 + 5 years) and laundering conspiracy (max 20 years); sentencing to follow under U.S. Guidelines. Enforcement Footprint: Case investigated by HSI Miami with assistance from Belize, Colombia, Spain; DOJ Fraud Section notes ongoing FCPA/FEPA focus. Why it matters (Compliance Angle) Confirms DOJ’s continued pursuit of third-party intermediary bribery and tradecraft (coded language, encrypted channels, sham contracts). Highlights cross-border cooperation and money-laundering tethers as leverage points for prosecution, not just bribery counts. What to Watch Sentencing timeline and whether forfeiture/restitution is sought. Potential debarment/procurement consequences and any collateral export/compliance reviews tied to law-enforcement supply chains. Call for Information FinTelegram invites tips on money laundering cases via our secure whistleblower platform Whistle42. Share Information via Whistle42

AInvest (website) is a New York-based AI-powered investment and trading platform operated by Ainvest Fintech Inc. and Light Horse Securities, Inc., focusing on delivering financial tools, analysis, and market insights for individual investors and traders using artificial intelligence. We asked AInvest for its opinion on the Gemini IPO. Here is its well-founded opinion: The Gemini IPO represents a pivotal moment in the crypto industry, signaling strong institutional confidence and strategic alignment with regulatory frameworks. With a $425 million raise and 20x oversubscription, Gemini has positioned itself as a regulated infrastructure leader in the digital asset space. However, its high valuation ($3.3 billion) and operational challenges (e.g., net losses, competition) warrant cautious optimism. The Winklevoss twins’ $1 million Bitcoin thesis adds speculative appeal, but long-term success hinges on institutional adoption and regulatory clarity. Analysis 1. Financial Performance & Market Context Gemini’s IPO highlights a $3.3 billion valuation, driven by 20x oversubscription and $425 million proceeds. The company reported $142.17 million in revenue and a $158.55 million net loss in 2024-2025, reflecting ongoing operational challenges. Metric2024Q4-2025H1Total Revenue$142.17MNet Loss-$158.55MOperating Expenses$159.42M Key Takeaway: Gemini’s financials align with early-stage crypto infrastructure firms, emphasizing growth over profitability. 2. Strategic Positioning Gemini’s regulated custody services and institutional focus (10,000+ clients, $21B assets under custody)78 differentiate it from retail-focused platforms like Coinbase. The Winklevoss brothers’ “Bitcoin as Gold 2.0” narrative ties Gemini’s success to long-term crypto adoption. Competitor ComparisonGeminiCoinbaseBitGoMarket Cap (2025)$3.3B$83BN/ARevenue (2025H1)$68.6M$1.2BN/AAssets Under Custody$21B$100B+$18B Key Takeaway: Gemini’s niche in regulated custody and tokenization23 offers defensible competitive advantages. 3. Risks & Challenges Regulatory Uncertainty: Despite Nasdaq’s $50M investment, crypto firms face ongoing SEC scrutiny. Competition: Larger exchanges like Coinbase and Binance dominate retail trading and market share. High Valuation: Gemini’s P/S ratio (~20x) exceeds peers like Coinbase (~12x), raising valuation concerns. 4. Future Outlook The Winklevoss twins’ $1 million Bitcoin thesis hinges on gold market cap displacement ($10T+). Gemini’s IPO success signals institutional validation, but sustained growth requires product innovation (e.g., tokenization, crypto rewards)23 and regulatory alignment. Conclusion Gemini’s IPO marks a milestone for regulated crypto infrastructure, but its high valuation and operational risks demand prudent investment. The Winklevoss twins’ visionary narrative adds speculative appeal, but long-term success depends on institutional adoption and regulatory stability. Share Information via Whistle42

Why this matters now: Stablecoin giant Tether says Anchorage Digital Bank, N.A will issue its new U.S.-regulated, GENIUS-compliant stablecoin USA₮. — the only U.S. national (OCC-chartered) crypto bank. This positions Anchorage at the center of on-shore stablecoin issuance just as U.S. policy (GENIUS Act) and institutional demand converge (Source: tether.io). Read our report on the USAT launch here. Who owns Anchorage & what it does Anchorage Digital is a privately held group founded in 2017 by Nathan McCauley (CEO) and Diogo Mónica (President). At the holding-company level it has been backed by KKR (Series D lead), a16z, Goldman Sachs, GIC, Visa and others; the Series D (Dec-2021) valued the business at >$3bn. The operating bank, Anchorage Digital Bank, N.A., is a federally chartered national trust bank regulated by the OCC (Sources: anchorage.com) Core activities: institutional qualified custody, trading/prime brokerage, staking & governance, settlement, and white-label stablecoin issuance—now including the USA₮ mandate. The firm also runs regulated entities in New York (BitLicense) and Singapore (MAS Major Payment Institution) to serve global clients (Source: anchorage.com). Regulatory status: OCC granted the national trust charter in 2021; a 2022 OCC consent order relating to BSA/AML has since been terminated (Aug-18, 2025) after remediation (Sources: OCC.gov+1). Scale & relationships: Anchorage cites “tens of billions” of assets under custody and has been added to BlackRock’s crypto custody network in 2025—both notable signals for institutional diligence. Quick view — Summary table TopicSnapshotTrading nameAnchorage DigitalWebsitewww.anchorage.comLegal entitiesAnchorage Digital Bank, N.AAnchor Labs, IncAnchorage Hold, LLCAnchorage Lending CA, LLCAnchorage Services, LLCCharter / RegulatorNational trust bank (OCC); consent order terminated 18 Aug 2025.Business linesInstitutional custody, trading/prime, staking, settlement, stablecoin issuance (white-label).Investors / Valuation$350m Series D (Dec-2021) led by KKR; valuation >$3bn.Key licensesOCC national trust, NYDFS BitLicense (Dec-2024), MAS Major Payment Institution (Nov-2024).Role in USA₮Issuer of Tether’s planned GENIUS-compliant USA₮; Cantor Fitzgerald to safeguard reserves. Scale signals“Tens of billions” AUC; BlackRock added Anchorage as a custodian (Apr-2025). Competitive landscape (U.S.) Crypto-native custodians / trust companies Coinbase Custody Trust (NYDFS limited-purpose trust) — scale, exchange adjacency. coinbase.com+1 BitGo Trust (SD & NY trusts) — long-standing institutional custody. sec.gov+1 Paxos Trust (NYDFS) — regulated issuer of USDP/PYUSD; seeking national trust charter. paxos.com+1 Fidelity Digital Asset Services (NYDFS trust) — TradFi brand, institutional focus. fidelitydigitalassets.com+1 Global custodians entering crypto BNY Mellon — U.S. digital-asset custody live since 2022; expanding tokenization services. bny.com+1 Anchorage’s edge vs peers: the only OCC-chartered national trust bank today (federal preemption/standards), plus multi-jurisdiction coverage (NYDFS BitLicense; MAS license) and now stablecoin issuance at scale via USA₮. OCC.gov+2anchorage.com+2 Is there a similar “crypto bank” in the EU? Not quite in the same legal sense. The EU lacks a single federal bank charter; instead, banks or EMIs operate under national licenses passported across the EU. Several EU banks now hold crypto custody licenses (notably Commerzbank under BaFin; Coinbase Germany was first to get BaFin’s crypto custody license; Deutsche Bank has applied and is preparing a launch). But none mirrors Anchorage’s U.S. national trust bank status. On stablecoins, Circle is MiCA-compliant via a French EMI; AllUnity (DWS JV) has BaFin approval to issue a euro stablecoin. Tether has not announced a MiCA-compliant coin. Reuters+4commerzbank.de+4coindesk.com+4 Strategic read-through: USA₮ + Anchorage For Anchorage: Becoming USA₮ issuer could accelerate stablecoin-as-a-service revenues (issuance, compliance ops, treasury/settlement flows) and deepen relationships with exchanges, broker-dealers, and banks that prefer a GENIUS-compliant rail. The fresh termination of the OCC order removes a headline overhang; combined with BitLicense and MAS coverage, Anchorage is well-positioned to intermediate on-shore dollars while maintaining global connectivity. anchorage.com+3tether.io+3OCC.gov+3 For the market: USA₮ introduces a two-brand Tether (USDT offshore / USA₮ on-shore). Competitively, this pressures USDC and prompts other issuers (e.g., Paxos) to seek federal charters. Expect fee/margin compression in custody/issuance as regulated capacity expands. Reuters Bottom line Anchorage is moving from “custody-first” to infrastructure linchpin for U.S.-regulated stablecoins. With a unique federal bank charter, cleaned-up supervisory posture, and marquee relationships, it’s well placed to capture USA₮-driven flows and adjacent institutional business—while facing capable competitors (Coinbase, BitGo, Fidelity, BNY, Paxos). In the EU, no true analogue exists, though BaFin-licensed banks narrow the gap. Execution around USA₮ and continued regulator-grade controls will determine how much of this opportunity converts into durable economics. Share Information via Whistle42

Tether has announced the upcoming launch of USA₮, a new stablecoin specifically designed to comply with the recently enacted GENIUS Act, representing a decisive move to align with U.S. regulatory standards for stablecoin issuance. Tether remains the dominant player in the global stablecoin market through its flagship product, USDT, but has not yet announced a MiCA-compliant stablecoin for the European market. Background and Market Position USA₮ website: https://usat.io/ Tether is the world’s largest stablecoin issuer, with USDT boasting a market capitalization above $169 billion and serving as the primary infrastructure for the digital asset economy. USDT is widely used in emerging markets, digital commerce, and crypto trading, dramatically outpacing competitors such as Circle‘s USDC. Tether is among the largest individual holders of U.S. Treasuries and reported profitability exceeding $13 billion in 2024. GENIUS Act Compliance and USA₮ Launch USA₮ will be issued by Anchorage Digital Bank, a federally regulated U.S. crypto bank, and backed by reserves managed by Cantor Fitzgerald. GENIUS Act mandates full reserve backing (with liquid dollar assets and Treasury securities) and monthly public disclosure of reserve composition, aiming to enhance transparency and regulatory trust. Bo Hines, a former White House Crypto Council director, is named CEO of Tether USA₮, highlighting Tether’s commitment to compliant governance and American regulatory alignment. Industry Impact Regulated on-shore rail: USA₮ gives exchanges, brokers, and fintechs a GENIUS-compliant option from the market leader—potentially diverting share from USDC in the U.S. and narrowing Circle’s “regulatory premium.” Early read-throughs already hit Circle’s stock. The move is likely to intensify competition with other regulated issuers (Circle, Paxos, Ripple) and could bolster dollar dominance in blockchain payments, especially in institutional financial services. Transparent U.S. regulation and compliance may attract more institutional adoption and support the evolution of stablecoins toward broader financial use. MiCA Compliance Status Tether has not announced a MiCA-compliant stablecoin. Multiple analyses confirm that Tether and USDT do not meet Europe’s MiCA requirements—which include European licensing, EU-based reserve holdings, and high disclosure standards—resulting in EU exchanges preparing to delist USDT or restrict access. Most of Tether’s business remains focused outside the EU, and its regulatory strategy is centered on U.S. compliance for now. Summary Table: StablecoinRegulatory ComplianceMarket Cap (USD)Geographic FocusUSDT (Tether)Foreign, not GENIUS/MiCA$169B+Global, non-EUUSA₮ (planned)GENIUS Act (U.S.)Launch pendingU.S. residentsMiCA-compliantNot announcedN/AN/A Bottom line: USA₮ is Tether’s long-awaited answer to “on-shore, fully regulated dollars.” If execution matches the announcement—issuer clarity via Anchorage, robust attestations, transparent reserves under Cantor—Tether could defend dominance in a GENIUS-era market and pressure competitors that previously benefited from a regulatory moat. For the global crypto stack, it signals a shift from “one size fits all USDT” to jurisdiction-specific stablecoins coexisting under different rulebooks. tether.io+1 One-liner for decision-makers: Expect faster U.S. institutional onboarding to Tether rails—if USA₮ ships as specified and passes compliance diligence; in the EU, absence of a MiCA variant keeps Tether on the sidelines for now. Share Information via Whistle42

