Venezuela, sitting on one of the world’s largest oil reserves, is no longer just selling crude in dollars. Under Nicolás Maduro, state oil company PDVSA is increasingly settling exports in Tether’s USDT, a dollar‑pegged stablecoin, to bypass U.S. sanctions and banking controls. This shift does not end dollar influence in oil, but it moves critical flows off the U.S.‑controlled banking grid and into opaque crypto rails—posing new challenges for Washington’s already strained, debt‑laden financial hegemony.​ USDT vs Petro‑Dollar: A Sanctions‑Driven Pivot Since 2024, PDVSA has re‑engineered its contracts to require that around half of many spot crude shipments be prepaid in USDT via digital wallets, pushing new clients into crypto‑based settlement and away from traditional correspondent banking. By 2025, more than 50% of crude shipments were reportedly partially or fully paid in USDT, with stablecoin inflows of roughly 119 million dollars reaching the private sector in a single month.​ This marks a decisive break with the classic petro‑dollar model, in which oil is invoiced, cleared, and stored in the U.S. banking system and Treasuries. Venezuela still references the dollar as unit of account, but execution now occurs on blockchains rather than via banks subject to OFAC and SWIFT. The strategy serves three objectives: Sanctions evasion and asset protection: USDT payments reduce the risk that proceeds are seized in foreign bank accounts under U.S. measures.​ Parallel “digital dollar” market: Caracas resells USDT domestically for bolívars, injecting hard‑currency liquidity while bypassing official FX channels.​ Template for other sanctioned oil exporters: Russia and others are already experimenting with crypto and stablecoins for energy trade, embedding de‑dollarisation into commodity flows.​ Strategic Risk for a Heavily Indebted U.S. For the United States, the danger is less about losing the dollar as unit of account in oil, and more about erosion of control over dollar‑linked flows. If major energy exporters can routinely clear large volumes via private stablecoin issuers outside the regulated banking core, U.S. sanctions, surveillance, and—ultimately—demand for U.S. Treasuries are gradually weakened.​ Yet Venezuela’s bet is fragile. USDT is centralized: Tether has already frozen addresses linked to sanctioned Venezuelan activity, proving that Washington can still exert pressure through issuers and key compliance choke points. A single freeze event could instantly strand millions in oil revenue, underscoring the geopolitical and counterparty risk of building an oil strategy on a private stablecoin.​ Conclusion Venezuela’s move to a USDT‑denominated oil trade is a live‑fire test of how far stablecoins can chip away at the operational dominance of the petro‑dollar without replacing the dollar itself. In a world of weaponised finance and mounting U.S. debt, every barrel settled in off‑bank “crypto dollars” marginally reduces Washington’s leverage—while pushing sanctioned regimes into a precarious dependency on opaque, privately run digital dollar infrastructures. The real contest is no longer dollar vs non‑dollar, but on‑shore dollar law vs off‑shore dollar technology. Share Information via Whistle42

Austria’s fallen real-estate tycoon René Benko and his wife Nathalie Benko are facing a second indictment for fraudulent bankruptcy (betrügerische Krida). Prosecutors allege that cash and luxury assets were secretly moved into a family safe to keep them out of the insolvency estate. The case escalates Benko’s already serious criminal exposure after a first, non-final prison sentence. Key Facts Forum & timing: Second criminal trial opens today before the Regional Court in Innsbruck; Benko remains in pre-trial detention since January 2025 (Sources: kurier.at, FinTelegram). Accused: René Benko as main defendant; wife Nathalie as alleged accomplice (Beitragstäterschaft) (Source: kurier.at). Core allegation: Concealment of approx. €120,000 cash plus luxury watches, cufflinks, and jewellery worth about €250,000–370,000 in a safe at relatives’ home, thereby reducing the pool available to creditors. Legal qualification: Fraudulent bankruptcy / insolvency-related asset transfer (betrügerische Krida), with a 1–10 year sentencing range (Source: DIE WELT). First trial: In October 2025, Benko was convicted in Innsbruck and sentenced to 24 months imprisonment over a €300,000 transfer to his mother; judgment not yet final (Source: Reuters). Short Analysis FinTelegram has documented for months how the Signa collapse evolved from a corporate insolvency into a full-blown criminal complex, with creditor claims approaching €40 billion and multiple WKStA investigation strands (Source: fintelegram). The new “safe case” fits the broader pattern already highlighted in previous FinTelegram reports: targeted asset shifts, opaque family-foundation structures, and luxury items quietly removed from the reach of insolvency administrators. Here, prosecutors allege a joint plan: Nathalie is said to have organised the safe at relatives, moved cash and watches there, and even asked that paperwork be destroyed to obscure the timing around Benko’s personal insolvency filing (Source: Kurier). Legally, this second indictment is critical. If the new charges also end in a conviction, courts will have to aggregate sentences. Against the backdrop of ongoing investigations into foundations, gold transfers, and advisory networks, the Benko proceedings increasingly define how Austria handles high-profile asset stripping in mega-insolvencies. Call for Information FinTelegram will continue to follow the Benko trials and the wider Signa Crime Case. Insiders, former employees, advisers, and counterparties who have information on asset transfers, foundations, or hidden valuables around René and Nathalie Benko are invited to share documents and evidence securely via Whistle42.com. Share Information via Whistle42

Noda, which poses itself as a payments service provider, recently saw some leadership reshuffling. As is evident from LinkedIn, a number of senior leaders left Noda in October 2025 – including CEO Igor Loktev (one of the co-founders), CRO Michael Bystrov, COO Anastasija Tenca, and many others. What has happened to the payments company, and who really runs it now? Noda’s Shareholders & Key People Firstly, let’s establish Noda’s registered locations. On its website, it is stated that for the payment initiation within the UK, the company’s official name is Naudapay Limited registered in London. Meanwhile, for the tech services within the EU, it’s Noda Holdings Limited, registered in Nicosia, Cyprus. One of the directors of the UK company NaudaPay (incorporated in 2018) was former COO Anastasija Tenca, yet in October 2025, her appointment was terminated (as is evident from LinkedIn too). Currently, the director of the UK company is Irina Konstantinova, a Latvian citizen. According to LinkedIn, she’s been in that position for seven years. Meanwhile, Noda’s co-founder Lasma Kuhtarska – who appears to be the only person from the original team still at Noda – is stated as the person with significant control, with 75% or more ownership of shares. Previously, entrepreneur Dmitri Volkov was one of the major shareholders too, yet his control ceased in 2023. Leadership Shifts to the UK There are two new UK-based leadership team members – financial director Ksenia Cohen and executive advisor Alex Batlin, who recently wrote an article about what the latest AWS outage means for the payments sector. NamePositionLocationPrevious relevant experienceKsenia CohenFinance DirectorUKEYAlex BatlinExecutive AdvisorUKBitpanda, UBS There are also a few UK-based leadership jobs advertised on LinkedIn. For example, Head of Analytics, Data Analyst, AML/KYC Risk Analyst, Product Designer – which suggests Noda may be shifting more of its team to the UK. Additionally, there are rumors that the expected Managing Director will be UK-based, along with the rest of the decision-making team. Noda’s UK address is 162 Buckingham Palace Road, which appears to be a “stylish co-working space”. What Has Changed with Noda Product? Are these position and location changes normal scaling adjustments or signs of deeper restructuring? Is there any disruption to the client-facing side of Noda, and what are the key changes to Noda’s product? Noda’s offering hasn’t changed. Its products still include open banking and card payments and payouts, checkout form, no-code pages, payment links and QR codes, interactive donation buttons (Noda Prime), sign-in via bank, and data enrichment. This suggests there hasn’t been a major disruption to Noda’s product.  Noda’s open banking network covers 2,051 banks across 28 countries – 250 in Europe, and full bank coverage in the UK. In the latest LinkedIn post, Noda stated that 1.7 million new users paid with Noda in the past six months, with 60% of them returning to this payment method. Possible Motives Behind Noda’s Restructuring So, if nothing else has changed with the product, what were the reasons for Noda’s leadership team restructuring in October-November 2025? As pointed out by Noda’s co-founder in the latest interview, Noda was built as an IT company, and its current competitive advantage lies in technology and accessibility. As for the future of Noda, she said that Noda will keep its focus on the UK and European payments. It’s possible that the current restructuring is strategy-lead or to refine corporate governance, yet there were no comments about this in the interview. Share Information via Whistle42

