By FinTelegram Editorial Desk Europe built instant, low‑cost payment rails—and accidentally created a paradise for cyber‑fraud. That’s the core message in a new academic paper by Elfriede Sixt, Chairwoman of EFRI and partner in the C42 project, who lays out a data‑driven indictment of today’s liability rules and a blueprint to fix them. Drawing on 1,750 victim cases across 20 countries (losses: €62.5m), Sixt shows how “authorised” push payments induced by deception remain largely unreimbursed, while even clearly unauthorised cases are inconsistently handled across Member States. The result is a double protection gap that erodes trust and rewards bad actors embedded in Europe’s payment stack. European Payment Rails What Sixt finds Europe’s “payment paradox.” Regulators modernised the rails (SEPA Instant & the 2024 Instant Payments Regulation), but consumer protection hasn’t kept pace. APP (authorised push‑payment) fraud shifted losses onto consumers, and redress is fragmented and slow. European Payment Rails Evidence at scale. EFRI’s dataset documents pig‑butchering/investment scams where most funds move via “authorised” transfers or CNP card payments; victims encounter denial, delay, and blame when they seek refunds. Psychological harm and trust loss are widespread, with 39% closing long‑standing bank relationships after the experience. European Payment Rails Gatekeeping failures in the rails. The same small circle of PSPs/acquirers/EMIs and certain banks repeatedly appear at the monetisation layer, onboarding high‑risk merchants, mis‑coding MCCs, and letting mule stacks run. This is contingent, not inevitable—many institutions don’t show these patterns, which supports shifting default liability to the actors best placed to prevent abuse. European Payment Rails Named case studies. Payvision (ING): processed high‑risk “investment” flows, including networks tied to Gal Barak/Uwe Lenhoff; internal figures attribute ~€154m CNP volume to the “Wolf of Sofia” group alone. European Payment Rails Wirecard: operated as a global fraud enabler before its collapse, legitimising illicit flows via acquiring units and subsidiaries. European Payment Rails Københavns Andelskasse (DK): pass‑through hub for scam proceeds; later fined DKK 794m for AML failures. European Payment Rails ADR that doesn’t redress. FIN‑NET and national ombuds schemes are obscure, uneven, and rarely binding; in EFRI’s cohort, no meaningful relief came through ADR. European Payment Rails Download the Research Paper here. What Sixt demands Sixt argues for outcome‑based reimbursement for all fraud‑induced payments—treat consent obtained through deception as no consent—and then align liability with functional control in the scam chain. Her blueprint includes: Reimbursement anchor at the payer’s ASPSP, with calibrated recourse down‑chain (beneficiary PSPs, acquirers, platforms, telcos). European Payment Rails Redefine “consent.” Fraud‑induced authorisations become unauthorised in law, triggering immediate refund rules. European Payment Rails FIN‑NET 2.0 (binding EU‑level ADR) with deadlines, presumptions, and disclosure so victims aren’t re‑victimised. European Payment Rails EU Fraud Data Framework to close opacity gaps and surface cross‑institutional risk signals (mules, layering, MCC camouflage). European Payment Rails Technology duties for PSPs and platforms: name/IBAN checks (CoP/VoP), real‑time analytics, kill‑switches, cross‑sector intel sharing. European Payment Rails The legislative moment: PSR Article 59 is not enough Europe’s Payment Services Regulation (PSR) is the vehicle to fix the gap. Parliament’s 2024 stance broadened coverage and explored shared, cross‑sector liability (PSPs, ECSPs, platforms). But the Council’s 18 June 2025 “General Approach” retreats to a narrow trigger—refunds only if the fraudster impersonated the consumer’s PSP (“bank spoofing”)—with a 15‑business‑day refund clock. That leaves most induced‑consent scams (fake tax, police, brand, marketplace) out of scope and keeps platforms/telcos largely off the hook. Sixt’s view: two PSR landings are realistic, but only the broader reimbursement model aligns incentives across the scam chain and restores trust. Otherwise, Europe cements an equilibrium that rewards institutions and harms consumers. European Payment Rails Why this matters now for cyberfinance: illegal casinos & crypto The paper’s lens on MLaaS (Money‑Laundering‑as‑a‑Service) explains why illegal online casinos and unlicensed crypto platforms keep thriving: they rely on regulated on/off‑ramps—acquirers, PSPs, EMIs, beneficiary banks, and exchanges—to collect, layer, and cash‑out at scale. Where onboarding/monitoring is weak (or willfully blind), these actors become financial crime enablers. Tightening KYCC/EDD, MCC governance, inbound risk‑scoring, mule controls, and beneficiary‑side holds/recalls is essential—and must be backed by default liability so the least‑cost avoiders actually invest in prevention. European Payment Rails Crypto‑native rails don’t sit outside this: scam funds frequently bridge to EMIs/banks for monetisation. Without outcome‑based reimbursement and binding ADR, victims of crypto‑themed pig‑butchering and casino funnels will keep absorbing losses while intermediaries capture fees.