Headline Take Gemini’s Nasdaq debut is a sentiment barometer for regulated exchanges. Pricing above range at $28, the deal raised ~$425m and opened ~32% higher, implying $3.3–$4.4bn valuation range on day one. That pop says “risk‑on,” but the financials (H1 loss, leverage) say “show me” (Source: Reuters+1). Key Facts (Gemini) Offer/Valuation: Priced at $28, ~$425m raised on ~15.2m shares; oversubscribed >20x; day‑one trading opened at $37.01, with intraday highs mid‑40s; debut valuation cited ~$4.4bn (Sources: Reuters+2Reuters+2). Strategic investor: Nasdaq committed $50m in a parallel private placement tied to product collaboration (custody/collateral) (Sources: coindesk.com). Financial profile (recent): H1‑2025 loss of ~$282.5m; liabilities reported in the low‑$2bn area pre‑IPO in media summaries. Execution path to profitability is the core overhang (Sources: Reuters). Market Context Crypto listings have returned: Bullish (NYSE) debuted strongly in Aug, peaking intraday >150% and implying ~$13.2bn value; Circle (NYSE) priced at $31, opened at $69, closed day‑one at $83.23 after a $1.05bn raise. Momentum is real (Sources: Reuters+2Reuters+2). Coinbase remains the benchmark: Q2‑2025 $1.5bn revenue; $1.4bn GAAP net income helped by gains; $512m Adj. EBITDA; massive balance‑sheet liquidity (Sources: s27.q4cdn.com). Comparative Snapshot (Gemini vs Coinbase, Bullish, Circle) IPO timing & size Gemini (GEMI, Nasdaq) — Sept 2025; $425m primary; >20x covered; open +32% (Sources: Reuters+1). Bullish (BLSH, NYSE) — Aug 2025; $1.11bn raised; debut implied ~$13.2bn valuation; stock >100% intraday (Sources: Reuters). Circle (CRCL, NYSE) — June 2025; $1.05bn raised at $31; opened $69; day‑one close $83.23; fully diluted value ~$18bn referenced (Sources: Reuters+1). Coinbase (COIN, Nasdaq) — Direct listing 2021; current comp used for scale and profitability optics; Q2‑2025 revenue $1.5bn, Adj. EBITDA $512m (Sources: s27.q4cdn.com). Business mix / positioning Gemini — Retail & institutional exchange, custody, staking, card; “compliance‑first” brand; fresh strategic tie‑in with Nasdaq infra (Sources: coindesk.com). Coinbase — Large, diversified flywheel (spot, derivatives, USDC economics, Base L2, custody); scale leadership in revenues and liquidity (Sources: s27.q4cdn.com). Bullish — Institutional‑heavy model; licensing push (BitLicense); proceeds partly into stablecoins; NYSE debut signals appetite for insto‑centric venues (Sources: Reuters). Circle — Stablecoin issuer (USDC); equity now a liquid proxy for stablecoin infrastructure; IPO pop reflected demand for regulated stablecoin exposure(Sources: Reuters). Regulatory signaling Gemini — IPO plus Nasdaq investment = strong TradFi bridge; must still prove operating leverage under U.S./global rules(Sources: coindesk.com). Coinbase — Positioned to benefit from U.S. policy milestones (e.g., GENIUS/CLARITY references in Q2 letter) and USDC tailwinds (Sources: s27.q4cdn.com). Bullish — Institutional compliance stance; licensing in NY (BitLicense) underway; CEO pedigree (ex‑NYSE) (Sources: Reuters). Circle — First listed stablecoin issuer; set valuation benchmarks for “regulated money” rails (Sources: Reuters). What the comps say about Gemini’s setup Where Gemini looks strong Signal value: A successful, oversubscribed listing with a Nasdaq tie‑in enhances customer/institutional trust and partner sales cycles. Product adjacencies: Custody, staking, card, and pending growth in EU/intl markets provide multiple levers (comparable to, albeit smaller than, Coinbase’s mix). Where the bar is high Profitability & scale: Coinbase’s Q2 print underscores the gulf in operating scale and cash generation; investors will demand visible paths from Gemini to positive unit economics. Peer momentum: Bullish and Circle both executed blockbuster debuts, setting aggressive comp multiples for crypto infra and insto exchanges; Gemini must defend its valuation with growth. Risks to watch (all four names) Regulation is still the king‑maker — Ongoing rule changes (U.S. and EU) can reshape economics (staking, stablecoins, derivatives, custody). Coinbase explicitly frames policy tailwinds; others must keep pace (Sources: s27.q4cdn.com). Fee compression & mix shifts — Competition (retail vs insto) plus “stablecoin yield economics” cyclicality can whipsaw revenues across the group (Sources: s27.q4cdn.com). Balance‑sheet/operational shocks — Data/security incidents, counterparty failures, or legal actions can move multiples quickly (sector‑wide lesson since 2022) (Sources: s27.q4cdn.com). Bottom Line Views Gemini (GEMI) — Constructive but selective. The IPO pop and Nasdaq partnership are legitimacy wins; however, H1 losses and leverage mean execution risk is front‑and‑center. For fundamental investors, we’d build a position on weakness contingent on evidence of revenue traction and opex control over the next 2–3 quarters. For event‑driven traders, volatility offers opportunity. Coinbase (COIN) — Best‑in‑class comp. Scale, diversified revenue (incl. USDC), and operating cash generation keep it the sector benchmark — albeit with macro/crypto beta. Bullish (BLSH) — Institutional pure‑play re‑rated. Strong debut/valuation; now must translate licensing and treasury strategy into recurring, less cyclical revenue. Circle (CRCL) — Stablecoin equity proxy. The IPO re‑priced “regulated digital cash” infrastructure upward; competitive dynamics (new regulated stables) are the next test, but Circle set the valuation marker. Key Peer Multiples & Metrics PeerRecent Revenue / Key MetricsValuation or IPO ValuationEV / Revenue (“EV/Sales”) or similar relevant multipleCoinbase (COIN)TTM revenue ≈ US$7.0‑7.1 billion as of mid‑2025. Market capitalization + enterprise value at current levels; profitable / positive EBITDA. EV / Revenue ≈ 10‑11× currently (about 11.1× by some sources). Circle (CRCL)Q2‑2025 revenue ≈ US$658 million, growing ~50+% YoY. FY 2024 revenue ≈ US$1.66 billion from stablecoin reserve interest, subscriptions etc. IPO valuation up to US$~6.9‑7.2 billion fully diluted. Implied EV / Revenue multiple likely in mid‑single digits to low double‑digits, depending on growth & margin expectations. (Exact multiple less consistently reported)Bullish (BLSH)Revenue (recent/trailing) is much smaller; e.g. one source says ~$200 million annualised revenue vs losses of ~$369 million trailing. IPO valuation: ~$5.4 billion equity value on first trading day. Thus EV / Revenue multiple ≫ Coinbase’s — likely in 15×‑25×+ territory (depending on margin, growth expectations) because of much smaller base and high growth expectations.Gemini (post IPO)H1 2025 revenue ~US$68.6 million (vs ~US$74.3 million in H1 2024) and net loss ~US$282.5 million. FY 2024 revenue ~US$142.2 million. IPO valuation non‑diluted: ~US$3.33‑4.4 billion, as per opening price jump etc. Preliminary Opinion The IPO pricing already seems to reflect something between a base and mild‑bull expectation — investors are betting that Gemini will achieve substantial growth, but also that risk is discounted via the loss profile and liability exposure. If we were modelling a fair target price, I would peg Gemini in the US$8‑12 billion equity value range under base case over 12‑18 months (i.e. EV somewhere around US$10‑20B depending on margin improvements), assuming no major regulatory setbacks. The bull case might push that much higher, but with much more risk. For those evaluating GEMI now: there is potential upside, but also risk of multiple compression. If revenue growth lags, or losses persist or regulatory setbacks emerge, the stock could underperform those peer names. Share Information via Whistle42

What happened: The U.S. Justice Department (DOJ) unsealed an indictment in the Eastern District of Virginia charging Lai Kui Sen, co‑CEO of Ostin Technology Group Co. Ltd. (NASDAQ: OST), and Yan Zhao (aka “Hank Shi/Hank Shu”), a financial advisor, with orchestrating a $100+ million securities fraud scheme that targeted U.S. retail investors between April–June 2025. OST is a Cayman Islands company with its principal operations in China. DOJ says the pair funneled tens of millions of OST shares to select insiders via non‑bona fide transactions—including one transfer of >70 million shares for no payment—then pumped the price through coordinated social‑media hype before dumping into the spike. On June 26, 2025, OST’s market cap allegedly collapsed by >94% (~$950 million). (Source: justice.gov) Key points (why it matters): The scheme: Allocate cheap/zero‑cost OST stock to a tight circle; launch a deceptive social‑media “buying momentum” campaign (including impersonating investment advisers); dump into retail demand. Proceeds claimed: >$110 million. Charges: Conspiracy to commit securities and wire fraud; substantive securities fraud (Titles 18 & 15) and wire fraud. Max penalties: up to 25 years (Title 18 securities fraud) and 20 years for the other counts (per count). Sentencing will follow U.S. Guidelines (Sources: justice.gov+1). Issuer context: OST—a Cayman holding company with principal ops in China—previously used a VIE structure common to China‑based listings. NASDAQ‑listed. Market integrity note: DOJ says nearly $10 million has already been seized from co‑conspirators’ accounts; the FBI and SEC‑OIG investigated, with FINRA’s Market Abuse group providing a referral. Short narrative (what regulators allege): According to DOJ, Sen and Zhao first siphoned OST shares to about 15 co‑conspirators through two sham transactions. On April 15, 2025—the day the first discounted tranche landed—a fraudulent promo blitz kicked off to inflate price and volume. Brokerage accounts were opened for select investors to unload the paper into artificially stoked demand. When the music stopped, retail bag‑holders absorbed the damage as OST’s value cratered on June 26, 2025 (Source: justice.gov). Regulatory/Enforcement angle (FinTelegram view): The case underscores a cross‑border enforcement push against social‑media‑driven microcap manipulation involving foreign issuers listed in the U.S. The involvement of SEC‑OIG and a FINRA surveillance referral signals deep market‑abuse tooling behind the scenes. Expect parallel civil action potential (SEC) and asset‑tracing to claw back proceeds. For platforms and promoters, impersonation and undisclosed paid hype remain high‑risk conduct that draws rapid attention from DOJ/FBI/SEC. (Inference based on DOJ language and prior practice.) What’s next: Case posture: Indictment unsealed Sept 12, 2025 in EDVA. Defendants are presumed innocent; sentencing exposure is substantial if convicted. Monitor for detention, extradition issues, and any SEC parallel filing. justice.gov+1 Issuer risk watchlist: Liquidity, trading halts, corporate disclosures, and any board/auditor updates should be tracked closely by investors and counterparties. (Market note.) Call for information (FinTelegram): Were you solicited to buy OST via social media, newsletters, or “advisor” messages between April–June 2025? Do you hold docs, chats, wallet trails, or payment receipts related to OST promotions or stock transfers? Contact FinTelegram confidentially. (Referencing DOJ’s victim notice page for affected investors.) justice.gov Share Information via Whistle42 Sources: U.S. DOJ Office of Public Affairs press release (Sept 12, 2025); U.S. Attorney’s Office, EDVA summary. justice.gov+1