Bitcoin wallets that interact with certain privacy protocols are increasingly treated by exchanges and analytics providers as “high-risk” – even when there is no proven wrongdoing. This reflects a wider shift: in today’s regulatory environment, mixers are no longer just a niche privacy tool, but a core AML/CTF concern. Andjela Radmilac published a nice piece on this subject recently. 1. Mixers in simple terms Mixers (or tumblers) are services or protocols that: Take in crypto from many users Shuffle or transform the funds Return coins that are harder to link to the original sender There are two broad types: Custodial mixers – an operator takes custody of coins, pools them, and sends back “clean” outputs. Non-custodial mixers / CoinJoin tools – users keep control of their keys while a protocol builds a joint transaction with many similar inputs and outputs. The goal is transaction privacy; the side-effect is that law enforcement and regulators see them as deliberate obfuscation infrastructure. 2. UTXOs and why Bitcoin is transparent Bitcoin uses a UTXO model (Unspent Transaction Outputs). Each coin you hold is one or more UTXOs with a fixed amount and a full on-chain history: Every UTXO can be traced back through each spend The entire graph of transactions is public and permanent Blockchain analytics firms cluster addresses, identify known entities (exchanges, darknet markets, mixers) and score wallets and UTXOs by their exposure to illicit activity. In other words, Bitcoin is pseudonymous but highly transparent – exactly why mixers emerged. 3. The legal and regulatory view Across major jurisdictions, the trend is clear: United States: FinCEN treats custodial mixers as money transmitters subject to full BSA AML/KYC obligations. OFAC has already sanctioned specific mixer protocols and addresses in the past. Operating or servicing a mixer without compliance can trigger criminal and sanctions exposure (Source: FinCEN). European Union: Under the new AML package and the upcoming AMLA, crypto service providers are “obliged entities.” Centralized mixers are seen as unlicensed financial intermediaries; coins linked to mixes or CoinJoin often receive high risk scores in KYT (Know Your Transaction) systems and trigger enhanced due diligence or outright blocking (Source: EU Council). Global standards (FATF): Mixers collide head-on with the Travel Rule and risk-based AML expectations. Even where there is no explicit ban, interaction with mixers is treated as a material risk factor (Source: AML Watcher). 4. Blockchain transparency and modern KYC/AML tooling Contrary to popular belief, blockchain is not a shadowy black box. From a compliance standpoint, it is often more transparent than traditional banking: Every transaction is public, timestamped, and immutable. Analytics providers (Chainalysis, TRM Labs, Elliptic, etc.) map addresses to known entities, identify obfuscation services, and generate risk scores for UTXOs and wallets (Sources: Chainalysis, yellow.com). These tools integrate directly with exchange and bank monitoring systems to: Auto-block known illicit sources (sanctioned wallets, darknet markets, ransomware addresses), Flag mixer exposure and cross-chain obfuscation, Support SAR filing and law-enforcement investigations. For law-enforcement, as one practitioner-oriented guide notes, blockchain analytics now allows officers to follow the trail from crime scene to cash-out venue in a way that is difficult to replicate with physical cash (Source: ACFS) This is exactly why mixers have attracted so much attention: they are one of the few tools that try to reverse this transparency. 5. Implications for compliance and users For compliance teams at exchanges, brokers, and custodians: Define a written policy on mixer exposure (direct and indirect). Use professional KYT / blockchain analytics, but tune thresholds and document decisions. Prefer enhanced due diligence over automatic de-banking where proportionate (proof of funds, source-of-wealth checks, ongoing monitoring). Coordinate sanctions, AML, and fraud views – mixer exposure tied to sanctioned actors is a separate category of risk. For users, the key message is simple: Blockchain is no longer an “anonymous escape hatch.” It is one of the most transparent financial systems ever built – and modern KYC/AML tools can see much more than most people assume. In this environment, using mixers purely for privacy may still be lawful in many places, but it comes with clear and growing compliance consequences. Share Information via Whistle42

The Estonian Financial Intelligence Unit (EFIU) has published a groundbreaking typology report examining nested services in virtual currency exchanges—and its findings directly corroborate FinTelegram’s long-standing compliance reporting on crypto payment processors servicing illegal online casinos. In December 2025, the EFIU released “Nested Services in Virtual Currency Exchanges,” a comprehensive analysis conducted in consultation with the U.S. Financial Crimes Enforcement Network (FinCEN). The study examined 12 nested virtual currency exchanges, tracing over nine million blockchain data points to reveal systematic AML/CFT failures, beneficial owner concealment, multi-layered nesting structures, and direct exposure to darknet markets and sanctioned jurisdictions. What Are Nested Services? Source: FIU Estonia Report: Nested Services in Virtual Currency Exchanges Nested services allow smaller crypto exchanges—often unlicensed or operating from weakly supervised jurisdictions—to conduct business through accounts held at larger, licensed host exchanges. While legitimate uses exist, the EFIU found that illicit actors exploit these arrangements to obscure transaction origins, evade customer identification requirements, and bypass AML monitoring. The structure functions like Russian nesting dolls: customer transactions pass through multiple layers before reaching their destination, each layer adding obfuscation. The EFIU identified exchanges registered as private individuals despite conducting millions in commercial transactions, entities masking their Russian origins while advertising weak KYC controls, and host exchanges providing services to previously delicensed operators. Several nested exchanges had direct on-chain exposure to ransomware, darknet markets, and sanctioned entities. Download the FIU Estonia Report on Nested Services here Independent Validation of FinTelegram’s Work FinTelegram has published multiple compliance reports documenting these exact patterns among crypto payment processors servicing unauthorized gambling operators. The EFIU’s independent investigation—conducted by a government financial intelligence unit with regulatory authority—validates FinTelegram’s investigative methodology and findings. Download the Full Compliance Report FinTelegram has prepared a detailed comparative analysis examining how the EFIU’s findings align with our published investigations. The report includes case study comparisons, red-flag indicator frameworks, unanswered regulatory questions, and professional conclusions about systemic vulnerabilities in the crypto payment processing sector. Download the Full Nested Services Comparative Analysis. Insiders: Share Your Information Securely If you have knowledge of nested service arrangements, host exchange compliance failures, or payment processor misconduct, FinTelegram’s Whistle42 platform provides a secure, confidential channel to submit information. Your insights can support regulatory enforcement and protect consumers. Share Information via Whistle42