StablR Ltd, a Malta-regulated Electronic Money Institution (EMI), operates within a highly challenging business environment for small stablecoin issuers. With stablecoin issuance stagnating at approximately €11 million for both EUR and USD tokens, the company faces fundamental structural challenges that raise serious questions about its long-term viability and the broader sustainability of small-scale stablecoin operations. The Stablecoin Business Model: Revenue Fundamentals Primary Revenue Streams Stablecoin issuers generate revenue through several key channels, with interest income from reserve management serving as the dominant source. For established issuers like Tether and Circle, approximately 99% of revenue comes from interest earned on reserves. Tether achieved $5.2 billion in profit during the first half of 2024 by investing reserves in US Treasury bills earning 4.72% yields, while Circle reported 53% year-over-year revenue growth reaching $658 million, primarily from reserve interest. Additional revenue streams include: Transaction fees for minting, redeeming, and transferring stablecoins Custodial partnerships and treasury management services API and SDK monetization for institutional clients Compliance and audit services for third parties The Economics of Scale Challenge The stablecoin business model fundamentally depends on achieving significant scale. With reserves of just over €11 million each for EURR and USDR tokens[obtained from proof-of-reserves], StablR faces severe limitations. At current European Central Bank rates of approximately 3.25%, the company’s maximum theoretical annual revenue from a €22 million reserve base would be approximately €715,000 – insufficient to cover operational costs for a regulated financial institution. Compare this to Tether‘s position: with over $140 billion in reserves, even modest yield improvements generate substantial returns. As one analysis noted, “even a meager 2% annual percentage yield (APY) on reserves would generate over $2.4 billion in yearly revenue” for Tether. StablR’s Specific Challenges Regulatory Overhead vs. Revenue Potential Operating as a Malta EMI under MFSA regulation requires significant compliance infrastructure. Malta EMI license requirements include: Minimum initial capital of €350,000 for full EMI licenses At least two Malta-based business controllers demonstrating fitness and propriety Comprehensive compliance framework including AML/CFT procedures, risk management, and regular auditing Ongoing regulatory fees and supervisory costs StablR‘s quarterly attestation reports by Grant Thornton [obtained from proof-of-reserves] represent additional operational expenses that become proportionally more burdensome at smaller scales. Interest Rate Dependency The stablecoin sector’s profitability is directly correlated with interest rate environments. Recent Federal Reserve rate cuts to 4.00%-4.25% have reduced the “easy profit margin model” for stablecoin issuers. This creates particular vulnerability for smaller issuers like StablR, which lack the diversified revenue streams of larger competitors. Market Position and Competition The MiCA Competitive Landscape StablR operates within the newly regulated European stablecoin market under MiCA, which came into full effect in 2024. The regulation has created both opportunities and challenges: Opportunities: Major non-compliant stablecoins like USDT have been delisted from European exchanges, including Kraken, Coinbase, and Crypto.com. MiCA compliance creates differentiation from non-regulated alternatives Tether’s strategic investment and use of Hadron tokenization platform provides technical and financial backing Challenges: Limited market size: The largest MiCA-compliant EUR stablecoin has only €200 million in circulation Intense competition from established players like Circle’s EURC European regulations prevent issuers from sharing yield with token holders, limiting adoption incentives Turkey Market Opportunity StablR‘s allegedly strong position in Turkey aligns with market data showing Turkey has the highest rate of stablecoin purchases relative to GDP globally at 4.3%. Turkish residents use stablecoins to preserve value amid high inflation rates exceeding 67%. However, this market opportunity primarily benefits dollar-pegged stablecoins due to dollarization preferences, potentially limiting StablR’s euro-focused strategy. Systemic Risks and Insolvency Scenarios Structural Vulnerabilities Small stablecoin issuers face unique insolvency risks that could result in massive losses for token holders: Liquidity Risk: Limited reserves make issuers vulnerable to redemption runs, particularly during market stress Operational Risk: High fixed costs relative to revenue create financial strain during low interest rate environments Regulatory Risk: Changing compliance requirements could impose additional costs or operational restrictions Counterparty Risk: Dependence on custodial banking relationships creates concentration risk The Payvision Connection Concerns Serious regulatory concerns surround StablR’s leadership connections to the Payvision scandal. CEO Gijs op de Weegh was a co-founder and active board member