Executive Summary The Danish-based crypto payment provider Swapped, co-founded and headed by Thomas Franklin, has established itself not as a mere payment facilitator, but as the central nervous system enabling GamDom’s illegal gambling operations across Europe. Through its sophisticated Swapped Connect platform, the company provides a turnkey solution that transforms regulated crypto exchanges into unwitting accomplices in money laundering and regulatory evasion on an industrial scale. The Architecture of Illegal Gambling: Swapped Connect’s Seamless Integration The €5 Million GamDom Fine A €5 million fine against Smein Hosting B.V. (GamDom) was issued in 2023 by Spain’s Directorate General for the Regulation of Gambling (DGOJ) as part of a sweeping crackdown on unlicensed gambling operators. In the first half of 2023, the DGOJ imposed fines of €5 million each and two-year bans on 14 unlicensed online casinos primarily domiciled in Curaçao, including Smein Hosting B.V. The penalty was among the harshest measures taken to curb black market gambling exposure in Spain, and highlighted the serious legal and financial risks such operators face across the EU when circumventing licensing and AML requirements. The Exchange Gateway System Swapped Connect (accessible via connect.swapped.com) represents one of the most sophisticated compliance evasion mechanisms discovered in the crypto gambling space. The platform directly integrates with major regulated exchanges, including Coinbase, Kraken, Binance, ByBit, and numerous others through three connection methods: Direct API Integration: Users authorize Swapped to access their exchange accounts directly API Key Connection: Customers provide API keys allowing Swapped to execute transactions on their behalf Proxy Connection: Temporary login sessions enabling immediate fund transfers The Laundering Pipeline Step 1: Regulatory BypassPlayers access GamDom and initiate deposits through Swapped‘s deeply integrated widget. The system pre-fills wallet addresses and eliminates traditional friction points that would normally trigger compliance scrutiny. Step 2: Exchange ExploitationWhen players deposit via their Coinbase, Kraken, or Binance accounts, the regulated exchanges’ KYC/AML systems see only a legitimate transaction to Swapped—completely blind to the final destination being an illegal casino. This systematically defeats the compliance controls that these regulated entities spent millions implementing. Step 3: Fiat Integration via Banking CircleFor traditional payment methods, Swapped utilizes Banking Circle S.A. (Luxembourg) with IBAN DE31202208000050484620 to process bank transfers and card payments. This adds another layer of legitimacy while obscuring the ultimate criminal purpose. Step 4: Seamless Conversion and DeliveryPurchased cryptocurrencies are automatically transferred to GamDom addresses and appear as credits in players’ gambling accounts—completing a transaction that would be impossible through direct channels due to banking and card network restrictions on gambling merchants. Swapped’s Blatant Terms of Service Violations Despite Swapped‘s merchant terms explicitly prohibiting “unlicensed gambling activities” and stating that it “does not support merchants operating in prohibited industries, including unlicensed gambling”**, the company has built its entire business model around facilitating exactly these activities. The Traffic Data Confirms the Casino Engagement Similarweb analysis reveals that in August 2025, over 8% of Swapped’s referring traffic originated from casinos and sports betting sites—a damning statistic that proves gambling facilitation is not incidental but core to their operations. Additionally, 40% of August 2025 traffic came via Kado.money, the acquired payment processor that Swapped absorbed to expand its illegal gambling reach. Regulatory Violations and Criminal Liability Multi-Jurisdictional Money Laundering United States: Violation of the Unlawful Internet Gambling Enforcement Act (UIGEA), which explicitly prohibits payment processors from facilitating restricted gambling transactions European Union: Systematic violation of AML directives and national gambling laws across all member states where GamDom operates illegally United Kingdom: Breach of Gambling Commission requirements and Money Laundering Regulations Denmark: Violation of Danish gambling licensing requirements and AML obligations under their own regulatory registration Circomventing Exchange Compliance By using Swapped Connect to mask the true nature of transactions, Swapped systematically misleads regulated crypto exchanges, causing them to unknowingly facilitate illegal gambling transactions. This constitutes: Fraudulent misrepresentation of transaction purposes Conspiracy to violate gambling laws across multiple jurisdictions Aiding and abetting unlicensed gambling operations Banking and Payment Network Fraud The use of Banking Circle accounts and traditional payment rails to process gambling-related transactions violates: Card network regulations (Visa/Mastercard prohibit gambling transactions with unlicensed operators) Banking compliance requirements under EU and Luxembourg AML laws Payment services regulations across multiple jurisdictions The Scale of the Criminal Operation Swapped is not merely a payment facilitator—it has created maybe the most sophisticated illegal gambling payment infrastructure in Europe. The deep integration with GamDom, the systematic exploitation of regulated exchanges, and the deliberate violation of its own terms of service demonstrate a criminal enterprise operating with impunity. The company’s ability to process traditional fiat payments, convert to cryptocurrency, and deliver funds to illegal gambling platforms while maintaining a veneer of regulatory compliance represents the evolution of financial crime in the digital age. Immediate Enforcement Actions Required FinTelegram calls for immediate coordinated action by global financial regulators: Immediate suspension of all Swapped operations and freezing of company accounts Criminal investigation of Swapped executives for money laundering conspiracy Regulatory action against Banking Circle for facilitating illegal gambling transactions Exchange compliance reviews of Coinbase, Kraken, Binance integration policies Seizure of all GamDom-related cryptocurrency wallets and fiat accounts Swapped Key Data CategoryDetailsWebsite/Domainswapped.com, connect.swapped.com, kado.money (redirects to Swapped)Social MediaX: @swappedcomLinkedIn: Swapped.comLegal Entities(Network)Swapped ApS (Denmark, registered 43326922)Kado Software Inc. (acquired, USA)Banking Circle S.A. (Luxembourg – payment intermediary, not owned)Local operational subsidiaries as needed in EuropeIndividualsCEO: Thomas Franklin (LinkedIn)Head of US Operations (ex-Kado): Emery Andrew (Crunchbase)Other directors: See Danish registry for full recordsJurisdictionsDenmark (Headquarters, Swapped ApS registered)Luxembourg (Banking Circle banking partner)USA (Kado acquisition, product operations)UK & EU operational coverageRegulationRegistered with Danish FSA as crypto service provider (public registry)Utilizes regulated partners (Banking Circle, IBANs)Subject to PSD2, AMLD5, GDPR in EuropeTerms prohibit unlicensed gambling, but evidence shows facilitation of illegal gambling is ongoing We sent Swapped a list of questions about the findings, but have not yet received a response. Whistleblower Call to Action The scope of Swapped’s criminal facilitation network likely extends far beyond GamDom. FinTelegram urgently seeks insider information about: Complete client lists of gambling operators using Swapped services Internal communications regarding compliance bypass strategies Financial records showing transaction volumes with illegal gambling sites Technical documentation of integration methods with regulated exchanges Beneficial ownership details of Swapped and related entities Submit evidence anonymously via FinTelegram’s secure whistleblower platform: Share Information via Whistle42 Your information is critical to exposing the full extent of this international financial crime network and protecting consumers from predatory gambling operations enabled by Swapped‘s criminal facilitation services. This investigation reveals Swapped as the central enabler of illegal gambling across Europe—a criminal enterprise masquerading as a legitimate payment processor while systematically violating financial crime laws across multiple jurisdictions.

The scandal surrounding the collapse of René Benko’s Signa Group has entered a new phase. The insolvency administrators of Signa Development and Signa Prime are preparing claims exceeding €100 million against KPMG, accusing the Big Four auditor of grave failures. Allegedly, KPMG ignored glaring red flags, enabling Signa to delay insolvency filings and deceive creditors for years. The case exposes deeper systemic flaws in the role of auditors and tax advisors in high-stakes real estate frauds. Key Points: €100M+ liability claims: Signa Development seeks up to €54M, Signa Prime up to €72M from KPMG. Accusation of negligence: KPMG allegedly failed to act “with due care or critical distance” between 2019–2022. Delayed alarms: Auditors waited until Oct 2023 to report insolvency risks, just before collapse. Worthless audits? Administrators seek return of €2.6M in fees, calling audits “worthless.” Overvalued assets & fake returns: Real estate marked up, return-on-sales inflated via revaluation tricks. “Hole-on-hole” financing: Signa allegedly concealed debt dependency by inflating book values. No court case – yet: KPMG invited to settle out-of-court alongside TPA and legal advisors. KPMG denies wrongdoing: Claims audits were conducted properly and dismisses accusations as routine post-collapse tactics. Short Narrative: The bankruptcy of Signa Group was not only the largest real estate collapse in Austrian history—it is now also becoming a reckoning for those who were paid to oversee and prevent such disasters. The insolvency administrators of key Signa units have formally accused auditing giant KPMG of professional misconduct, claiming that its auditors looked the other way while Signa faked valuations, masked liquidity shortfalls, and manipulated financials. The message is blunt: Signa’s auditors didn’t just fail—they enabled the fraud. According to the administrators, the fraud could have been stopped years earlier if KPMG had fulfilled its legal duty to report. Instead, KPMG gave clean audit opinions while Signa’s executives used inflated valuations to mislead lenders, investors, and regulators. The result? A multi-billion-euro collapse, with creditors left holding the bag—and auditors walking away with millions in fees. But this time, the administrators are fighting back. Armed with legal claims and growing public scrutiny, they’ve launched a coordinated attack on KPMG, as well as tax advisor TPA and Signa’s own advisory board members. Settlements may still happen—but the pressure is rising. Extended Analysis: The claims against KPMG mark a pivotal moment in Austria’s unfolding white-collar crisis. As post-Signa shockwaves ripple through the financial system, the role of gatekeepers—auditors, tax advisors, legal counsel—is coming under fire. These professionals didn’t merely rubber-stamp questionable valuations—they are now seen as having enabled systemic deception. KPMG, in its defense, calls the accusations standard fare in major bankruptcies. But the administrators’ case is unusually detailed, pointing to specific violations of the duty to report under Austrian corporate law. They allege that auditors ignored signs of insolvency for multiple years, allowing Benko’s house of cards to grow while creditor exposure ballooned. The hole-on-hole financing model, in which new loans were used to repay old ones and real estate assets were chronically overvalued, should have triggered red flags. It didn’t. Worse: KPMG allegedly certified unrealistic return-on-sales numbers that any competent auditor should have questioned. The return of audit fees signals a more aggressive strategy: calling the audit “worthless” is not just symbolic—it’s a direct challenge to the profession’s credibility. What’s more, the involvement of TPA and supervisory board members in the negotiations shows this is not just about KPMG. It’s about accountability across the entire compliance chain. Actionable Insight: Regulators, prosecutors, and investor protection groups should pay close attention to the Signa-KPMG case. If even half of the allegations hold up, it will reinforce what many critics have long suspected: that the Big Four often operate less as auditors and more as co-pilots of aggressive financial engineering. FinTelegram recommends that the Austrian Chamber of Public Accountants, FMA, and European supervisory bodies re-examine the regulatory frameworks for audit oversight and introduce stronger whistleblower protections for insiders in auditing firms. Call for Information: Were you involved with Signa, KPMG, TPA, or other advisory firms linked to this case? Do you have internal documents or insights into the audit process or valuation tricks? Submit your information confidentially via Whistle42.com. All leads are reviewed by FinTelegram’s investigative team. Share Information via Whistle42