Austrian businessman Bernd Bergmair built his fortune in the shadows of Pornhub’s parent MindGeek while victims and activists accused the group of profiting from sex trafficking and child sexual abuse material. Now, as Reuters links him to a bid for Lukoil’s sanctioned assets, new questions arise over how porn profits may be recycled into Russian oil. Background Bernd Bergmair‘s estimated net worth is estimated at approximately $1.5 to $2 billion in various reports. However, this figure should be treated with caution, as it is based on valuations of MindGeek prior to the major scandals and the sale to Ethical Capital Partners (ECP) in 2023. He held the majority of shares through a complex network of shell companies (including in Luxembourg and Cyprus). Austrian investigative platform Wiener Zocker has spotlighted a name that until recently stayed in the shadows: Austrian businessman Bernd Bergmair, long described by media investigations as the former majority owner of Pornhub’s parent MindGeek, now rebranded as Aylo (Sources: Wiener Zocker, Wikipedia). According to a recent Reuters exclusive, Bergmair has approached the U.S. Treasury about buying the international assets of sanctioned Russian oil major Lukoil, a portfolio of refineries, oil-field stakes and fuel stations worth an estimated $22 billion and managed from Vienna (Source: Reuters). From secret porn mogul to would-be oil baron Raised near Linz and later working as an investment banker at Goldman Sachs, Bergmair built a low-profile fortune via a complex network of holding companies that controlled MindGeek, the Luxembourg-based conglomerate behind Pornhub, RedTube and YouPorn. His identity as the group’s principal owner was first widely reported in 2020–21 by the Financial Times and others, prompting political scrutiny in Canada.Wikipedia+1 MindGeek/Aylo has since faced an avalanche of civil lawsuits and class actions in the U.S. and Canada. Plaintiffs allege that the company knowingly hosted and monetised non-consensual videos, including child sexual abuse material, and violated federal sex-trafficking and child-pornography laws (Sources: GovInfo, The New Yorker). MindGeek denies the allegations but has responded to public pressure by deleting unverified content and tightening uploader verification and moderation. Laila Mickelwait and the #Traffickinghub campaign A central figure in the global backlash is U.S. anti-trafficking advocate Laila Mickelwait (@LaileMickelwait), founder of the #Traffickinghub movement. Her campaign and petition accuse Pornhub/MindGeek of “enabling, distributing and profiting from rape, child sexual abuse [and] sex trafficking” (Source: traffickinghubpetition.com, NCOSE) On X, she has called MindGeek/Aylo “one of the most vile, exploitative and criminal organizations in the world” and said the harm to children and lives “shattered for profit … are incalculable” (Source: Post on X, Post on X). Mickelwait also used social media to publicly identify Bergmair as the previously hidden majority owner of Pornhub, breaking the anonymity that offshore structures had long provided him (Post on X, Post on X). Ethical Capital Partners and open ownership questions In March 2023, Canadian private-equity firm Ethical Capital Partners (ECP) acquired MindGeek and later rebranded it as Aylo. ECP, chaired by businessman Rocco Meliambro and fronted by criminal-defence lawyer and rabbi Solomon Friedman, presents itself as a compliance- and trust-and-safety-driven owner seeking to reform the company (Source: ECP). Transaction terms and seller identities were not disclosed. Public reporting and Reuters now describe Bergmair as the former majority owner, and ECP says previous owners no longer hold interests (Source: Reuters). FinTelegram has found no public evidence that Bergmair retains a stake in Aylo via ECP or related funds, but the opacity of private-equity structures leaves room for continued speculation. Key Findings on MindGeek/Aylo Legal Exposure Jurisdictional Coverage: The company and its executives face coordinated legal action across three primary jurisdictions: USA — Multiple federal district courts (California Central, California Northern, Eastern District of New York), FTC administrative proceedings, state-level actions (Utah), and related criminal prosecutions of trafficking partners Canada — Quebec Superior Court class action, federal Privacy Commissioner investigation, and ongoing regulatory oversight following private equity acquisition International — Potential exposure through corporate structure (Luxembourg headquarters, Cyprus entities, Ireland profit routing) Key Defendants Named in Litigation: Bernd Bergmair — Identified as majority owner and “over-boss” of alleged criminal enterprise in USA racketeering complaints; previously kept identity hidden; named in California and Quebec lawsuits Feras Antoon — CEO; named as co-conspirator in organized crime allegations David Tassillo — Executive; named in sex trafficking complaints Corey Urman — VP Product Management; named in Quebec class action Corporate entities — MindGeek S.à.r.l. (Luxembourg), MindGeek USA Inc., MG Freesites Ltd. (Cyprus), Aylo Holdings (current name) Allegations Pattern: All jurisdictions allege similar core violations: Hosting CSAM — Videos depicting minors in sexual abuse situations Sex trafficking facilitation — Knowing profiting from coerced/fraudulent content (especially GirlsDoPorn partnership, 2011-2019) Non-consensual content — Intimate images/videos uploaded without consent; failure to honor removal requests Deceptive marketing — False claims about content safety and moderation Financial Exposure: ActionAmountStatusCanada Class Action$600 million+Pending class certificationFTC Settlement$15 millionFinalized Sept 2025 ($5M paid immediately)US DPA (DOJ)$1.84 millionFinalized Dec 2023California SettlementsConfidentialMultiple closed (terms not disclosed)GirlsDoPorn Civil Awards$13 millionTo victims (2020) No Strafrechtliche Verurteilung (Criminal Convictions) of MindGeek/Aylo Itself: Notably, while individual GirlsDoPorn operators received federal prison sentences, no criminal conviction has been obtained directly against MindGeek/Aylo as a corporate entity. Instead, the company has used deferred prosecution agreements and civil settlements to resolve matters without formal criminal adjudication — a common corporate enforcement approach for large entities. Reputation-laundering in Nigeria? Bernd Bergmair receives the honor Doctor of Business Administration in Nigeria In November 2024, the Enugu State University of Science and Technology (ESUT) in Nigeria awarded Bergmair an honorary Doctor of Business Administration for his “achievements” and the donation of a large solar power plant to the Faculty of Management Sciences (Source: The Guardian Nigeria). The honour stands in sharp contrast to the unresolved allegations surrounding MindGeek/Aylo and its former control structure. With Bergmair now reportedly eyeing sanctioned Lukoil assets from his base in London and Vienna, questions multiply: Who are his partners and financiers? How, if at all, are past MindGeek profits being recycled into strategic energy deals? And what did key executives know and do during the years when illegal content allegedly flourished on MindGeek platforms? FinTelegram, together with Wiener Zocker, will continue to investigate. Insiders, victims, employees, bankers or advisors with knowledge of Bernd Bergmair’s structures and deals are invited to contact us confidentially via our whistleblower platform Whistle42. Share Information via Whistle42