for 18 years of Payvision, which processed over €131 million in fraudulent transactions and faced criminal proceedings for systematic AML failures. The European Funds Recovery Initiative (EFRI) has formally requested the MFSA review StablR‘s EMI license, citing: AML proceedings against key Payvision executives being ignored during licensing Opaque ownership chain through Dutch holding Plutus B.V. Risk to EU financial system from allowing actors involved in large-scale money laundering to operate under MiCA Macroeconomic Scenarios and Business Model Viability Favorable Conditions Scenario Under optimistic conditions, StablR could achieve viability through: Scale expansion to €500 million+ in token circulation Interest rate increases to 5%+ enhancing reserve yields Market share capture in Turkey and other high-inflation markets Fee-based revenue diversification through institutional services Stress Scenarios Several macroeconomic conditions could trigger insolvency: Extended low interest rates reducing reserve income below operational costs Competitive pressure from established issuers with superior liquidity and yields Regulatory enforcement actions related to management fitness and propriety Bank runs triggered by confidence loss or technical issues The Zero-Sum Competition Reality JPMorgan analysts describe the stablecoin market as potentially becoming a “zero-sum game” for smaller issuers, where competition is limited to market share battles unless the overall crypto market grows substantially. With the total stablecoin market at $278 billion but representing less than 8% of total crypto market cap, growth opportunities for small issuers remain constrained. Conclusion and Risk Assessment StablR‘s business model faces fundamental challenges that question its long-term sustainability. The combination of high regulatory overhead, limited scale, interest rate dependency, and concerning management connections to financial crime creates a high-risk profile for token holders. The stagnation of token issuance at €11 million levels suggests market recognition of these limitations. Without achieving dramatic scale increases or securing sustained higher interest rate environments, StablR risks becoming another cautionary tale in the small stablecoin issuer space. For the broader stablecoin ecosystem, StablR represents the challenges facing second and third-tier issuers attempting to compete with established giants like Tether and Circle. The “stablecoin sandwich” cross-border payment model may provide some utility, but insufficient scale and regulatory overhead make sustainable profitability unlikely. Call for Whistleblowers FinTelegram calls upon insiders with knowledge of StablR‘s operations, financial condition, management decisions, or connections to the Payvision scandal to provide information through our secure whistleblower platform Whistle42.com. Your confidential disclosures can help protect investors and ensure regulatory accountability in the evolving stablecoin sector. Information of particular value includes: Internal financial reports and business projections Management communications regarding business strategy Details of Turkish market operations and partnerships Documentation of reserve management practices Evidence of connections to Payvision or Rudolf Booker entities Contact FinTelegram securely and anonymously at Whistle42.com to submit information that serves the public interest in financial transparency and investor protection. Share Information via Whistle42.

The Hyperliquid USDH stablecoin proposal, led by Paxos, marks a pivotal step in merging compliance, DeFi innovation, and token incentives. This report dissects what USDH aims to be, the mechanics behind it, and the ongoing debates that have surfaced in the crypto community. It raises key questions for insiders regarding transparency, governance, and ecosystem impact. What Is the USDH Stablecoin? USDH is planned as a blockchain-native stablecoin for Hyperliquid, backed 1:1 by fiat assets—including liquid instruments like Treasury bills and cash reserves. Paxos, already a reputable name with regulated fiat-backed coins (USDP), is leading the development. The core selling point: USDH is not just a generic dollar token, but tailored for decentralized finance (DeFi) on Hyperliquid’s fast, high-volume blockchain. Mechanically, USDH’s reserves are intended to generate interest, with 95% committed directly to buying back Hyperliquid’s primary token, HYPE. These HYPE tokens are then distributed as rewards to developers, validators, and users. This “buyback-reward” feedback loop aims to tie the stablecoin to network health and activity—unlike most competitors whose yield is sequestered by their own platforms or parent companies. Analysis: Why Is USDH Drawing Attention? Compliance and Trust Hyperliquid seeks to distinguish itself by anchoring USDH on strict regulatory standards—GENIUS Act (US) and MiCA (EU)—in pursuit of institutional money and mainstream adoption. This is a bold promise in an industry often criticized for regulatory ambiguity and compliance risks. However, only time will tell if Paxos and Hyperliquid truly deliver on these claims or whether