GamDom, operated by Smein Hosting B.V. under Curacao license GLH-OCCHKTW0702182020, presents significant regulatory compliance concerns that mirror broader issues identified in our previous analyses of MetaWin and BC.Game. The Spanish Gambling Authority’s €5 million fine against Smein Hosting for targeting Spanish players without proper authorization exemplifies the regulatory enforcement actions crypto casinos face when operating in jurisdictions where they lack appropriate licenses. This report examines GamDom‘s regulatory violations, payment facilitation structures, and connections to Hub88 and other entities within the crypto casino ecosystem. Read our reports on GamDom here. Spanish Regulatory Enforcement: The €5 Million Fine DGOJ Sanctions Against Smein Hosting Spain’s Directorate General for the Regulation of Gambling (DGOJ) imposed a €5 million fine on Smein Hosting B.V. in 2023 as part of broader enforcement actions against unlicensed gambling operators targeting Spanish consumers. This penalty was categorized as a “very serious infringement” under Spain’s gambling laws for operating without proper Spanish licensing while actively soliciting Spanish players. The fine was part of a larger regulatory crackdown that saw €77.4 million in total penalties distributed across 14 unlicensed operators in the first half of 2025, with most operators receiving €5 million fines and one facing a €10 million penalty. Payment Status: Our investigation could not confirm whether Smein Hosting has paid the €5 million fine, as Spanish regulatory authorities do not publicly disclose payment status of imposed sanctions. Regulatory Pattern and Enforcement Trend The Spanish enforcement action against GamDom follows a consistent pattern of regulatory violations by Curacao-licensed crypto casinos. Between 2021 and 2024, Spain imposed over €475 million in fines across 180 sanctions, with the DGOJ demonstrating increasingly aggressive enforcement against offshore operators. This trend reflects broader European regulatory tightening around unlicensed gambling operations targeting EU consumers. Corporate Structure and Key Personnel Primary Operating Entities Legal Entity: Smein Hosting N.V. Registration: Company Number 141727, Curacao License: Curacao Gaming Control Board GLH-OCCHKTW0702182020 Registered Address: Zuikertuintjeweg Z/N (Zuikertuin Tower), Curacao Payment Agent: Vilnius IT Solutions UAB, Lithuania Payment Agent Structure GamDom operates through Vilnius IT Solutions UAB as its Lithuanian payment agent, providing direct EEA market access despite lacking appropriate European licensing. This Lithuanian entity, with registration address at Ateities g. 31B-101, LT-06326 Vilnius (company code 304988128), facilitates European Union payment processing while the parent company remains offshore. Payment Processing and FIAT Conversion Swapped Integration GamDom utilizes Swapped (Swapped.com) for fiat-to-crypto conversion services, enabling European players to deposit euros and other fiat currencies by purchasing cryptocurrencies on-platform. Swapped processes bank payments from players for the purchase of cryptocurrencies for use on GamDom the bank account (DE31202208000050484620) of Swapped ApS‘s at Banking Circle (www.bankingcircle.com). Swapped, registered with Australian ASIC, FinTRAC Canada, and Danish Financial Supervisory Authority, operates as a regulated crypto payment processor offering over 40 payment methods. The Swapped integration creates a two-step transaction process where players first purchase cryptocurrency using traditional payment methods, which is then automatically transferred to their GamDom account for gambling purposes. This structure potentially complicates chargeback processes and regulatory oversight, as identified in FinTelegram’s previous analysis. Via Swapped Connect (connect.swapped.com), players can also make deposits to GamDom via other crypto exchanges such as Binance, Coinbase, Kraken, or ByBit. In fact, all leading crypto exchanges have been connected to GamDom via Swapped Connect. Additional Payment Facilitators Beyond Swapped, GamDom works with multiple payment processors: PayOp and PayDo for Gamdom Coin transactions MoonPay for direct crypto purchases Traditional card processing through various third-party providers Hub88 Partnership and Game Distribution Content Aggregation Relationship GamDom maintains a business relationship with Hub88 (website), a Malta-based casino games aggregator that provides access to over 12,000 games from 100+ suppliers through a single API integration. Hub88, recently crowned “Best Game Aggregator” at the International Gaming Awards 2025, serves as a content distribution platform for multiple crypto casinos, including GamDom. Hub88’s Compliance Framework HUB88 Limited, licensed and regulated by the Malta Gaming Authority (MGA) under the B2B Critical Supply License number MGA/B2B/536/2018, operates from Malta with operational bases in Estonia, providing game aggregation services to licensed and unlicensed operators across multiple jurisdictions. The company’s aggregation model enables crypto casinos like GamDom to access premium gaming content while potentially circumventing direct relationships with individual game providers, which may have stricter compliance requirements. Regulatory Compliance Analysis Jurisdictional Violations GamDom‘s Curacao license does not provide automatic authorization to operate in EEA jurisdictions, yet the platform actively targets European players through localized payment methods and marketing. This creates multiple regulatory violations: Unlicensed Operation: Operating gambling services without proper national licenses in restricted jurisdictions Payment Processing Violations: Using EU-based payment agents while lacking European gambling authorization Consumer Protection Failures: Offering gambling services to consumers in jurisdictions where such services are prohibited Restricted Jurisdictions GamDom is explicitly blocked in 36 countries, including major markets such as the United States, United Kingdom, Spain, Germany, Netherlands, and France. However, enforcement of these restrictions relies primarily on IP geoblocking, which can be circumvented through VPN usage. Risk Assessment and Compliance Concerns Consumer Protection Deficiencies GamDom’s operational model presents several consumer protection concerns: Chargeback Complications: The fiat-to-crypto conversion process makes traditional chargeback mechanisms difficult or impossible to execute Jurisdictional Confusion: Players may unknowingly violate local gambling laws by accessing offshore services Regulatory Arbitrage: The platform exploits regulatory gaps between Curacao licensing and European enforcement AML and KYC Considerations While GamDom claims to have implemented a three-tier KYC verification, the crypto-first model and offshore licensing create potential AML risks. The platform’s acceptance of players from jurisdictions where it lacks proper licensing may facilitate regulatory arbitrage and complicate efforts to detect money laundering. Conclusions and Regulatory Outlook GamDom‘s regulatory profile demonstrates the broader compliance challenges facing Curacao-licensed crypto casinos operating in global markets. The Spanish €5 million fine against Smein Hosting represents a clear enforcement trend toward stricter penalties for unlicensed operators targeting European consumers. The platform’s reliance on Lithuanian payment agents while maintaining offshore licensing creates a complex regulatory structure that may face increased scrutiny as European authorities enhance cross-border enforcement coordination. FinTelegram has submitted formal inquiries to GamDom management regarding the Spanish fine payment status, future compliance strategies, and explanations for the operational structures identified in this analysis. This report serves as the foundation for continued investigation into the crypto casino industry’s regulatory compliance practices and enforcement vulnerabilities. Note: This analysis builds upon FinTelegram’s previous examinations of MetaWin and BC.Game, contributing to our comprehensive assessment of regulatory patterns within the offshore crypto casino sector. Future reports will examine additional operators and enforcement actions across multiple jurisdictions. Share Information via Whistle42 This compliance report was prepared based on comprehensive research into public regulatory filings, corporate records, and enforcement actions. FinTelegram maintains its commitment to transparent financial crime reporting and regulatory compliance analysis.

Introduction and Business Activity Swapped is an international crypto payment processor positioning itself as a regulatory-compliant bridge between FIAT and cryptocurrencies. The platform enables users and businesses to purchase, exchange, and pay with crypto assets using a wide range of payment methods—credit/debit cards, bank transfers, and alternative payment solutions. Swapped’s growing B2B segment includes seamless “in-platform” crypto purchasing integrations for online merchants, most notably gambling operators. One high-profile use case is Swapped’s direct integration with GamDom, a widely used crypto casino that accepts European FIAT payments for gambling in Bitcoin and other cryptocurrencies, even in jurisdictions where such activity is illegal or unlicensed. Corporate Structure and Key Stakeholders Primary Legal Entity:Swapped ApSRosbjergvej 22A, 8220 Brabrand, DenmarkCompany Registry: 42865397 (Danish CVR) Other Corporate Entities: Swappedcom Inc. (USA, Delaware: EIN 38-4342884) Australian Branch: Registered with ASIC, ACN 670 910 291 Leadership and Control:Swapped does not widely publicize information about its beneficial owners or controlling individuals. Standard sources and public records confirm Danish and international business and compliance officers, but transparency remains limited regarding executive decision-makers and ultimate beneficial ownership. This lack of transparency is a red flag in financial compliance, especially in the high-risk crypto payments sector. Web presence: www.swapped.com Regulatory Status Swapped presents itself as a legitimately regulated payment business: Danish Financial Supervisory Authority (Finanstilsynet): Registered as a crypto-asset service provider (CASP) and passportable across the EU under MiCAR. FINTRAC Canada: Registered Money Services Business (MSB), obligated for AML/CTF compliance in Canada. Australian Securities & Investments Commission (ASIC): Registered for operations through a branch entity. Swapped boasts a compliance framework with KYC and AML checks and claims strict industry vetting, including the explicit prohibition of using its services for illegal or unauthorized gambling, as stated in its Terms of Service. Compliance Concerns and Practical Reality Despite its self-claimed regulatory posture, FinTelegram’s investigations reveal that Swapped is actively facilitating transactions for GamDom and potentially other crypto casinos operating without required licenses in the EU and UK. This means consumers in Spain (whose regulator has already imposed sanctions), Austria, Germany, Italy, and the United Kingdom are able to use Swapped to gamble on offshore platforms that are specifically prohibited for targeting their residents. This is not a minor loophole: The Spanish DGOJ has fined GamDom’s operator, Smein Hosting, €5 million for unlicensed activity. German law (GlüStV 2021) and Italian/UK regulations explicitly prohibit offshore gambling—especially where operators and intermediaries are aware of their target market’s restrictions. Swapped’s integration with these services is not merely a passive payment solution—it provides the core technical bridge for converting FIAT to cryptocurrencies for gambling, knowing (or negligently disregarding) that such acts contravene major European licensing requirements. Swapped’s “prohibited activities” clauses in its ToS for Merchants are functionally ignored in practice, raising serious questions regarding the company’s compliance culture, merchant onboarding/monitoring, and the strength or sincerity of its regulatory attestations. FinTelegram Statement and Next Steps FinTelegram has formally reached out to Swapped’s management for comment and clarification regarding these regulatory violations and their ongoing commercial relationships with unlicensed gambling platforms. Swapped management has been notified that a failure to respond will be publicly noted, with all provided statements published in full context. Compliance Assessment Summary Regulatory facade—Swapped leverages registrations in Denmark, Canada, and Australia, but fails on ongoing monitoring and enforcement of its own ToS and AML/market conduct expectations. Facilitation of illegal gambling—By knowingly serving operators like GamDom in restricted jurisdictions, Swapped is not just failing in compliance, but is potentially complicit as a facilitator of illegal online gambling. Lack of transparency—Reluctance to disclose full beneficial and operational control further undermines trust and exposes the platform to substantial regulatory and reputational risk. FinTelegram will publish all updates and management responses as they become available, and calls on all stakeholders and whistleblowers to provide further evidence regarding Swapped, GamDom, and similar high-risk payment/gambling partnerships via Whistle42. Share Information via Whistle42 This report is produced as part of our ongoing financial crime and regulatory monitoring work on the crypto gambling and payment processor sector. FinTelegram stands for transparency, integrity, and consumer protection in global finance.