In a brazen display of regulatory overreach, the EU has slapped Elon Musk‘s X with a €120 million ($140 million) fine under the Digital Services Act (DSA), targeting alleged breaches like misleading blue checkmarks, opaque ad disclosures, and restricted data access for researchers. This punitive strike exposes the EU’s hypocritical war on U.S. tech giants, while the bloc languishes without a single noteworthy social media platform of its own. Musk and U.S. politicians are firing back with fury, demanding sanctions and even the EU’s abolition. As FinTelegram monitors cyber-financial risks, this escalating feud signals potential market disruptions, investment chills, and geopolitical fractures in global digital finance. The EU’s Punishment: A Censorious Power Grab The fine, announced December 5, 2025, accuses X of enabling misinformation through its paid verification system, hiding ad origins that could mask foreign influence, and blocking researchers from detecting bots and propaganda networks. This isn’t protection—it’s an outrageous assault on free speech, echoing the EU’s history of hammering American innovators like Google, Apple, and Meta with billions in fines under GDPR and DMA. Yet, the EU produces zero competitive social media platforms, relying on U.S. dominance while wielding regulatory hammers to kneecap rivals. Recent “initiatives” like the Digital Decade package and AI strategies tinker at edges but offer no real revitalization—mere window dressing for a stagnant tech scene drowning in bureaucracy. Reactions:Musk and U.S. Politicians Unleash Hell Elon Musk decried the fine as “crazy” and “insane,” falsely claiming it targeted him personally, and called for targeted U.S. retaliation against EU officials—financial sanctions, no-fly lists, and more. Senator Ted Cruz (@tedcruz) branded it an “abomination” and assault on American jobs and speech, urging President Trump to impose sanctions until reversed. JD Vance echoed the sentiment, slamming EU censorship fears. Supporters on X amplified calls to abolish the EU, restore sovereignty, and even shutter X in Europe, framing the bloc as a “socialist hellscape” weaponizing fines for control. Implications for FinTelegram This clash highlights EU jealousy and impotence: punishing U.S. success without building alternatives. For cyber-financial intelligence, watch for retaliatory tariffs disrupting transatlantic investments, heightened cyber risks from platform wars, and volatile tech stocks. The EU’s tech void invites exploitation—time for bold American countermeasures to crush this regulatory tyranny. Share Information via Whistle42

FinTelegram received a “DMCA” email from Stoyan Staykov demanding the removal of two articles. The message included ID scans and screenshots, but none of the statutory details that identify a specific copyrighted work. The notice is therefore formally deficient and, in our assessment, a misuse of the DMCA intended to chill reporting. We have sent a detailed deficiency response and will not remove content absent a legally compliant notice. Why the DMCA Email Fails No identification of the specific copyrighted work (title/author/publication) allegedly infringed. No precise location of the allegedly infringing passage/image on our site. No complete contact details; government ID scans are neither required nor appropriate. Result: no valid §512(c)(3) DMCA notice. Read our reports on Stoyan Staykov here. What Staykov Wants Taken Down – The Core of Our Reporting 1) “8 Million to Panama – Alpha Fund & Canal Bank” We reviewed a board resolution of Alpha Fund AD (April 1, 2025) authorizing the subscription of 11,428,571 shares at USD 0.70 in Canal Bank S.A. (Panama)—a total of USD 8 million; to be executed via Bulgarian intermediary Faktori AD. Our red-flag indicators: offshore jurisdiction (Panama), low share price/high volume, accelerated timeline, and an external broker. Public confirmations beyond the internal resolution have not been located. By contrast, the ~9.55% stake of Alpha Fund in Wiener Privatbank SE is publicly disclosed (read our report here). 2) “The Bulgarian Investor Stoyan Staykov and His Vast Network” This piece analyzes the corporate web around Alpha Bulgaria AD (ALFB), Alpha Fund AD, and intermediary vehicles (including CREDITBOX SMLTD) spanning Bulgaria and Vienna. Patterns include sub-10% shareholdings, nominee layering, and cross-border capital flows. Several claimant accounts (e.g., Anton Erokhine; an Austrian notary) report unpaid liabilities. We clearly label items as alleged/documented, as appropriate. Beyond OSINT – What Insiders Told Us As part of our investigation, we spoke with individuals who did business with Staykov or have direct knowledge of his network. Multiple insiders allege that Staykov acts as a front man for Russian oligarchs, using Vienna/Bulgaria as operational hubs. One of these oligarchs is allegedly Oleg Boyko. These allegations are being further verified and are not based solely on open sources; our work includes internal materials and witness statements. Our Standard FinTelegram reports critically, fact-based, and law-compliant. We correct verified errors—yet we do not respond to deficient DMCA notices or pressure tactics. We do not publish ID documents and handle personal data minimally. Call for Information: If you hold documents, contracts, payment trails, or internal communications related to Alpha Bulgaria / Alpha Fund / Wiener Privatbank / Staykov, please submit them confidentially via Whistle42. Substantive evidence helps clarify the facts and exposes improper attempts to silence reporting. Share Information via Whistle42

Viennese lawyer and long-time Social Democratic (SPÖ) networker Oliver Stauber has moved from running a Social Democratic “think tank” under former chancellor Christian Kern to running KuCoin’s new EU hub in Vienna. At the same time, Austria’s FMA co-signed a paper warning that national regulators cannot effectively police global crypto platforms—then, just weeks later, granted a full MiCA licence to KuCoin, a repeat offender in major AML cases in the US and Canada. The sequence raises hard questions about political networks, regulatory capture, and how MiCA is already being bent in practice. 1. The political lawyer: SPÖ insider with his own “section” Before he was marketed as a crypto-compliance specialist, Oliver Stauber (LinkedIn profile) was a classic Social Democratic insider: He served for years as deputy federal chair of the SPÖ youth organisation (Junge Generation) and sat on the board of the association of Social Democratic lawyers (Source: Trending Topics). In 2016, he founded and chaired the SPÖ “Sektion ohne Namen (Section without a Name” in Vienna’s first district – a self-declared “think tank” and Realo counterweight to the left-wing Sektion 8 (Sources: Trending Topics, Der Standard). https://fintelegram.com/tag/christian-kernMedia such as Der Standard and Die Presse described the group as a modern, business-friendly SPÖ hub where Christian Kern’s son Niko Kern was active and where the Austrian chancellor Kern presented his “Plan A” for a modernised Austria (Source Der Standard). In other words: Stauber didn’t just “support” the SPÖ—he built his own power base inside it, positioning the Sektion ohne Namen (Section without a Name) as a bridge between party politics, consultants and business elites in Vienna’s inner city. This political profile matters because it is exactly this mix—law, lobbying, and party networks—that now underpins his role in Austria’s crypto policy ecosystem. 2. From SPÖ networker to crypto insider Over the last decade, Stauber systematically repositioned himself as a crypto and FinTech lawyer: He became Chief Legal Officer at Bitpanda, Austria’s best-known crypto platform, and managing director of its regulated entities (Source: brutkasten). He joined the FinTech Advisory Board at the Austrian Ministry of Finance, a body that helped shape the “regulatory sandbox” and wider digital-finance policy (Source: Brutkasten, Brutkasten) He co-founded and sat on the board of the Digital Assets Association Austria (DAAA), a lobbying and industry association explicitly spun out of this FinTech advisory work (Source: Brutkasten). So by the time MiCA was being negotiated, Stauber sat at a rare intersection: Political networks (SPÖ, Kern orbit, inner-city “think tank”), Regulatory networks (Finance Ministry advisory bodies, sandbox), Crypto industry interests (Bitpanda, DAAA, later KuCoin). That is precisely the profile that becomes controversial once you add his next career step. 3. KuCoin: a “repeat offender” in global AML enforcement KuCoin is not a clean slate looking for an EU home: In March 2024, the US Department of Justice charged KuCoin and its Chinese founders Chun Gan and Ke Tang with flouting US AML laws, highlighting billions in suspicious flows and failure to implement