regulatory supervisors will scrutinize their business models for actual transparency. Tokenomics: The HYPE Buybacks The unique structure, where 95% of USDH reserve interest funds are used for token buybacks, distributing rewards to network actors, creates questions about long-term sustainability. Will this lead to pump-and-dump cycles? How transparent will the allocation and distribution be? What safeguards exist to ensure insiders or large holders don’t disproportionately benefit? Centralization vs. Decentralization While Hyperliquid positions itself as a decentralized player, Paxos—a centralized, regulated firm—controls the stablecoin’s reserves and issuance. Will this duality prove resilient, or will it create governance tensions? As a precedent, similar arrangements have triggered regulatory investigations or discontent among community members who fear censorship or asset freezing. Critical Questions for Insiders & Industry Observers What mechanisms guarantee transparency in USDH reserve management, yield tracking, and HYPE reward allocations? How does Hyperliquid plan to prevent manipulation of HYPE’s price from coordinated buybacks—or, conversely, pump-and-dump risks? Who decides protocol-level changes to USDH and HYPE reward distributions? Is this truly governed by smart contracts, or is there off-chain discretion? Can users audit the fiat reserves backing USDH in real time? Will the platforms offer independent proof-of-reserves or just periodic attestations from Paxos? What oversight do European and US financial regulators have over Hyperliquid’s operations, and how are cross-jurisdictional compliance concerns being handled? How does Hyperliquid intend to balance growth incentives with systemic stability? Are there protections against rapid capital flight, depegging, or loss of confidence in USDH? Conclusion and Call to Insiders The USDH stablecoin could transform network incentives and DeFi adoption if executed transparently and sustainably. Yet, the project raises complex questions around regulatory legitimacy, governance, and economic consequences for the HYPE ecosystem. Share Information Insiders, compliance managers, and blockchain developers: What can you tell us about Hyperliquid’s true processes, controls, and philosophy? Are the transparency claims marketing spin, or is this a genuine leap in crypto governance and regulation? The industry is watching, and your answers matter now more than ever. Share Information via Whistle42

Austria had the Signa Group, and Switzerland has the Steinblick case. The unfolding Steinblick AG affair has erupted into one of the most severe and symbolic real estate scandals in recent Swiss history. What began as an ambitious developer’s rise in the Limmattal region has ended—at least for now—with criminal indictments, paralyzed construction, and millions in losses suffered by major Swiss banks. Background: Company and Key Figures Steinblick AG, founded in 2017 and headquartered in Dättwil, positioned itself as a vertically integrated real estate developer, promising completion and delivery of high-value residential projects near Baden and across the Limmattal sector.Its operations were led by CEO Shaqir Berisha, with management participation from Ahmer Nedjiposki—both of whom are now central to the investigation. They are both Kosovarian nationals. The Crisis Unfolds: Banking Losses and Legal Action By spring 2024, alarm signals became unmistakable. The Raiffeisenbank Wasserschloss was forced to write down multimillion-franc loans to Steinblick—effectively erasing capital and triggering the removal of executive management. Other lenders, including Valiant, Luzerner Kantonalbank, and WIR Bank, soon found themselves bracing for similar or even greater losses. Bank insiders report that in response, all major credit lines to Steinblick AG were promptly terminated. Parallel to the mounting financial crisis, several “Grundbuchsperren” (land register blocks) were imposed against company assets; construction sites were frozen; development investors, creditors, and local subcontractors were left in limbo. The criminal dimension has now come into sharp relief. The Aargau Public Prosecutor has confirmed ongoing criminal complaints against Steinblick’s leading figures—including, but not limited to, charges of document forgery. Investigations are underway, with the scope and legal qualification of proceedings yet to be finalized. It is reported that CEO Berisha has already left Switzerland for the Middle East, with suspicions of asset flight and personal enrichment raised. Systemic Failures: A Forensic Assessment The Steinblick AG episode is not just a tale of one developer’s collapse, but a mirror held up to systemic failures across the Swiss banking and regulatory framework: Compliance Lapses: Despite clear risk factors, banks disbursed large loans to Steinblick AG, circumventing or disregarding FINMA’s lending criteria around collateralization, equity, and borrower transparency. Supervisory Complacency: The contagion was facilitated by inadequate due diligence, insufficient market intelligence, and risk departments systematically overridden by profit-seeking management. Sector-Wide