The recent warning issued by Bitcoin.de and its operator, BaFin-regulated Futurum Bank AG, represents a watershed moment in crypto compliance that exposes the stark divide between regulated German financial institutions and complicit payment processors facilitating illegal gambling operations. While Bitcoin.de explicitly prohibits transactions related to unlicensed gambling under Germany’s State Treaty on Gambling 2021, major crypto payment processors such as MoonPay and Swapped continue to enable illegal casino operations through deliberate compliance failures and willful blindness to their merchants’ activities. In 2023, the German regulator BaFin ordered futurum bank to remedy shortcomings in money laundering prevention. This regulatory warning demonstrates that legitimate actors in the crypto ecosystem recognize the illegality of offshore casino operations, making the continued facilitation by other payment processors not merely negligent but complicit in systematic violations of national gambling laws across multiple jurisdictions. German Regulatory Framework and Bitcoin.de’s Compliance Stance Legal Clarity Under the State Treaty on Gambling 2021 Germany’s Interstate Treaty on Gambling 2021 (Glücksstv 2021) provides unambiguous legal authority for Bitcoin.de‘s warning. Section 4 (1) and (4) explicitly prohibit both the offering and use of gambling services without valid German licensing, extending this prohibition to crypto-asset transactions that facilitate unlicensed gambling operations. The treaty’s Section 6b (4) further restricts gambling payments to those originating from identified payment accounts with obligated parties under German anti-money laundering law, effectively excluding anonymous crypto transactions for gambling purposes. Notably, the new regulations include an explicit ban on crypto transfers for unlicensed gambling operations, demonstrating German lawmakers’ recognition of cryptocurrency’s role in circumventing gambling restrictions. BaFin-Regulated Institution’s Compliance Leadership As a BaFin-regulated institution, Futurum Bank AG operates under strict supervisory oversight that includes comprehensive AML/KYC obligations and transaction monitoring requirements. The bank’s warning reflects its regulatory obligations under the German Banking Act (KWG) and demonstrates how properly regulated financial institutions must approach crypto-gambling compliance. “Transactions in connection with illegal gambling constitute a violation of applicable law,” the bank stated, threatening account restrictions and relationship termination for violators. This represents the gold standard for crypto payment processor compliance that starkly contrasts with the permissive approaches of MoonPay, Swapped, and other facilitators. Payment Processor Facilitation: A Study in Regulatory Arbitrage MoonPay’s Systematic Casino Integration Despite claiming compliance with PCI DSS standards and KYC/AML verification, MoonPay has systematically integrated with multiple offshore crypto casinos operating without proper licensing in target jurisdictions. Recent partnerships include: Claps Casino: Curacao-licensed operator offering direct MoonPay integration for “ridiculously easy” crypto purchases BitStarz: Offshore casino accepting deposits up to $11,940 without adequate KYC/AML verification Multiple unlicensed operators: Facilitating deposits across dozens of offshore casinos targeting restricted jurisdictions Read our reports on MoonPay here. MoonPay‘s integration allows players to “purchase Bitcoin, Ethereum, or USDT using traditional payment methods — no exchange account or wallet required,” effectively circumventing the friction designed to prevent illegal gambling participation. This seamless fiat-to-crypto conversion occurs within the casino interface, demonstrating technical integration specifically designed to facilitate prohibited activities. Swapped’s Merchant Due Diligence Failures While Swapped maintains prohibited industries policies that explicitly ban “unlicensed gambling operators,” the company continues processing payments for GamDom and other offshore casinos that lack proper licensing in target markets. This represents a fundamental failure of merchant due diligence and ongoing compliance monitoring. Swapped‘s MiCAR authorization through the Danish Financial Supervisory Authority (FSA) should require enhanced scrutiny of merchant activities, yet the company appears to rely on superficial Curacao licensing rather than comprehensive jurisdictional compliance analysis. Systematic Compliance Failures Across the Industry The pattern of payment processor facilitation extends beyond individual companies to represent systematic industry failures: CryptoPay: Processes deposits for “anonymous and illegal online casinos,” resulting in compliance downgrades Changelly: Facilitates payments for unlicensed operators alongside MoonPay Cyprus-based PSPs: Systematically process transactions for Curacao-licensed operators targeting EU markets without proper authorization Legal Analysis: From Negligence to Complicity Knowledge Standard and Willful Blindness Payment processors cannot claim ignorance of their merchants’ illegal activities when: Technical Integration: Custom API integrations and white-label solutions demonstrate active participation in casino operations Marketing Cooperation: Joint promotional materials and “seamless gambling experiences” show commercial partnership beyond mere payment processing Jurisdictional Targeting: Processing payments from jurisdictions where merchants lack proper licensing demonstrates knowledge of regulatory violations Industry Knowledge: Widespread reporting on crypto casino illegality establishes constructive notice across the industry Facilitation vs. Complicity The distinction between inadvertent facilitation and criminal complicity narrows when payment processors: Design specific integration tools for casino operators Market their services as solutions for “crypto gambling” Ignore obvious red flags in merchant applications and transaction patterns Fail to implement adequate ongoing monitoring despite regulatory obligations Regulatory Enforcement Trends and Industry Impact Escalating Enforcement Actions Recent regulatory actions demonstrate increasing enforcement against facilitators: Spain: €77.4 million in fines against 14 unlicensed operators, with payment facilitation under scrutiny UK: Mastercard and Visa under investigation for processing illegal gambling transactions Germany: Joint Gambling Authority removing over 200 illegal sites from search results Financial Crime Nexus The intersection of crypto casinos and money laundering creates additional enforcement risks. UNODC research indicates that “online gambling platforms, and especially those that are operating illegally, have emerged as among the most popular vehicles for cryptocurrency-based money laundering”. Payment processors facilitating these operations face potential Financial Crimes Enforcement Network (FinCEN) violations, FATF compliance failures, and secondary sanctions for enabling prohibited financial flows. Comparative Compliance Analysis InstitutionRegulatory StatusGambling PolicyCompliance ApproachBitcoin.de/Futurum BankBaFin-regulated bankExplicit prohibitionProactive warning, account restrictionsMoonPayFCA/Multi-jurisdictionalPermissive integrationTechnical facilitation, minimal oversightSwappedMiCAR/Multi-jurisdictionalWritten prohibitionPolicy violation through continued processingCryptoPayLithuania-regulatedNo clear policyDowngraded for illegal casino processing Call for Industry Accountability and Whistleblower Reports Regulatory Reckoning Required The Bitcoin.de warning should serve as a wake-up call for regulators across jurisdictions to examine the role of licensed payment processors in facilitating illegal gambling operations. The contrast between Futurum Bank’s proactive compliance and MoonPay/Swapped’s permissive facilitation demonstrates that proper compliance is both possible and legally required. Payment processors claiming regulatory compliance while technically integrating with illegal casinos are not merely failing their oversight obligations—they are actively participating in systematic violations of national gambling laws. Whistleblower Intelligence Network FinTelegram encourages industry insiders, former employees, compliance officers, and technical personnel with knowledge of payment processor facilitation of illegal gambling operations to provide evidence through our Whistle42 platform. Critical intelligence needed includes: Internal compliance policies vs. actual merchant onboarding practices Technical integration documentation for casino operators Management communications regarding regulatory risks and illegal gambling Financial data showing transaction volumes to unlicensed operators Regulatory correspondence and internal legal analyses Share Information via Whistle42 Whistleblower protection and anonymity are guaranteed through our secure reporting infrastructure. Conclusions and Regulatory Recommendations The Bitcoin.de warning represents more than regulatory compliance—it demonstrates that legitimate crypto ecosystem participants recognize their legal obligations and refuse to facilitate illegal gambling operations. The continued technical integration and commercial partnership between major payment processors and offshore casinos operating without proper licensing constitutes systematic facilitation of illegal gambling that demands immediate regulatory intervention. FinTelegram’s analysis concludes that payment processors like MoonPay and Swapped have moved beyond passive facilitation to active complicity in illegal gambling operations through custom technical integrations, marketing cooperation, and deliberate compliance failures. The time for regulatory tolerance of this systematic law circumvention has ended. Authorities across jurisdictions must follow Germany’s lead in holding payment processors accountable for their role in the illegal casino ecosystem, while legitimate industry participants like Bitcoin.de demonstrate that proper compliance is both achievable and legally mandated. The choice facing crypto payment processors is clear: follow the compliance leadership of regulated institutions like Futurum Bank AG, or face the legal consequences of continued facilitation of illegal gambling operations. FinTelegram maintains its commitment to exposing financial crime and regulatory violations across the cryptocurrency ecosystem. Our investigation into crypto casino facilitation continues, with additional reports forthcoming on systematic compliance failures across the payment processing industry.