basic KYC/AML controls (Source: US DOJ). On 27 January 2025, KuCoin’s Seychelles vehicle Peken Global Limited pleaded guilty in New York federal court to operating an unlicensed money-transmitting business. KuCoin agreed to pay nearly USD 300 million in fines and forfeitures and to exit the US market for at least two years (Sources: US DOJ). The DOJ and multiple legal analyses describe extensive AML failures: no effective KYC programme, failure to file suspicious activity reports, and facilitation of over USD 5 billion in illicit transactions, including darknet, ransomware and fraud proceeds (Source: Web Publishing). On 25 September 2025, Canada’s AML authority FINTRAC announced its largest ever penalty: CAD 19.6 million against Peken Global for operating without proper registration, failing to report large virtual currency transactions and neglecting suspicious transaction reports (Source: Reuters). Add to this a CFTC enforcement action in 2024 for illegally dealing in leveraged crypto derivatives for US customers, and a New York Attorney General case for operating unregistered, and you have a platform that regulators themselves now cite as a textbook AML problem case (Source: moneylaunderingnews.com, Thomson Reuters, FinCrime Central). Download the full KuCoin Compliance Report 2025 here. It’s also widely documented that KuCoin was founded by Chinese nationals and runs through a network of entities in Seychelles, Singapore and Hong Kong—the exact type of third-country structure European supervisors describe as high-risk under MiCA (Source: Wikipedia). 4. September 2025: FMA admits national regulators are outgunned On 15 September 2025, the French AMF, Austrian FMA and Italian Consob published a joint position paper calling for a “stronger European framework for crypto-asset markets” under MiCA (Source: FMA Österreich, Ashurst). The paper’s key messages (summarised by law firm Ashurst) are telling: National MiCA supervision has led to fragmented oversight and regulatory arbitrage; CASPs are “doing their regulatory shopping all over Europe, trying to find a weak link.” The authorities explicitly call for direct ESMA supervision of “significant” CASPs, including licensing and sanctioning powers, because national regulators alone cannot effectively oversee global platforms. They warn about global platforms and third-country structures that serve EU clients via complex intra-group arrangements, undermining MiCA’s effectiveness and investor protection. In plain language:The FMA publicly acknowledges that national authorities are structurally too weak to police global crypto platforms and that regulatory shopping is a real danger under MiCA’s passport regime. 5. November 2025: FMA licences KuCoin EU anyway Just two months later, on 27 November 2025, the same FMA issued a MiCA licence to KuCoin EU Exchange GmbH in Vienna (Source: FMA Österreich). According to the FMA’s own press release, KuCoin EU is now authorised under Article 63 MiCA to: provide custody and administration of crypto-assets, exchange crypto-assets for fiat and for other crypto-assets, place crypto-assets, and provide transfer services on behalf of clients. Under MiCA’s passporting rules, that licence can become KuCoin’s entry ticket to the entire EU, even though: KuCoin has just pleaded guilty in the US, has been hit with a record AML penalty in Canada, and is still facing ongoing supervisory and civil actions. FinTelegram and investor-protection groups like EFRI have already questioned whether Austria has effectively “whitewashed a repeat offender” and turned itself into a MiCA hub for high-risk platforms (Source: FinTelegram) The FMA, for its part, has so far offered only boilerplate explanations about meeting MiCA criteria—no detailed public discussion of how KuCoin’s global AML track record was weighed against those criteria. 6. Where Stauber fits into this picture At the very moment when: national regulators warn they cannot effectively supervise global CASPs, and argue that regulatory shopping and third-country structures undermine investor protection, Austria chooses to license exactly such a platform—and the face of this move is a lawyer whose career combines: Party-political networking (SPÖ functionary, founder of the Sektion ohne Namen, close to the Kern circle), Regulatory insider roles (Finance Ministry advisory bodies, regulatory sandbox, DAAA spin-off), brutkasten+2brutkasten+2 Top positions in crypto firms (CLO and managing director at Bitpanda, now CEO of KuCoin’s EU operation in Vienna) (Source: EFRI). That combination does not prove any illegal conduct or direct political interference in the FMA’s licensing decision. But from a compliance perspective, it creates a classic appearance-of-conflict problem: The same networks that promoted a pro-innovation, industry-friendly approach in Austria’s FinTech policy now appear to have delivered a full MiCA licence to one of the most heavily sanctioned crypto platforms in the world. The same authority (FMA) that co-authored a paper about the limits of national supervision and regulatory shopping has chosen to become the home regulator of a global CASP with a recent criminal plea and record AML penalties. For investors and counterparties, the question is simple and uncomfortable: Is Austria demonstrating that MiCA can be applied rigorously to high-risk global exchanges—or is it demonstrating how political networks and regulatory arbitrage can still prevail under the new regime? At this stage, only the FMA and the KuCoin EU team know exactly how the licensing file was argued, what conditions and remediation plans were agreed, and which assessments of fitness & propriety were made in light of the US and Canadian cases. 7. What needs to happen next From a professional compliance standpoint, several steps would be needed to restore confidence: Full transparency from the FMA Publish a detailed non-confidential summary of the KuCoin EU authorisation, including how the US guilty plea, FINTRAC penalty and CFTC/NYAG actions were assessed under MiCA’s fit-and-proper and organisational-requirements tests. Clarification from KuCoin EU and its management Explain clearly how KuCoin’s group-wide AML framework has changed since the enforcement actions, what on-chain monitoring and KYC controls will be applied in the EU hub, and how governance independence from the sanctioned entities is ensured. Clear communication about conflicts of interest Disclose any past or present political advisory roles, lobbying mandates or party functions held by key KuCoin EU managers, including Stauber, that might intersect with Austrian or EU crypto policymaking. ESMA involvement Given the September position paper, ESMA should examine whether KuCoin qualifies as a “significant CASP” requiring direct supervision and whether Austria’s licensing approach is consistent with the paper’s own logic. Ashurst Without such steps, Austria risks cementing an image as Europe’s weak link: the jurisdiction that speaks loudly about regulatory shopping—then hands a passport to one of the market’s most controversial players. 8. Call for information This report is based exclusively on publicly available information and official enforcement records. It does not allege criminal conduct beyond what authorities have already established in their own proceedings, and it does not claim that any Austrian official or lawyer has broken the law. However, the sequence of events, political networks and licensing decisions raises serious questions about: the true independence of Austria’s MiCA supervision, the influence of political-regulatory insider networks in shaping crypto policy, and the concrete conditions under which KuCoin EU obtained its licence. Insiders, current or former employees of KuCoin, Bitpanda, the FMA, the Finance Ministry or related advisory bodies who can shed light on: the KuCoin EU licensing process in Vienna, Stauber’s role and contacts in that process, or internal discussions around the September 2025 MiCA position paper are invited to contact us securely via our whistleblower channels (including Whistle42) or other encrypted means. Share Information via Whistle42 Confidentiality and source protection are paramount. The integrity of MiCA supervision in Europe depends on understanding how this licence was granted—and whether political networks are already rewriting the rules before they are fully in force.