Symptoms: The narrative is disturbingly familiar—parallels to the Benko/Signa collapse, Greensill, and other high-profile frauds are widely noted by experts and lay observers alike, heightening concerns of a broader property bubble. Public Reaction and Narrative Warfare The case has polarized observers. Some among the public and former associates defend the protagonists, arguing that investigations concern only isolated individuals and not Steinblick AG as a corporate entity. Yet the depth of integration between management and the company—combined with ongoing asset freezes and pending insolvency signs—point to an enterprise-wide disaster, not merely “one bad actor”. Others argue the Swiss system has once again allowed itself to be exploited, with compliance failures now laid bare for both regulators and taxpayers. Name / EntityTypeRole / InvolvementWebsite / LinkedIn ProfileSteinblick AGCompanySwiss real estate developer at the center of scandalsteinblick.ch, Steinblick LinkedInShaqir BerishaIndividualCEO, Chief Executive, investigated by authoritiesShaqir Berisha LinkedInAhmer NedjiposkiIndividualGeschäftsführer (Managing Director), co-investigatedAhmer Nedjiposki LinkedInRaiffeisenbank WasserschlossBankMajor creditor, wrote off multimillion loans–Valiant BankBankExposed creditor, terminated credit lines–Luzerner Kantonalbank (LUKB)BankExposed creditor, risk of loan default–WIR BankBankExposed creditor, risk of loan default– Notes: Steinblick AG is registered in Baden/Dättwil, Switzerland. The CEO and Managing Director are under criminal investigation, reportedly have left the country. The listed banks provided substantial credit to Steinblick and face substantial losses in the aftermath. The domains and LinkedIn profiles for the company and key individuals are verified and current. The Outlook Steinblick AG is functionally incapacitated. Its core leadership is absent, assets are blocked, banking relationships terminated, and construction sites abandoned. Swiss banks now face multi-million-franc write-offs, reputational damage, and increased regulatory scrutiny. Above all, the affair raises grave questions about the capacity and willingness of the Swiss financial system to enforce its own rules in the face of sophisticated, high-risk real estate operators. Conclusion: The collapse of Steinblick AG is a wake-up call—illuminating the urgent need for a return to robust due diligence, independent risk controls, and unwavering regulatory enforcement within the Swiss financial sector. Compliance failures are not merely statistical outliers; in the current environment, they now carry system-wide consequences. Share Information via Whistle42

Boris Pustovoytov is a Russian travel entrepreneur; public face of premium, “expedition-style” trips marketed to Russian-speaking high-net-worth clients. Founder of Dubai-based TRVL (a/k/a “TRVL – Beyond Ordinary”) and co-founder of Moscow-marketed NEVEREND. On social media (Instagram), he self-identifies as an entrepreneur and co-founder of Neverend (Sources: TRVL.global, Scam-Or.com). There are no official fraud charges against Pustovoytov personally. However, his flagship North Pole charter collapsed amid a high-risk crypto payments connection (Evita/Goognin), leaving an $8.5m hole and litigation with Ponant. The episode exposes sanctions-evasion and AML vulnerabilities around his operation and raises sharp questions about counterparties, UBO opacity, and marketing to a sanctioned-exposed client base. (Source: ft.com). 1) Why he matters now In August–September 2025, TRVL’s charter of Ponant’s Le Commandant Charcot for a “polar party” to the North Pole was cancelled after U.S. authorities arrested crypto-payments founder Iurii (George) Gugnin, whose Delaware companies (Evita Investments/Evita Pay) were brokering charter payments. TRVL then sued Ponant in France, claiming $5.8m already paid (of an $8.5m charter) plus damages; Ponant cited compliance concerns tied to Evita. Russian and international media widely covered the cancellation and suit (Sources: FT.com, Scam-Or.com) Separately, the U.S. Department of Justice unsealed a 22-count indictment against Gugnin (a/k/a Iurii Mashukov and George Goognin in June 2025, alleging he used Evita to move >$500m through U.S. banks/crypto while concealing sanctioned Russian ties. The DOJ filings do not name Pustovoytov or the cruise transaction. However, according to the whistleblower reports available to us, there are close personal and economic ties between Pustovoytov and Gugnin. (Source: justice.gov). 