Executive Summary MetaWin represents a prime example of the emerging generation of cryptocurrency-based online gambling platforms that exploit regulatory gaps to serve global markets while avoiding traditional licensing requirements. Operating under a low-tier Anjouan license and targeting users worldwide—including those in the European Union—MetaWin demonstrates the significant challenges regulators face in controlling the rapidly expanding crypto casino sector. This analysis examines MetaWin‘s structure, regulatory status, and broader implications for financial crime prevention and consumer protection. Company Background and Leadership MetaWin was founded in 2022 by Richard “Skel” Skelhorn, who serves as CEO and operates under the pseudonym “Skel” within the crypto gaming community. The platform positions itself as a fully decentralized, Web3-native casino operating primarily on the Ethereum blockchain. Despite its public-facing leadership, the actual corporate control lies with Raman Dandyan, a Canadian resident born in 1997 who owns over 75% of the UK-registered MetaWin Limited (Company Number 15072116).cryptopotato+5 The operational team includes Rafael Gómez Agar as Head of Compliance and Payments, Rory Cartwright as COO, and Chelsey Mitchell as Financial Controller. The company maintains headquarters in London with additional presences in Monaco, Gibraltar, and Miami (Source: linkedin+1). Notably, founder Skelhorn has demonstrated an entrepreneurial approach to tokenization, launching the $ROCKY meme coin on the Base network in April 2024, indicating his involvement in the broader crypto ecosystem beyond gambling operations (Source: cryptopotato). Understanding Crypto Casino Operations Crypto casinos fundamentally differ from traditional online gambling platforms in several key aspects: Technical Architecture Blockchain-based transactions: All deposits, wagers, and withdrawals occur directly on-chain, typically using Ethereum or other smart contract platforms (Source: casinosblockchain+2). Smart contract automation: Game outcomes and payouts are processed through automated smart contracts, reducing operator control over individual transactions (Source:blockonomi+1). Non-custodial approach: Players interact directly from their crypto wallets (such as MetaMask), maintaining control over their funds until actively wagered (Source: binance+2). Operational Differences Anonymous participation: Users can gamble without traditional KYC requirements, accessing services through wallet connections rather than account registrations (Source: casinosblockchain+2). Provably fair gaming: Blockchain technology enables cryptographic verification of game fairness, allowing players to independently verify outcomes (Source:binance+1). Cross-border accessibility: The decentralized nature makes geographical restrictions technically difficult to enforce (Source: blockonomi+1). These features create significant regulatory challenges, as traditional gambling oversight mechanisms are ill-equipped to monitor decentralized, anonymous, cross-border transactions conducted through smart contracts (Source: nominis+2). Regulatory Status and Licensing Current Authorization MetaWin operates under a gambling license from the Government of the Autonomous Island of Anjouan (Comoros), license number ALSI-1523 12009-FI3. This jurisdiction provides minimal regulatory oversight and is not recognized by any major gambling authority or EU member state for the purposes of offering gambling services to their residents (Source: sportsgambler+3). EU Market Access Critically, MetaWin’s terms and conditions do not exclude most EU jurisdictions from accessing their services, with restrictions applying only to specific countries including Austria, France, Germany, the Netherlands, and Spain. This means users from the majority of EU member states—including Italy, Poland, Sweden, Romania, and Portugal—are not technically prohibited from using the platform.cryptomaniaks However, this apparent compliance gap is significant: MetaWin lacks any valid EU or EEA gambling license, meaning it operates illegally when serving EU residents, regardless of its terms and conditions. The platform’s Anjouan license provides no legal authority to solicit or accept players from regulated EU markets.casinosblockchain Comparative Analysis: MetaWin vs. BC.game Both platforms share remarkably similar operational models and regulatory challenges: Structural Similarities Both operate under Anjouan licenses after losing or abandoning Curacao authorizations (Sources: bc+2) Neither platform requires meaningful KYC procedures for crypto user (Sources: bcplaytime+2) Both offer anonymous, wallet-based gambling with fast crypto transactions (Sources: bcplaytime+1) Each platform lacks authorization to serve EU markets despite accepting such players (Sources: jaxon+1). Key Operational Differences FeatureMetaWinBC.gameWebsitesMetaWin.comBC.game and many othersLaunch Year2022 (Sources: coincentral+1)Earlier (established brand)Game Portfolio~4,000 titles (Sources: coincentral~10,000+ titles (Sources: cryptomaniaks).Primary FocusWeb3-native experiencecasinosblockchain+1Broader crypto gambling (Sources:bcplaytime)Regulatory IncidentsLimited public issuesExtensive UK violations (Sources:espn+2)Market PresenceGrowing platformEstablished global brand BC.game’s Regulatory Violations BC.game has faced significant enforcement actions, particularly in the UK where it continued operating and sponsoring Premier League clubs (notably Leicester City) after losing its UK gambling license in December 2024. The UK Gambling Commission formally warned football clubs about promoting unlicensed gambling operators, with club officials facing potential criminal liability (Sources: news.sky+3). These enforcement actions demonstrate that while regulatory authorities can take action against crypto casinos, the process is often reactive rather than preventive, occurring only after significant violations or public attention. Regulatory Enforcement Challenges Technical Obstacles The decentralized nature of crypto casinos creates unprecedented challenges for traditional regulatory enforcement: Jurisdictional Ambiguity: Platforms operate across multiple jurisdictions simultaneously, making it unclear which regulators have authority (Sources: linkedin+2). Anonymous User Base: Wallet-based access eliminates traditional player identification methods (Sources:block3finance+1). Cross-border Transactions: Cryptocurrency payments bypass traditional financial intermediaries subject to banking regulations (Sources:payram+1) Legal Gray Areas Current regulatory frameworks were not designed for fully decentralized gambling platforms. Traditional enforcement relies on: Licensed operators with fixed jurisdictions Identifiable financial flows through regulated payment processors Clear player identification and transaction records Crypto casinos circumvent each of these oversight mechanisms, creating what regulators describe as operating in “regulatory gray areas” (Sources: linkedin+1). EU Regulatory Response: MiCA Implementation The European Union’s Markets in Crypto-Assets Regulation (MiCA), fully implemented as of December 30, 2024, represents the most comprehensive attempt to regulate crypto-based financial services. However, its application to gambling remains complex (Sources: esma.europa+2): CASP Requirements: Crypto casinos serving EU users must either become licensed Crypto-Asset Service Providers or partner with licensed intermediaries (Sources:ambcrypto+1) Stablecoin Compliance: Platforms using non-compliant stablecoins like USDT face potential exclusion from EU markets (Sources: szilaghi+1) Enhanced AML Obligations: MiCA mandates transaction monitoring, identity verification, and suspicious activity reporting (Sources:fincrimecentral+1). Despite MiCA’s comprehensive scope, enforcement remains challenging due to the global, decentralized nature of crypto casino operations (Sources: ainvest+1). Financial Crime and Consumer Protection Risks Money Laundering Vulnerabilities Crypto casinos present elevated financial crime risks due to: Anonymous Transactions: No traditional AML/KYC requirements for most users (Sources: block3finance+2). Cross-border Flows: Funds can be moved internationally without traditional banking oversight (Sources:fincrimecentral+1). Mixing Services: Integration with crypto mixing protocols can obscure fund origins (Sources: fincrimecentral). Consumer Protection Gaps Operating outside traditional regulatory frameworks means reduced consumer protections: Dispute Resolution: Limited recourse for players in case of disputes or operator insolvency Fund Security: No deposit protection schemes or segregated client accounts Responsible Gambling: Minimal implementation of addiction prevention measures (Sources:xaigate+1). Recent Security Incidents MetaWin itself suffered a significant security breach in November 2024, losing approximately $4 million to hackers. While the company claimed to recover funds, this incident highlights the additional risks faced by users of unlicensed, unregulated platforms (Sources: casino+2). Implications of Gambling Tokenization for Regulators The increasing tokenization of gambling activities represents a fundamental shift that challenges traditional regulatory approaches: Regulatory Fragmentation Multiple Jurisdictions: Token-based gambling operates across numerous blockchain networks and legal jurisdictions simultaneously Regulatory Arbitrage: Operators can easily relocate to more favorable jurisdictions without changing their technical infrastructure Enforcement Coordination: Effective regulation requires unprecedented international cooperation Technical Complexity Smart Contract Oversight: Regulators lack technical expertise to audit and monitor automated gambling protocols Decentralized Infrastructure: Traditional regulatory tools designed for centralized operators prove inadequate Rapid Innovation: The pace of technological change outstrips regulatory adaptation Consumer Accessibility Reduced Barriers: Tokenized gambling eliminates traditional barriers to entry, potentially increasing problem gambling Global Access: Geographic restrictions become largely meaningless in decentralized systems Youth Exposure: Crypto-native platforms may attract younger, tech-savvy users more vulnerable to addiction Conclusions and Regulatory Implications The MetaWin case illustrates the profound challenges facing gambling regulators in the cryptocurrency era. While the platform operates with apparent technical sophistication and transparency, its regulatory status remains fundamentally problematic—offering services to EU residents without proper authorization while exploiting jurisdictional gaps to avoid meaningful oversight. The comparison with BC.game‘s regulatory violations demonstrates that enforcement action, while possible, typically occurs only after significant violations or public pressure. This reactive approach proves inadequate for protecting consumers and maintaining market integrity in rapidly evolving crypto gambling markets. The broader trend toward tokenized gambling represents a regulatory paradigm shift requiring: Enhanced international cooperation to prevent regulatory arbitrage Technical expertise development within regulatory bodies to understand blockchain-based operations Regulatory framework modernization to address decentralized, cross-border financial services Proactive enforcement mechanisms rather than reactive penalty-based approaches As MiCA implementation progresses in the EU and other jurisdictions develop crypto-specific regulations, the current regulatory gray areas may gradually close. However, the global, decentralized nature of blockchain technology will continue challenging traditional territorial-based regulatory approaches. The MetaWin model—technically sophisticated but regulatorily non-compliant—represents the future landscape gambling regulators must prepare to address through enhanced cooperation, technical capabilities, and modernized legal frameworks. Key Data Comparison: MetaWin vs. BC.game AspectMetaWinBC.gameRegulatory StatusAnjouan License (ALSI-1523 12009-FI3)casinosblockchain+1Anjouan License (post-Curacao withdrawal)bc+1Launch Year2022coincentral+1Established earlierEU AuthorizationNonecasinosblockchainNonejaxonKYC RequirementsMinimal, large withdrawals onlycasinosblockchain+1Minimal, selective enforcementbcplaytimeGame Portfolio~4,000 titlescoincentral~10,000+ titlescryptomaniaksPrimary BlockchainEthereum-focusedcasinosblockchain+1Multi-chain supportbcplaytimeEnforcement ActionsLimited public issuesUK license revocation, club sponsorship violationsnews.sky+1Security Incidents$4M hack (Nov 2024)tradingview+1Various operational challengesTarget MarketsGlobal, most EU countries not excludedcryptomaniaksGlobal, similar EU access patternsjaxonCorporate StructureUK-registered, Canadian beneficial ownerfind-and-update.company-information.serviceComplex international structure Whistleblower Call to Action FinTelegram’s investigation into MetaWin and BC.game reveals only the surface of a complex, rapidly evolving sector that operates largely beyond traditional regulatory oversight. These platforms represent a broader ecosystem of crypto-based gambling operators that exploit regulatory gaps while serving global audiences, including EU residents, without proper authorization. We urgently need insider information about MetaWin, BC.game, and other crypto casinos to better understand their operations, compliance practices, and potential regulatory violations. If you have knowledge of: Internal compliance procedures or their absence Customer verification processes or circumvention methods Financial structures and beneficial ownership arrangements Marketing practices targeting restricted jurisdictions Money laundering controls or their inadequacy Security incidents or operational failures Regulatory interactions or avoidance strategies Please contact us securely through our Whistle42 platform at [whistle42.com]. Your identity will be protected, and your information could be crucial for regulatory authorities and consumer protection efforts. The crypto casino sector operates in shadows that only industry insiders can illuminate. Your information can help protect consumers and strengthen regulatory responses to these emerging threats. Share Information via Whistle42

Swiss Marketplace Group (SMG) stands at the forefront of Switzerland’s digital economy, operating as the nation’s dominant online classifieds and marketplace operator. With its imminent IPO on the SIX Swiss Exchange, SMG is poised to become one of the largest publicly traded tech entities in Switzerland, yet faces growing scrutiny from regulators and market participants. Company Overview SMG was founded in 2021 as a merger between established Swiss digital platforms under the ownership of TX Group, Ringier, Mobiliar, and General Atlantic. The company owns Switzerland’s undisputed heavyweights in digital real estate and auto classifieds, notably ImmoScout24, Homegate, Flatfox, and AutoScout24. The breadth of its portfolio gives SMG an unrivaled customer reach in the Swiss digital classified space. Financials Revenue (2024): 291 million CHF. Adjusted Operating Margin (2024): 48%. Revenue Growth (2025, projected): 13–15%. Margin Outlook (2025): Mid-50% range. IPO Target Proceeds: ~1 billion CHF, valuing SMG at ~4.5 billion CHF (approx. $5.6 billion). Shareholder Structure The IPO is structured as a secondary offering—SMG will not raise new capital. Instead, existing shareholders seek to partially cash out: Major Shareholders: Mobiliar, Ringier, and General Atlantic will sell shares. TX Group: Retains 30.7% and will not participate in selling at IPO. Strategic Advisors: Global investment banks including J.P. Morgan, Goldman Sachs, and UBS are leading the placement. Regulatory Environment: WEKO Investigation Amidst its IPO preparations, SMG is under investigation by the Swiss competition authority WEKO. While not yet a formal enforcement action, WEKO has initiated a market observation—prompted by widespread complaints over steep price increases imposed on real estate brokers and classified advertisers. Primary Concern: Whether SMG abuses its dominant market position through price hikes and possible anti-competitive conduct. Process: Market surveys and questionnaires have been distributed to affected market participants, with SMG under pressure to justify its pricing policy and market practices. Timing: Regulatory scrutiny coincides with the IPO schedule, increasing the risk perception for public investors. Summary Table FeatureDetailsWebsitehttps://swissmarketplace.groupCEOChristoph ToniniExchangeSIX Swiss Exchange IPO Proceeds~1 billion CHF (secondary) Valuation~4.5 billion CHF 2024 Revenue291 million CHF 2024 Adj. Op. Margin48% 2025 Revenue Growth13–15% (estimate) Main PlatformsImmoScout24, Homegate, AutoScout24, FlatfoxMajor ShareholdersTX Group (30.7%), Mobiliar, Ringier, General AtlanticRegulatory RiskWEKO investigation ongoing Lead UnderwritersJ.P. Morgan, Goldman Sachs, UBS FinTelegram Opinion SMG’s IPO offers access to the most powerful digital classifieds operator in Switzerland, with a rare combination of high margins, resilient growth, and true market dominance. However, this very dominance is at risk of becoming a liability: the ongoing WEKO investigation, triggered by SMG’s aggressive pricing and quasi-monopoly position, raises uncertainty about mid-term profitability and regulatory risk. Investors should weigh these factors against strong financials. FinTelegram does not regard the current regulatory probe as trivial; any findings of market abuse could materially impact SMG’s valuation, pricing strategies, and investor returns in the coming years. Call for Whistleblowers FinTelegram invites all insiders, competitors, and affected parties with knowledge of SMG’s business practices, pricing methods, or compliance processes to contact us—confidentially and securely—via our whistleblower system Whistle42. Your information may be critical in clarifying the truth and ensuring a fair marketplace for all participants. Share Information via Whistle42

Austria’s economic and political establishment has been shaken by the bankruptcy of the Signa Group around René Benko. His pre-trial detention has been extended once again, with his latest application for release unequivocally rejected by the Vienna court—casting a sharp spotlight on Austria’s justice system and the deepening Signa Crime Case. Context and Detention Extension The Vienna Regional Court cited “Tatbegehungsgefahr”—risk of new offenses—as justification for keeping Benko behind bars until at least October 6, 2025, continuing a series of extensions traced back to January 2025. The court asserted urgent suspicion and proportionality remain, even as Benko’s legal team contests his ongoing detention. Charges and Allegations Benko faces charges of fraudulent bankruptcy and aggravated asset concealment in connection with the collapse of his Signa real estate empire. He allegedly diverted millions intended for creditors—making questionable rent prepayments and transferring €300,000 to relatives during a period of impending bankruptcy. Prosecutors assert these acts were orchestrated to frustrate creditor claims and conceal assets, while Benko maintains his innocence. Upcoming Court Hearing The first criminal trial begins October 14-15, 2025 at the Innsbruck Regional Court, focusing on Benko’s alleged obstruction of bankruptcy administration and possible embezzlement. The scheduled hearings will scrutinize transactions involving his Tyrolean villa and gifts to family, with the prospect of a severe sentence if convicted. New Revelations: Secret Commissions and Networks Emerging revelations indicate that Martin Wittig, a confidant of Signa investor Klaus-Michael Kühne, received clandestine commission payments from Benko’s group for securing Kühne’s investment into Signa Prime. Investigations have exposed a web of contractual arrangements and hidden transfers—including a CHF 1.06 million payment—unknown even to Kühne himself, triggering Wittig’s abrupt resignation from his positions at Kühne + Nagel. This fresh scandal raises urgent questions about corporate governance, fiduciary duty, and the true scope of the Signa network’s opacity. Read our report on the secret commission payment. FinTelegram’s Previous Coverage on the Signa Crime Case FinTelegram has consistently documented Benko’s downfall, his arrest, and the mushrooming scandal—including the intricate schemes, the secretive commissions, and the judicial response to one of Europe’s largest property collapses. Prior reports have dissected not only Benko’s alleged manipulations but also broader implications for the Austrian and European financial systems. Follow our Signa Crime Case reports here. Provocative Questions How many more skeletons will emerge from the Signa closet as the Benko trial unfolds—with high-powered confidants, secret payments, and investor betrayals? Why did the justice system react so rigorously to Rene Benko, while others implicated in the scandal still remain at liberty? Can Austrian authorities truly restore trust after revelations of hidden commissions and the apparent breakdown of oversight at the highest echelons? The renewed extension of Benko’s detention—against the backdrop of secret deals and shattered trust—demands relentless scrutiny, not only of Benko and his associates, but of the structures that enabled the Signa Crisis to fester for so long. Share Information via Whistle42