A new whistleblower case shows how brutally so-called “recovery funds” and fake AML teams now target crypto users. An email from AML@review-blockchain.com claims that a USD 28,634.17 transaction to a Kraken wallet has been frozen for “money laundering” – and demands a 20% “refundable security deposit” in ETH to a “neutral verification wallet” to release the funds. Red flags everywhere: the sender is not Kraken, not a regulated AML office, but a random domain (review-blockchain.com); the message mixes USD and ETH (at one point even promising 28,634.17 ETH – tens of millions in today’s prices); and it uses a classic pressure script: pay now or your account will be blacklisted and your money confiscated. This pattern is textbook advance-fee and recovery fraud: scammers promise a big payout or “release” of frozen funds but demand money upfront. Once paid, they disappear – victims are scammed a second time. Regulators and authorities describe these “recovery offers” as follow-on scams that specifically target people who already lost money in an earlier fraud (Sources: Investor, CFTC). Important: No legitimate exchange, AML officer, regulator or law-enforcement agency will ever ask you to send crypto to a private wallet to “verify” funds, unfreeze an account or avoid blacklisting. Verification is done via KYC documents, not by sending more money. Requests for deposits, especially in crypto, are a massive red flag. Our whistleblower is not alone. Similar emails from AML@review-blockchain.com demanding a 20% payment have already surfaced in online scam forums, indicating a broader, coordinated campaign (Source: Reddit). FinTelegram warning:Never pay upfront “security deposits”, “taxes” or “fees” to release alleged frozen funds – you will only lose more money. If you receive such an email: Do not send crypto. Contact your bank and the relevant regulator. Preserve all emails, wallet addresses and transaction data. Call for Information: If you have received messages from AML@review-blockchain.com or any “recovery fund” demanding fees to unlock crypto, please share your documents and experience with FinTelegram via our Whistle42 system or by email. Help us map and expose this global fund-recovery scam industry. Share Information via Whistle42

U.S. crypto exchange Kraken has agreed to acquire Swiss-Jersey tokenization specialist Backed Finance AG, issuer of the fast-growing xStocks line of tokenized equities and ETFs. Media outlets report that the deal is structured as a strategic acquisition to consolidate the issuance, trading, and settlement of tokenized stocks inside Kraken’s infrastructure (Source: coindesk.com). Backed’s xStocks are 1:1-backed tokens representing listed shares like Nvidia, Tesla – and Coinbase (COINx) – issued via a Jersey vehicle under a prospectus approved by the Liechtenstein FMA and framed under Swiss DLT rules (Source: Backed Finance). For Kraken, which now holds a MiCA CASP licence in the EU and multiple licences in the US, UK, Canada and elsewhere, the deal deepens its push into tokenized real-world assets (RWAs) just as the RWA market passes $30+ billion and grows roughly 10x since 2022. Contrary to some social-media spin, this is not a takeover of Coinbase itself but a takeover of the platform that issues tokenized versions of Coinbase and dozens of other stocks. The strategic question for regulators and investors: Are we watching the birth of parallel stock markets inside crypto exchanges – and under which rulebook? Opportunities – Why Kraken Wants Backed Vertical RWA stack: Kraken gains full control over the xStocks pipeline – from issuance and custody to secondary trading – plugging directly into its MiCA-regulated EU custody network and US broker-dealer arm (Source: Kraken Blog). RWA growth tailwind: Tokenized RWAs have crossed roughly $30–35 billion in value, led by private credit and Treasuries, with forecasts into the hundreds of billions or even trillions by the 2030s (Source: investax.io). 24/7 equities exposure: xStocks already offer exposure to 60+ stocks and ETFs, tradable 24/5 on Kraken and 24/7 on-chain, with self-custody and DeFi composability (Source: Kraken Blog). IPO runway: Kraken is widely seen as a pre-IPO candidate; owning a flagship tokenization business strengthens the “regulated infra + RWA” story for public markets (Source: Summit Ventures Partners). Market Impact – Tokenized Equities Go Mainstream Backed Finance has positioned xStocks as “composable tokenized securities” that are freely transferable, DeFi-compatible and multi-chain, with the underlying held by licensed custodians and each token backed 1:1 and redeemable for cash value (Source: Backed Finance). Kraken states that xStocks exceeded $10 billion in combined exchange and on-chain volume within six months of launch – remarkable traction for a 2025 product – and plans to integrate xStocks into its broader product suite, including the Krak money app. Customers may eventually hold and spend tokenized equities like any other balance (Source: Kraken Blog) This acquisition, therefore: Pushes tokenization out of the pilot stage and into a global, multi-jurisdictional platform with millions of users. Blurs the border between “crypto exchange” and “multi-asset brokerage plus RWA venue.” Raises the competitive stakes for rivals like Coinbase, Binance, Bybit and others that have also announced or tested tokenized equities offerings. investax.io+1 Tokenization of Real-World Assets – Function and Significance What tokenization does technically Representation: A legal structure (often an SPV or structured note) holds the real-world asset – a share, bond, fund unit, or property interest. Digitization: Smart contracts issue tokens that encode the economic and sometimes governance rights linked to that asset. Transfers on-chain correspond to changes in beneficial ownership off-chain. Automation: Corporate actions (dividends, coupons, buybacks), KYC/AML checks, and transfer restrictions can be automated at token level. Why this matters Liquidity & access: Fractional tokens allow smaller tickets and 24/7 global trading, particularly attractive for private credit, Treasuries and real estate – the segments already driving most of the $30B+ RWA market (Source: investax.io). Operational efficiency: Instant settlement and programmable compliance lower back-office costs and settlement risk, aligning with “same risk, same rules” principles regulators repeat in their RWA and DLT guidance. New collateral layer: Tokenized RWAs become plug-and-play collateral in DeFi and institutional repo/credit workflows, especially when paired with regulated stablecoins and tokenized MMFs. But there is a catch: tokenization doesn’t magically upgrade bad products. If the underlying security, governance or valuation is weak, the token becomes a more transparent version of the same risk – not a cure. Regulatory Context – MiCA, Securities Law and the