2) The Scam-Or Project Allegations In an interesting piece of investigative work, Scam-Or (“Boris Pustovoytov’s Crypto Scandal Sinks Russian Elite’s $8.5M Polar Party”) frames the trip as financed by illicit funds and asserts that TRVL’s UBO is Dmitry Portnyagin (a prominent Russian business blogger and Pustovoytov’s known collaborator). The article leans on FT and DOJ reporting and highlights sanctions/compliance risks around the broker (Evita). We note that its UBO claim is not independently evidenced in the piece; we could not verify TRVL’s ownership in open corporate records. Context & cross-checks: NEVEREND’s own site and comms show Portnyagin as co-founder and actively promoting the North Pole expedition, aligning with the “TRVL/NEVEREND ecosystem” narrative — but doesn’t by itself prove TRVL’s UBO (Source: neverend.travel) FT (paywalled) sets out the cancellation, Evita’s role, the refund dispute, pricing ($70k–$200k per cabin) and client profile, but does not allege Pustovoytov’s personal fraud. ft.com Russian outlets (TASS, Vesti) cite Pustovoytov as TRVL’s founder and repeat the €7–7.5m claim demanded from Ponant — again, no fraud charges against him (Source: TACC). Analyst view: Scam-Or’s compliance angle (sanctions risk, third-party broker) is credible and consistent with FT/DOJ. Assertions about illicit origin of guest funds or TRVL’s UBO remain unproven in public sources and are open questions pending documentation (Source: Scam-Or.com). 3) Who is Boris Pustovoytov? Travel operator & frontman: Markets ultra-high-touch, “expedition-style” itineraries via TRVL (global/English) and NEVEREND (RU-market). Testimonials and marketing place “Boris” front-and-center on trips. Russian registrations: As an individual entrepreneur (ИП) in Moscow, primary activity “tourist agencies”; the ИП was voluntarily liquidated on 14 Jan 2025. (This doesn’t speak to TRVL/NEVEREND corporate status offshore.) (Source: rusprofile.ru). Media presence (RU): Profiled in Russian business/travel media as co-founder of NEVEREND; interviews describe premium travel “production” and a North Pole expedition project. Note: one feature is marked “partner material” (sponsored). 4) Timeline of the polar-party collapse (public record) Oct 2024–May 2025: Marketing ramps; NEVEREND promotes North Pole expedition; TRVL positions as operator. June 9–10, 2025: DOJ indicts Iurii/George Gugnin; details Evita’s alleged $500m laundering pipeline (no mention of TRVL). Aug–Sep 2025: Ponant cancels charter citing the payments broker; TRVL sues in France seeking €7m+; media coverage in FT and Russian outlets. 5) Red-flag indicators (AML/sanctions/FC risk) Third-party crypto payments broker at the center of DOJ sanctions-evasion case. Even if unrelated to the cruise, association risk is high. Why use an unlicensed, crypto-heavy broker in a sensitive, high-value EU transaction? Sanctions-exposed clientele (Russian elites) + Arctic itinerary with political sensitivities (Svalbard/North Pole) = heightened KYC/PEP/sectoral-sanctions risk. Did TRVL/NEVEREND perform independent PEP/sanctions screening and SOF/SOW verification matching $70k–$200k tickets? UBO opacity: Public materials link TRVL/NEVEREND to Pustovoytov and Portnyagin, but we found no authoritative registry confirming TRVL’s beneficial ownership. Scam-Or’s claim that Portnyagin is UBO remains unverified. Demand docs. Corporate segmentation/jurisdictional arbitrage: RU-facing brand (NEVEREND) paired with UAE booking entity (TRVL). Check booking flows, payment processors, and any split-invoicing across jurisdictions. Voluntary closure of RU sole-proprietor vehicle (Jan 2025) just before the North Pole trip window — possibly routine, but the timing merits review of liabilities/contracts migrating offshore. 6) What we can say — and what we cannot Supported: Pustovoytov is the public founder/face behind TRVL/NEVEREND; the North Pole charter collapsed after the Evita/Goognin arrest; TRVL is suing Ponant for €7–7.5m; no public fraud charges exist against Pustovoytov. Alleged but unproven: That TRVL’s funds or guest payments were illicit, or that Pustovoytov personally perpetrated fraud/scam. These are whistleblower and media allegations, not judicial findings. 7) Open questions for further inquiry Payments trail: Exact on-/off-ramps used by Evita (exchanges, banks, stablecoin rails), KYC files for TRVL, and whether Ponant’s “approved broker” vetting actually occurred as claimed. Ownership/control: Articles of association/UBO certificates for TRVL (UAE), any offshore affiliates, and contractual links to NEVEREND (RU). (Scam-Or’s UBO assertion remains uncorroborated.) Client screening: PEP/sanctions checks, source-of-funds attestations for 150+ guests; any refund liabilities or chargebacks post-cancellation reported by TRVL. Prior complaints: Any consumer, civil or criminal filings involving Pustovoytov/NEVEREND/TRVL in RU/UAE/EU courts; Russian registry shows the ИП ceased activity, but court/arbitration history is sparse in open sources. 8) Analyst assessment (interim) Pustovoytov built a high-touch travel brand targeting a sanctions-sensitive clientele and plugged a crypto payments intermediary into a large EU charter — a classic AML/sanctions own-goal once the intermediary was indicted. That alone doesn’t make him a fraudster, but it does indicate weak counterparty risk management and heightened exposure to illicit-finance vectors. Until audited ownership records, payment flows, and guest KYC files are produced, treat the ecosystem as high-risk and escalate enhanced due diligence. Key sources Financial Times: overview of cancellation, charter sums, Evita’s broker role, and TRVL’s lawsuit. DOJ (EDNY & OPA): Evita/Gugnin indictment and alleged $500m laundering scheme (context for broker risk). TRVL site (about/marketing) & NEVEREND news item (Portnyagin co-founder, North Pole promo). Russian media (TASS, Vesti, RFI-RU): lawsuit sums, quotes naming Pustovoytov as TRVL founder. Scam-Or Project: investigative framing and unverified UBO claim; treat as allegation pending documents. Rusprofile (RU registry): Pustovoytov’s ИП (tourism) existed 2017–2025; voluntarily liquidated. Call for information (Whistle42) If you worked with TRVL/NEVEREND, were on the North Pole guest list, processed payments, or have internal ownership/payment documents (UBO certificates, KYC files, invoices, broker agreements, sanctions screening), we need to hear from you. Share securely via our whistleblower platform Whistle42. Anonymity respected; verifiable documents are most valuable. Share Information via Whistle42