Case Summary Volodymyr Viktorovich Tymoshchuk, a Ukrainian national operating under aliases such as deadforz, Boba, msfv, and farnetwork, has been indicted by the US Department of Justice as a central administrator of the LockerGoga, MegaCortex, and Nefilim ransomware operations. The superseding indictment—unsealed in the Eastern District of New York—alleges Tymoshchuk helped orchestrate attacks on more than 250 companies in the US and hundreds more globally, inflicting tens of millions of dollars in damages, including business disruption, remediation costs, and ransom payouts (Sources: justice.gov+1, CyberScoop). Legal Action and International Collaboration Tymoshchuk faces multiple serious charges, including conspiracy to commit computer fraud, intentional damage to protected computers, unauthorized access, and extortion-related threats (Sources: The Record from Recorded Future, BleepingComputer). The Department of State’s Transnational Organized Crime Rewards Program is offering up to $11 million for information leading to his arrest or conviction (Sources: justice.gov, CyberScoop). The prosecution reflects a multi-national law enforcement push: EDNY’s National Security and Cybercrime Section, DOJ’s Computer Crime and Intellectual Property Section, FBI legal attachés, and authorities across Europe—including France, Germany, the Netherlands, Norway, Switzerland, and Ukraine—along with Europol and Eurojust, all contributed to building the case. Operational Mechanics Between Dec 2018–Oct 2021, Tymoshchuk deployed variants of LockerGoga, MegaCortex, and later Nefilim, customizing each malware executable per victim to ensure decryption tools were unique and conditional on ransom payment. From Jul 2019–Jun 2020, the earlier variants were used; thereafter, from Jul 2020–Oct 2021, he operated Nefilim under a ransomware-as-a-service model—providing affiliates (like co-defendant Artem Stryzhak, extradited from Spain) access in exchange for ~20% of ransoms. Notably, many attempts failed due to preemptive law enforcement warnings to targets, though the group repeatedly evolved its malware in response. Strategic Insight This prosecution underscores geopolitical and cybersecurity policy convergence: ransomware operations are treated not merely as criminal enterprises, but as transnational threats warranting coordinated law enforcement—and rewarded intelligence. The hefty bounty adds pressure on co-conspirators and an international messaging deterrent. Tymoshchuk exemplifies the evolving RaaS model, blending technical innovation with global affiliate networks. As law enforcement gains traction, agility in malware and affiliate recruitment becomes vital to criminal payload delivery and evasion. Implications for Businesses & Cyber Defenders Proactive detection works: Victim alerts disrupted many attacks before deployment, reinforcing the value of threat intelligence sharing. Customization is both strength and vulnerability: Victim-specific malware increases sophistication but expands forensic leads. RaaS monetization aggression: Affiliate models accelerate spread—but also democratize targets, increasing systemic risk. FinTelegram Take Tymoshchuk’s indictment marks a milestone in ransomware accountability—targeting a key enabler rather than just the affiliates. The unprecedented reward signals Washington’s readiness to escalate the spotlight on ransomware leadership. As the RaaS model matures, the DOJ’s aggressive pursuit may tilt the cost-benefit calculus for cybercriminals. Share Information via Whistle42

Greece’s Independent Authority Against Money Laundering has ripped the cover off a sprawling scheme that allegedly funneled illicit money through licensed betting platforms. Roughly 200 individuals—including senior public officials and ministry directors—are under scrutiny, with at least ten operators probed for failing even the most basic AML checks. Investigators cite single deposits up to €1 million, accounts cycled through betting shops and online wallets, and money wired back out to personal bank accounts as “winnings.” This is not a grey market problem. This is the regulated sector behaving like a laundromat (Sources: GreekReporter.com, NEXT.io, CasinoBeats, focusgn.com). Key Points (for investigators & risk teams) Scale & status: ~200 suspects, including high‑ranking civil servants; probe led by Greece’s AML authority (headed by former Supreme Court deputy prosecutor Charalampos Vourliotis) (Sources: NEXT.io, CasinoBeats). Operators in scope: ≥10 licensed betting companies reportedly under investigation for AML control failures and potential facilitation (Sources: igamingtoday.com,focusgn.com). Red‑flag pattern: Large cash/transfer deposits (up to €1m in single entries), minimal source‑of‑funds (SoF) challenge at shop/agent level, funds later withdrawn as “winnings” to personal bank accounts (Sources: focusgn.com,The Gamblest). Regulatory frame: Hellenic Gaming Commission oversight + AML Authority enforcement within Greece’s updated gambling framework (incl. Law 4635/2019 and subsequent regs) (Sources: gamingcommission.gov.gr, practiceguides.chambers.com). Political optics: Investigation names public servants and ministry officials—a reputational crisis for Greece’s “clean‑up” agenda against illegal gambling and AML (Source: SigmaPlay). Short Narrative — How the “winnings cycle” worked The alleged method is depressingly simple. Suspects moved funds—often large—into accounts at licensed betting firms (in shops or online). Clerks and platforms rarely challenged the origin of funds. Bets were placed (sometimes minimally), balances were then withdrawn to bank accounts as “clean” gambling proceeds. When a single deposit hits €1m, “source of funds” and “ongoing monitoring” aren’t optional niceties; they’re the law. Yet here we are (Sources: focusgn.com, The Gamblest) Extended Analysis — Why this is systemic, not a one‑off 1) Structural weak point: retail & agent channelsMultiple reports point to shop assistants/agents not interrogating deposits or customer profiles. That’s not a “bad apple”; that’s a control design failure and a predictable exploitation vector in any hub‑and‑spoke retail network. If agents are paid for volume, SoF friction disappears (Sources: focusgn.com,The Gamblest). 2) Licensed ≠ low‑riskThis scandal obliterates the myth that licensure alone suppresses AML risk. If transaction monitoring, affordability checks, and SoF triggers aren’t enforced (and evidenced), a regulated brand becomes the perfect cloak for illicit flow. The presence of public officials as high‑value customers should have auto‑triggered PEP‑adjacent scrutiny and income‑vs‑loss profiling. It apparently didn’t (Sources: GreekReporter.com) 3) Governance and board accountabilityIf ten or more operators are in scope, the problem is not just front‑line negligence—it’s board‑level risk appetite and second‑line failure (compliance/AML functions). Greece’s framework empowers regulators to sanction hard for systemic breakdowns; enforcement now must show teeth (Sources: practiceguides.chambers.com 4) The “policy paradox”Even as Athens touts an aggressive reform drive against illegal gambling and AML leakages, its licensed sector stands accused of being the conduit. Expect Brussels and FATF peer pressure if sanctions, licence conditions, and remediation aren’t decisive—and public (Sources: SigmaPlay). Compliance Takeaways (Operators & PSPs) Hard SoF at abnormal thresholds: Any high‑velocity inflow or >€10k‑€50k single‑day funding (set locally) must freeze to documentary review—no bets until verified. PEP/public‑servant lens: Flag civil‑service roles (where lawful), track declared income ranges, and trigger enhanced monitoring when gambling intensity diverges from profile. Agent economics: Re‑engineer incentives so AML stops are rewarded, not punished. Audit mystery‑shop programs monthly. Banking exits: Risk‑score withdrawals to personal IBANs labeled as “winnings.” Large/layered payouts require secondary approval and narrative justification. Look‑back + SAR surge plan: Run a 24‑month retrospective on top‑decile depositors and file SARs where SoF was flimsy or fabricated; notify payment partners proactively. Regulatory Context — The rulebook they ignored Greece’s modernized gambling regime (notably Law 4635/2019 and subsequent regulations) sits under the Hellenic Gaming Commission umbrella with AML enforcement by the Independent Authority. The framework requires robust KYC, continuous monitoring, and SoF checks commensurate with risk—especially for high‑value or public‑exposed customers. The conduct described—€1m deposits and frictionless cash‑outs—suggests profound non‑compliance with both national AML law and EU standards. practiceguides.chambers.comgamingcommission.gov.gr FinTelegram’s Verdict This is state‑adjacent money laundering hiding in plain sight, allegedly laundered through the comfort blanket of licensure. If regulators don’t put names, fines, and licence conditions on the table now, Greece will have advertised a blueprint: wear a badge, run a laundromat. The industry loves to blame the “illegal market.” Not today. Today the rot is inside the fence. SBC NewsCasinoBeats Call for Information (confidential) Were you (a) staff, (b) agent/retailer, or (c) compliance at a Greek betting operator who saw source‑of‑funds waved through, especially for public officials or six‑figure deposits? We want to hear from you. Provide documents, internal emails, or SOPs showing SoF overrides, VIP exceptions, or pressure from commercial teams. Your identity will be protected. Share Information via Whistle42

A new wave of crypto company IPOs is reshaping the digital asset investment landscape in 2025, driven by regulatory clarity and a surging market. Several major firms are progressing toward public listings, with some already completed and others—such as Kraken—still speculative but highly anticipated. Based on all available sources and market sentiment, the current IPO landscape is summarized below. Confirmed and Recent Crypto IPOs Several major crypto companies have successfully completed IPOs in 2025: Bullish: Backed by Peter Thiel, this cryptocurrency exchange made a dramatic market debut on the NYSE in August 2025, soaring 218% on its first day of trading. The company’s IPO valued it at $5.4 billion, with the stock hitting a market cap of $13 billion during initial trading. Bullish plans to convert a portion of its IPO proceeds to stablecoins. Circle: The USDC stablecoin issuer entered public markets in June 2025, aiming for validation from traditional finance and increased DeFi adoption. Circle’s listing seeks to anchor its $31.8B stablecoin firmly within the regulated financial ecosystem. Gemini: The exchange founded by the Winklevoss twins is in the process of going public on Nasdaq under the ticker GEMI. The public listing intends to offer 16.66 million shares at an anticipated market cap of about $2.1 billion, seeking to cement Gemini’s status as a compliant crypto trading and custody solution. Bitkub: Thailand’s top crypto exchange Bitkub is finalizing an IPO targeting a $165 million raise, part of the broader push in Southeast Asia driven by rapid regional adoption and evolving regulatory oversight. Telegram/TON: There are ongoing initiatives to bring Telegram’s TON blockchain ecosystem to the public, tapping its 900M user base for integrated dApp and payment services, targeting a possible $30–50 billion valuation. High-Profile Rumored and Upcoming IPOs Kraken Kraken remains one of the most widely rumored IPO candidates, repeatedly hinting at a public listing since Coinbase went public in 2021. In 2024/25, Kraken considered raising $100M in a pre-IPO round, aiming for a public debut at a $15B valuation in late 2025 or Q1 2026. Regulatory headwinds—particularly ongoing legal challenges from the SEC—continue to pose a risk to the timeline. Kraken‘s co-CEOs have publicly stated that market conditions, regulatory clarity, and business performance will dictate the final IPO decision. No public listing has been confirmed as of September 2025, and Polymarket odds currently list the IPO by end-2025 as unconfirmed but closely watched by investors. Other Candidates eToro and Galaxy Digital have also been linked to imminent or ongoing IPO activity, leveraging increased investor appetite for regulated, diversified financial platforms. Ripple has been listed among possible IPO aspirants, but recent sources provide no concrete confirmation of timing. Analyst Opinion and Final Assessment The crypto IPO surge is being fueled by renewed institutional interest, mainstreaming of financial infrastructure, and regulatory support in the U.S. and Asia. These IPOs are seen as a litmus test for crypto’s absorption into traditional capital markets. Bullish and Circle’s successful debuts have demonstrated robust investor demand, but early post-IPO volatility remains high. Analyst sentiment on Bullish, for example, has cooled since the first-day price rally, underlining risk awareness. Kraken’s prospective IPO would instantly become a major event, attracting global attention. However, it will depend closely on macro environment, regulatory clearance, and internal capital-raising success. Investors remain split: those bullish see Kraken as a Coinbase-scale opportunity, while skeptics point to its regulatory baggage and slower pre-IPO fundraising. Broadly, expect further listings and growing differentiation between compliant, regulated firms and those struggling to achieve mainstream acceptance. Final View: The current slate of crypto IPOs marks a genuine turning point for sector legitimacy and transparency. While appetite is strong, each listing’s long-term value will reflect regulatory positioning, risk management, and adaptability to institutional standards. Investors are advised to prioritize firms with proven compliance, diversified revenue, and clarity on legal exposure, particularly as IPO-driven volatility remains likely through 2025-2026. Share Information via Whistle42