xStocks Puzzle Kraken already positions itself as a heavily licensed player, with E-money and MiCA CASP licences in Ireland, FCA registrations and EMIs in the UK, Canadian restricted dealer status, a Wyoming SPDI, and a US broker-dealer for equities. Backed’s issuer, meanwhile, operates under Swiss DLT law, a Jersey structure approved by the JFSC, and a prospectus vetted by the Liechtenstein FMA, explicitly marketing its tokenized products only to qualified, non-US investors and excluding UK retail. Actionable Takeaways for FinTelegram Readers Institutional readers/investors: Treat tokenized equities as securities with better plumbing, not as “just another crypto token.” Due diligence must cover the entire chain: issuer SPV, custodians, prospectus, and venue licences. Compliance officers: Map xStocks and similar products into your existing securities/derivatives frameworks. Check how MiCA CASP permissions interact with MiFID II, UCITS, and national securities law for any exposure you have via Kraken or DeFi protocols. Regulators & policymakers: The Kraken–backed deal is a live test of “same risk, same rules” in RWA tokenization. Clear guidance on when a crypto venue becomes a de-facto securities exchange is overdue. Share Information via Whistle42

FinTelegram’s compliance review of LuckyWins (www.luckywins.com), a Dama N.V. offshore casino, has uncovered systematic use of deceptive payment processing schemes that disguise crypto purchases as bank deposits. The investigation reveals Kryptonim‘s continued facilitation of illegal gambling transactions despite explicit prohibitions in its terms of service, alongside participation by regulated entities MiFinity, utPay, and open banking providers Contiant and Rapidob/Skrill. The Dama N.V. Context LuckyWins operates under Dama N.V. (Curaçao registration 152125, license OGL/2023/174/0082), a company managing over 80 online casinos targeting EU jurisdictions without appropriate licenses. Dama N.V. entered bankruptcy proceedings in June 2024 following lawsuits from German and Austrian players seeking over €800,000 in unpaid winnings. However, in August 2024, the court ruled that the company was indeed not in a state of insolvency, supported by financial documents and payments to Dama’s business creditors. As a result, the bankruptcy has been overturned. Thus, LuckyWins and other Dama casinos continue operations across EU markets where such unlicensed gambling is prohibited.​ The “Fake Bank Deposit” Mechanism Our deposit testing revealed LuckyWins employs a sophisticated multi-layered payment architecture designed to disguise cryptocurrency purchases as conventional bank transfers: Layer 1: Onramper Aggregation – Deposits labeled as “bank transfer” are routed through Rillpay (Rillpay.co), a Costa Rica-registered crypto wallet infrastructure provider. Rillpay operates as an onramp aggregator similar to Onramper.com, connecting merchants to multiple crypto payment processors.​ Layer 2: VASP Processing – Rillpay directs transactions to Kryptonim sp. z o.o. (KRS 0001017630), the Polish VASP we previously exposed in our Neon54 investigation. This creates a “fake bank deposit” where players believe they’re funding casino accounts directly, but are actually purchasing cryptocurrency that Kryptonim transfers to the casino. Layer 3: Parallel Processing Channels – LuckyWins simultaneously offers deposits via utPay (Utrg UAB, Lithuania), MiFinity (FCA/MFSA-regulated EMI), and open banking through Contiant (powered by Yapily) and Rapidob.com (Skrill’s Rapid Transfer service).​ Read our Neon54 & Kryptonim report here. Critical Compliance Violations Kryptonim’s Contradiction – Kryptonim’s Terms of Service explicitly state: “iGaming and Betting: Using credit cards for online gambling, betting, or any other iGaming activities is strictly prohibited”. Yet our testing confirms systematic processing of LuckyWins deposits, consistent with player reports from our Neon54 investigation.​ Chargeback Circumvention – By converting fiat to crypto before casino crediting, these schemes eliminate players’ chargeback rights and dispute mechanisms available with direct card or bank payments. Players are left with cryptocurrency transactions rather than gambling deposits on their statements.​ Merchant Categorization Fraud – The payment flow deliberately misrepresents transaction nature, likely using false Merchant Category Codes to bypass banking blocks on gambling transactions.​ Open Banking Abuse – Similarweb analysis shows Contiant’s domain (paywith.contiant.com) processes traffic exclusively for casino sites[user report]. Yapily-powered open banking, designed for legitimate merchant payments, is being exploited for illegal gambling facilitation.​ Summary Table: LuckyWins Payment Facilitators EntityJurisdictionRoleRegulatory StatusCompliance FlagDama N.V.CuraçaoCasino OperatorLicense OGL/2023/174/0082Bankrupt June 2024​Rillpay SRLRillpay.coCosta RicaOnramp AggregatorUnregulatedUnknown beneficial ownershipKryptonim sp. z o.o.Kryptonim.comPolandCrypto VASPRDWW-649, FINTRAC M23813101Terms prohibit gambling​utPay (Utrg UAB)LithuaniaCrypto ProcessorEU VASP registrationPreviously flagged​MiFinityUK/MaltaEMIFCA 900090, MFSAOrange compliance list​ContiantUK (Yapily)Open BankingFCA-authorized PISPCasino-exclusive trafficRapidob/SkrillUKOpen BankingSkrill Rapid TransferPaysafe Group subsidiary Call for Information FinTelegram urgently seeks information from players, banking compliance officers, and payment industry insiders regarding: Documentation of LuckyWins or other Dama N.V. casino payment flows Evidence of Kryptonim, Rillpay, or open banking provider involvement in offshore gambling Internal communications regarding compliance with gambling prohibitions Details of chargeback attempts and merchant descriptor analysis Submit information confidentially via our secure Whistle42 system. Share Information via Whistle42