The German Federal Court of Justice (BGH) has confirmed a three-and-a-half-year prison sentence for former Freshfields tax partner Ulf Johannemann, following his conviction for aiding serious tax evasion in connection with the Cum-Ex scandal. This marks a major milestone in Germany’s fight against what is considered the country’s most complex tax fraud case. Background: The Cum-Ex Scandal The Cum-Ex scheme involved rapid trading of shares around the dividend cutoff date, creating confusion over ownership and enabling multiple parties to claim tax refunds for taxes that had only been paid once. Between 2001 and 2016, this practice resulted in Germany losing roughly €30 billion. Banks, brokers, and their advisors exploited this loophole, presenting it as legal tax optimization, although the courts later clarified these were cases of deliberate and aggravated tax evasion. Details of the BGH Ruling Ulf Johannemann—formerly Head of Global Tax at Freshfields—provided German bank Maple Bank with legal opinions that downplayed the risks and legality issues of Cum-Ex transactions. The BGH established that his legal advice omitted major counterarguments and gave executives a false sense of legal certainty, facilitating trades that led to €374 million in state tax losses. His conviction affirms that enabling or justifying such schemes through manipulated legal assessments constitutes criminal participation in tax fraud. This decision expands criminal liability not only to dealmakers and banks but also to external legal advisors whose work plays a critical role in facilitating criminal financial schemes. The courts believe the responsible Maple Bank managers would not have undertaken these trades without Johannemann’s misleading guidance. Implications for Legal and Financial Sectors The latest BGH ruling sets a precedential tone for ongoing and future cases involving Cum-Ex and other tax structuring abuses. Legal opinions and advisory notes, especially those used to justify high-risk financial constructions, will be subject to ever closer scrutiny, and their authors may face criminal prosecution if found complicit. This is a clear warning to legal and financial professionals against using expertise to “legitimize” dubious, abusive tax minimization structures. The judgment also strengthens prosecutors’ ability to pursue enablers—including law firm partners and compliance advisors—who make large-scale tax fraud possible. Several more high-profile trials involving lawyers and bankers are expected, with the German judiciary showing resolve to recover billions lost to such schemes. Conclusion The BGH decision marks a new legal era in the fight against complex financial crime in Germany, demonstrating that criminal accountability reaches beyond direct perpetrators to include those providing legal and regulatory cover for fraudulent activities. The case serves as a clear message: expert advice that facilitates large-scale public harm through deliberate evasion will result in serious personal consequences. Share Information via Whistle42

Crypto payment processor MoonPay has announced the acquisition of Meso Network (website), a crypto payment infrastructure startup specializing in bridging traditional banking systems and cryptocurrencies—a move designed to advance MoonPay’s ambition of building a global, regulated payments network that serves fintech, casino, and gaming sectors, among others. Transaction Details Nature of Deal: MoonPay acquired Meso for an undisclosed sum, integrating its API-based technology for seamless connections between classic finance rails (like ACH and real-time payments) and major blockchains. Leadership Changes: Meso founders—seasoned fintech veterans formerly with Braintree, Venmo, and PayPal—take senior roles at MoonPay to accelerate product innovation and developer integration. Strategic Rationale: The deal strengthens support for US banking networks, enhances developer tools, and solidifies MoonPay’s edge against competitors like Visa and Circle, especially in high-risk sectors like gambling and casinos. MoonPay’s Role in Online Gambling Recent investigations, including FinTelegram’s analysis, have exposed MoonPay’s ongoing facilitation of payment services for a variety of online casinos—some of which operate without recognized licenses and are therefore classified as illegal by regulators: Read our report on MetaWin here. MoonPay acts as the primary payment gateway for