Paxos has proposed USDH, a Hyperliquid-first stablecoin where ~95% of reserve interest (e.g., T-bill yield) would be used for programmatic buybacks of HYPE, Hyperliquid’s utility token. The announcement coincided with a ~3% pop in HYPE as the market priced in a structural bid for the token. If adopted and scaled, USDH could create a powerful “stablecoin yield → native-token demand” loop around Hyperliquid’s already dominant on-chain perps venue. EU investors should note: for EU usage, USDH must satisfy MiCA e-money token (EMT) requirements (issuer type, whitepaper/notifications, redemption, no interest to holders), and MiCA Title VI market-abuse rules would apply to any systematic buybacks in EU trading venues. (Sources: CointelegraphODaily, Coinpaper, Blockonomi, 21shares.com, service.betterregulation.com, esma.europa.eu). Issuers & Players Paxos — NYDFS-regulated trust company; issuer of USDP and former BUSD partner (BUSD minting halted in 2023 per NYDFS; 2025 settlement reached). Proposal claims USDH would be compliant with MiCA and the US GENIUS Act framework (Sources: Department of Financial Services, Reuters, theblock.co, TradingView) Hyperliquid (HYPE) — Order-book DEX + L1 focused on perpetual futures. Multiple analyses show outsized share of on-chain perps volume in 2024–25 (estimates 75–80% share, $1.5T+ cumulative volume). A hallmark is extreme efficiency: public interviews and reports frequently cite a core team of ~11 people, fueling the “Binance-on-chain” narrative (Sources: OKXMedium+1, Medium). The DEX/Perps Segment (Where USDH Would Live) Perpetual futures or perps (no expiry; funding payments align perp to spot) have become crypto’s core derivatives rail. In 2025, decentralized perps volume reached ~$2.6T, with daily peaks in the tens of billions. Hyperliquid and dYdX lead; GMX/Aevo trail. Hyperliquid’s edge: fast L1, deep market list, aggressive leverage, and a CEX-like UX—all on-chain. 21shares.comNFT Evening What USDH Actually Proposes Design: A Hyperliquid-native stablecoin (USDH) issued by Paxos; ~95% of reserve yield used for ongoing HYPE buybacks and redistribution to ecosystem stakeholders (validators/users/partners). USDH governance by validator selection is flagged in reports (Sources: Cointelegraph, ODaily, TradingView). Market reaction: Coverage notes an immediate ~3% rise in HYPE post-announcement; live trackers show HYPE trading in the high-$40s area around the news cycle (Sources: Coinpaper, CoinMarketCap). Why This Is a Big Deal (Mechanics & Flywheel) Value capture: Instead of paying yield to USDH holders (barred under MiCA for EU EMTs), the reserve yield is rerouted to HYPE—creating persistent buy-side flow if USDH’s float scales. It’s a seigniorage-style flywheel that fortifies the L1/DEX token rather than the stablecoin itself (Sources: service.betterregulation.com). Strategic moat: If USDH gets serious adoption on Hyperliquid (quote currency, collateral, fees), the buyback stream could reduce circulating HYPE (depending on burn/lock policy) and tighten the Hyperliquid moat against rival perps DEXs (Sources: 21shares.com). Regulatory Context (EU) USDH in the EU = EMT under MiCA. For EU distribution/use, the issuer must be an EU credit/e-money institution (or appropriately passported), publish the required EMT documentation/notifications, and comply with redemption at par and no interest to holders (Article 50). Using reserve income for HYPE buybacks sidesteps interest to holders, but execution/disclosure matter. (Sources: eur-lex.europa.eu; eba.europa.eu, service.betterregulation.com). HYPE (utility token) & market integrity. MiCA Title VI prohibits market manipulation and insider dealing in crypto-asset markets. A standing buyback program linked to USDH’s reserve yield must be run with clear policies, blackouts, ADV caps, and periodic disclosures to avoid manipulation optics—especially if activity touches EU-admitted venues/CASPs (Sources: esma.europa.eu, paulhastings.com). MiCA vs. MiFID II. MiCA excludes MiFID financial instruments; HYPE/USDH are not MiFID instruments per se. (If an instrument offered rights to revenue/dividends, it would be a security under MiFID II and outside MiCA—your separate security-token idea would sit there) (Sources: esma.europa.eu+1, amf-france.org). Opportunities Structural demand driver: If USDH supply scales, buyback flow grows—potentially a persistent positive impulse for HYPE liquidity and price discovery (Sources: Cointelegraph) On-chain dominance compounder: Hyperliquid already commands share; a native EMT can reduce USDC dependence, deepen markets, and further attract market makers/liquidity takers (Sources: 21shares.com) Issuer credibility: Paxos’ regulated pedigree (NYDFS supervision; orderly BUSD wind-down; recent settlement/SEC matter resolved) may soothe counterparty concerns if EU structuring aligns with MiCA (Sources: Department of Financial Services, Reuters). Risks Regulatory execution in the EU. “MiCA-compliant” claims must map to actual EU EMT authorisation and whitepaper/notification; otherwise EU platforms/investors can’t rely on it. ESMA has warned CASPs about misleading compliance marketing (Sources: Reuters). Market-abuse optics. A large, predictable buyback stream can draw manipulation scrutiny if not transparently governed (timing, size, counterparties) (Sources: esma.europa.eu). Concentration & key-person risk. Hyperliquid’s tiny team supercharges agility but heightens operational dependence; any shock to infra/governance could ripple through the perps market (Sources: Medium). Adoption risk. USDH must win share against entrenched EMTs (USDC/EUR-EMTs) and competing proposals (reports mention Frax/Agora bids) (Sources: AInvest). Market Impact (What to watch next) Validator vote / issuer selection and whether USDH gains base-pair status on Hyperliquid. EU structuring: Will there be an EU EMI/credit-institution issuer (or passport) for EU usage? Policy docs: Buyback governance—blackout windows, ADV caps, monthly reporting—to align with MiCA Title VI expectations. HYPE data: circulating supply trends, treasury/validator distributions, and realized buyback volumes post-launch. Actionable Takeaways Traders: Expect liquidity and funding-rate dynamics to shift if USDH becomes a primary quote asset; the buyback stream may reduce HYPE float over time (if burned/locked), affecting perp basis. Institutions: Before using USDH in Europe, verify EMT status (issuer entity, whitepaper/notification, redemption, safeguarding). Treat “compliant” claims as non-binding marketing until documentation is posted. Builders/venues: If mirroring the model, keep the reserve-yield → buyback linkage discretionary, publish policy + disclosures, and avoid “backing/pegged” claims to stay out of EMT interest prohibitions and market-abuse crosshairs. Share Information via Whistle42

Liquidity via Index & Perps—Without Becoming a Security (Revised) You can give a utility token real market visibility—without turning it into a security—by separating roles: keep the token + index/oracle safely in MiCA, and let venues list perps where appropriate MiFID II permissions exist. Our latest tests underscore why this split matters: EU access to perps without KYC is a regulatory tripwire for venues, not a loophole for issuers. Why this “scene-setter” now We’ve just published two compliance pieces on DEX perps and EU law, including an FT Flash Case showing that EU users can fund, swap, and trade perps on Hyperliquid without KYC or geo-blocking. That reality strengthens this plan—not weakens it—because it clarifies where liability and licensing sit: MiCA = where your utility token and index/oracle belong, if you avoid pegs/backing/dividends. MiFID II = where perps live when provided to EU clients—and where the venue/market makers bear authorisation and conduct duties. This article sets the scene for a practical tutorial series that shows how to implement that split—safely and transparently. Read our report on crypto perps and MiFID II compliance here. What readers will learn in the series Designing a MiCA-safe utility tokenClear “do’s and don’ts” (no pegs/backing/dividends; communicate utility, not returns). Publishing a credible index + oracleMethodology, signed heartbeat, public archives—signals, not claims or entitlements. Routing liquidity the compliant wayHow authorised venues (or non-EU venues that exclude EU clients) can list perps on your index; how your IP licence enforces that. Communications & market integrityWebsite wording, disclaimers, and what to avoid (no “backed by,” no “guaranteed,” no solicitation to non-authorised venues). The model at a glance (non-technical) Layer 1 — Program & Token (MiCA):A utility token that unlocks access/fees/rewards in your ecosystem. It is not “backed,” not redeemable for an asset or currency, and does not pay dividends. Layer 2 — Index & Oracle (MiCA context):A transparent methodology transforms on-chain and exchange data into a published index; a signed oracle broadcasts readings and archives them. The index is informational, not a promise. Layer 3 — Venue & Perps (MiFID II for EU clients):Independent venues may list perpetual futures referencing the index. If they serve EU clients, MiFID II obligations (authorisation, KYC/appropriateness, surveillance) apply to them.Your project does not run the risk engine and does not offer derivatives. What changed since our first draft (important) Live tests (from different EU jurisdictions): FinTelegram verified that EU users can fund via Ledger, swap ETH→USDC on Spot, and open perps on Hyperliquid without KYC or geo-blocking. So what? This doesn’t “legalise” perps in the EU—it heightens venue exposure. Our roadmap insists on one of two routes for derivatives liquidity: EU-authorised venues/firms, or Non-EU venues that effectively exclude EU clients (geo-fencing + controls). Implication for issuers: Double down on separation. Keep token + index/o­­racle in MiCA. Do not point EU audiences toward non-authorised derivatives access. Bake compliance into your IP licence. Compliance foundations (plain English) MiCA covers crypto-assets that are not financial instruments (e.g., many utility tokens when you avoid pegs/backing/dividends). MiFID II covers derivatives (e.g., perps) when provided to EU clients. That triggers venue/market-maker responsibilities: permissions, client onboarding, market-abuse monitoring, and disclosures. Reverse solicitation is narrow. Ongoing EU business, EU-facing funnels, or affiliates generally defeat the carve-out. Build like you’ll have to prove non-solicitation. Guardrails for the token & index/oracle (use this as your checklist) Utility token (MiCA): Utility/access/rewards; community governance; fee discounts No pegs/backing/redeemability; No dividends/profit-sharing; No claims of stability Index & oracle (MiCA context): Public methodology + parameter files; signed heartbeat; immutable archives; change-log No “backed by” language; No entitlements; No promises of performance or stability Words to avoid in websites/pitch: “backed by,” “redeemable for X,” “pegged to,” “dividend,” “yield guaranteed,” “stable exposure to…” Guardrails for derivatives routing (the venue’s burden) When a venue lists perps on your index: EU path: Use an EU-authorised venue/firm. Non-EU path: License only to venues that exclude EU clients (geo-fencing, residency attestations, KYC where required). IP licence clauses (mandatory): EU distribution rules (authorised only / geofenced only) No EU marketing for perps without permissions Audit + takedown rights if controls fail Data integrity & attribution requirements for your index feed The value proposition (why this is worth doing) Liquidity and price discovery without turning your token into a security. Transparency via index/oracle boosts credibility, partner interest, and analyst coverage. Compliance by design: Clear split between your MiCA footprint and venues’ MiFID II obligations. Operational flexibility: You can work with EU-authorised venues where available, and non-EU venues that truly exclude EU clients. What’s next in the series (roadmap) Part 1 — Utility Token Playbook (MiCA-safe by design) Part 2 — Index Methodology & Oracle Transparency Part 3 — IP Licensing for Perps (authorised vs geofenced) Part 4 — Communications & Disclosures: do’s/don’ts Part 5 — Monitoring & Governance: audits, change-control, takedown flows (We’ll keep referencing our DEX/Perps compliance reports as living context. If venue practices change, we’ll update call-outs in the tutorial steps.) Share Information via Whistle42