MetaWin, a crypto casino, enabling customers to fund accounts with fiat or crypto through its platform, even in jurisdictions where gambling licenses are absent or expired. The firm’s crypto ramp lets consumers bypass KYC controls by leveraging its integrations, thus supporting offshore and unregulated gambling operations. Compliance and Regulatory Concerns Licensing: Despite possessing Money Transmitter licenses in 47 US states, and BitLicense/MiCA registrations, MoonPay’s business development in high-risk sectors raises questions about its diligence and risk controls. Regulatory Evasion: Authorities face challenges due to the structure MoonPay provides: customers buy cryptocurrency through MoonPay and instantly transfer funds to casino-controlled wallets, circumventing chargeback and AML mechanisms. Reported Issues: Multiple independent sources flag MoonPay’s willingness to serve casinos flagged by regulators for illegal activity, contributing to an environment where unlicensed gambling flourishes under the guise of regulated payments tech. Critical Analysis MoonPay’s acquisition of Meso Network extends its influence and technical reach, especially into contentious and poorly supervised areas such as online gambling. The repeated disclosures by FinTelegram and compliance observers suggest MoonPay‘s risk controls may be insufficient for the scale and impact of its sector involvement, particularly regarding unlicensed casino schemes. As MoonPay continues acquiring and integrating payment startups, regulatory scrutiny and critical inquiry into its facilitation of risky business models—in violation of financial crime and licensing rules—should intensify. Share Information via Whistle42

A fresh cross-border investigation ties fugitive ex-Wirecard COO Jan Marsalek to Moscow safe-harbor, FSB proximity pings, and—most explosively—allegations he fought for Russia in the Ukraine war. In Munich, former CEO Markus Braun (also Austrian) remains on trial after prosecutors dropped some counts to speed proceedings; Braun’s line hasn’t changed: Marsalek ran a criminal network that deceived him. Notably, in July 2023, Marsalek wrote to the court via his lawyers asserting the Asian Third-Party Acquirer (TPA) business was real—a claim at the center of Braun’s defense. Wirecard still stands as one of Europe’s largest financial-crime collapses. Key Points Moscow, false IDs, FSB orbit: Partner outlets tracked devices linked to Marsalek hundreds of times near the FSB’s Lubyanka HQ (2024) and published current imagery; the consortium reports allegations he “fought for Russia” in Ukraine. (Allegations not adjudicated.) (Source: t-online). UK spy-ring cases: Old Bailey proceedings and CPS materials depict a Bulgarian cell run for Russia and directed by Marsalek, with jail terms handed down in May 2025 (Source: Financial Times). Braun trial still live: Munich prosecutors trimmed charges but maintained core fraud counts; Braun continues to blame Marsalek (Source: Financial Times). The 2023 Marsalek letter: Via counsel, Marsalek confirmed the TPA business existed, challenging state witness Oliver Bellenhaus; court confirmed receipt of the letter (Source: luxtimes.lu). Context: Wirecard’s 2020 implosion exposed a €1.9bn hole, triggering sprawling criminal and civil fallout still playing out in 2025 (Source: Reuters). Short Narrative The latest consortium reporting crystallizes a transformation: Marsalek, once the wunderkind COO of Germany’s fintech champion, now appears embedded in Russia’s ecosystem, allegedly combat-adjacent and intelligence-linked. This security-state overlay reframes the Wirecard saga from “plain corporate fraud” into a hybrid threat nexus: espionage, disinformation, and wartime logistics. Back in Munich, Braun’s defense leans hard on the reality of Asian TPA revenues—a position Marsalek himself bolstered in 2023—even as investigative work across Europe portrays Marsalek as a Kremlin asset who fled in 2020 and never looked back (Source: t-online). Extended Analysis (Concise) FSB adjacency isn’t exculpation—but it matters. Repeated device pings near Lubyanka and Moscow residency under false identities make extradition or witness access improbable, complicating evidentiary lines that could aid (or undercut) Braun (Source: t-online). The UK cases harden the “spymaster” frame. CPS narratives and FT coverage of the Bulgarian spy cell establish Marsalek’s tasking/coordination role, moving him from rumor to courtroom-tested actor (Source: cps.gov.uk). TPA letter vs. fraud thesis. While Marsalek’s letter backs Braun’s “TPA was real” argument, multiple probes (and the insolvency math) keep pressure on the fictitious-revenue hypothesis. The court will ultimately weigh witness credibility and payment/settlement evidence from Asia (Source: Reuters). Call for Information FinTelegram invites insiders, ex-contractors, TPA merchants, settlement banks, and compliance officers to submit documents securely via Whistle42—especially invoices, bank statements, SHA-2 hashes of payment files, and email headers evidencing TPA cashflows or post-2020 Russian facilitation. Share Information via Whistle42

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.