Following FinTelegram’s exposé on Coin Sonic UAB, the operator of illegal offshore casinos SlotsDynamite and SlotsAmigo has quietly replaced its Lithuanian payment facilitator with Yotta Pay, an unlicensed UK entity leveraging Revolut‘s open banking infrastructure. Here is our update on the payment facilitators involved in these offshore casino schemes. FinTelegram’s Impact Confirmed On 30 October 2025, FinTelegram published its compliance report questioning whether Lithuanian VASP Coin Sonic UAB was being misused to facilitate fiat payments for offshore casinos operating illegally in the EU. Following that report, Coin Sonic’s MLRO, Tsimafei Breski, sent a complaint alleging defamation—yet failed to identify any specific inaccuracy. Read the Coin Sonic report here. Our follow-up review on 3 December 2025 confirmed that our reporting has had a direct effect: Coin Sonic UAB d/b/a InstaXchange has apparently terminated its relationship with Coco Loco Holdings N.V., the Curacao-based operator of SlotsDynamite and SlotsAmigo. Player bank transfers are no longer routed to Coin Sonic‘s Banking Circle account. (Screenshot left). New Payment Facilitator: Yotta Pay Coco Loco Holdings N.V. has now engaged Yotta Digital Ltd (trading as Yotta Pay) as its replacement payment facilitator. Yotta Digital Ltd is a UK-registered micro-entity (company number 12195240), incorporated on 9 September 2019 and headquartered in Swansea, Wales. The sole director and person with significant control is Ukrainian citizen Ihor Kononko.​ Yotta Digital Ltd is not authorized by the FCA. A search of the Financial Conduct Authority’s Financial Services Register returns no entry for Yotta Digital Ltd or Yotta Pay. Without FCA authorization as a Payment Institution or Electronic Money Institution, Yotta Pay cannot legally provide payment services to UK or EU consumers.​ Traffic intelligence analysis of YottaPay.co.uk reveals that 100% of outgoing links point to oba.revolut.com—Revolut’s Open Banking subdomain. This suggests Yotta Pay operates as a technical layer routing payments through Revolut‘s open banking API infrastructure, rather than processing transactions under its own regulatory authorization.​ Payment Flow for Illegal Casino Deposits Our review identified the following deposit flow for players at SlotsDynamite and SlotsAmigo: Player initiates bank deposit at the casino Redirected through high-risk gateways such as Omerpayments.com or Zinzipay.com​ Lands on Yotta Pay’s checkout interface (YottaPay.co.uk) Payment routed via Revolut Open Banking to the recipient account This multi-layer routing obscures the ultimate beneficiary and enables unlicensed offshore casinos to accept EU player deposits through seemingly legitimate UK open banking infrastructure. Compliance Concerns Yotta Pay presents significant compliance red flags: No FCA authorization despite facilitating payment services​ Sole Ukrainian director with no disclosed compliance team​ Opaque payment routing through multiple high-risk intermediaries​ Exploitation of Revolut’s Open Banking API for gambling-related transactions​ Revolut should investigate whether its open banking infrastructure is being exploited by unlicensed payment facilitators serving illegal gambling operations. Summary: Payment Facilitator Comparison CategoryOld FacilitatorNew FacilitatorEntityCoin Sonic UAB d/b/a InstaXchangeYotta Digital Ltd d/b/a Yotta PayJurisdictionLithuaniaUnited Kingdom (Wales)RegistrationCompany code 306200594Company number 12195240DirectorGeorge AdamidesIhor Kononko (Ukrainian)Regulatory StatusVASP (not licensed for fiat payments)Not FCA-authorizedBank AccountBanking Circle Germany (DE73202208000056199298)Via Revolut Open BankingPayment RoutingVia InstantBankPayment.com / YapilyVia Omerpayments.com / Zinzipay.comCasino ClientsSlotsDynamite, SlotsAmigoSlotsDynamite, SlotsAmigo Call for Information FinTelegram invites players, insiders, and whistleblowers with knowledge of Yotta Pay, Coin Sonic, Coco Loco Holdings N.V., or related payment schemes to come forward. Information on payment flows, transaction records, corporate relationships, or compliance failures can be submitted confidentially via our whistleblower platform Whistle42. Share Informatin via Whistle42 Your information helps protect consumers and expose illegal gambling operations exploiting European payment infrastructure.

A FinTelegram Analysis of the Austrian FMA’s Rapid CASP Authorisations and What It Means for EU Crypto Regulation Executive Summary Austria’s Financial Market Authority (FMA) is aggressively positioning Vienna as a gateway to the European crypto market. With six MiCA-licensed crypto-asset service providers (CASPs)—including two exchanges with substantial regulatory baggage—the FMA has emerged as one of the EU’s most prolific MiCA licensing authorities. However, this regulatory sprint raises serious questions: Is Vienna on track to become the new “Cyprus of crypto,” or does the FMA possess the capacity to supervise globally active exchanges with histories of enforcement actions? The Austrian MiCA Licence Roster The FMA has issued MiCA authorisations to six CASPs as of December 2025[web: 95][web: 101][web: 202]: CompanyLicence DateHQ/OriginNotable IssuesBitpandaApril 2025Austria (domestic)Clean record; long-standing FMA relationshipBybit EU GmbHMay 2025Dubai/Singapore$1.5B hack (Feb 2025); DNB €2.25M fine; Russian user exposure (~20–27% of traffic)AMINA (Austria) AGOct 2025Switzerland (Amina Bank group)Regulated banking groupCryptonow GmbHOct 2025SwitzerlandFirst Swiss firm to receive Austrian MiCA licenceFIOR Digital GmbHNov 2025AustriaDomestic fintechKuCoin EU Exchange GmbHNov 2025Seychelles/Hong Kong$297M DOJ settlement (Jan 2025); Seychelles FSA rejection; founders departed Of these six licensees, only Bitpanda and FIOR Digital are genuinely Austrian companies. The remainder are foreign platforms—including two (Bybit and KuCoin) with significant enforcement histories—that have chosen Vienna as their EU regulatory gateway. The EU MiCA Licence Landscape: Is Vienna Leading? No—but Austria punches above its weight. The latest data shows Germany and the Netherlands lead in absolute CASP licence numbers: JurisdictionCASP LicencesNotable FeaturesGermany (BaFin)~12–18Largest market; established fintech hubNetherlands (AFM)~9–14Strict AML regime; early MiCA implementerMalta (MFSA)~5ESMA criticism for inadequate authorisation processesFrance (AMF)~3–6Threatening to block passported licencesAustria (FMA)6Includes KuCoin, BybitCyprus (CySEC)~2–3Revolut recently licensed Austria’s six licences place it alongside Malta and ahead of Cyprus—but the composition of those licences is the issue. While Germany and the Netherlands have licensed primarily domestic or established players, Austria has become a favoured destination for offshore exchanges seeking EU access. The Cyprus and Malta Comparison: Warning Signs The FMA’s licensing trajectory draws uncomfortable parallels to two jurisdictions with troubled crypto regulatory histories: Malta: ESMA’s July 2025 peer review criticised the MFSA for granting licences without adequately assessing material risks, including governance, conflicts of interest, and AML/CFT control. The review found Malta’s authorisation processes only “partially” met expectations. Malta has since pushed back against proposals to centralise CASP supervision at ESMA level. Cyprus: CySEC was the regulator of choice for binary options brokers during the 2010s “Cyprus era,” a period marked by widespread retail investor harm and eventual regulatory crackdowns. While CySEC has since tightened standards, Cyprus has been slower to issue MiCA licences, with Revolut obtaining approval only in October 2025. Austria’s risk: By authorising exchanges like KuCoin (convicted in the US) and Bybit (hacked for $1.5 billion, significant Russian exposure), the FMA is inviting comparisons to Malta’s permissive licensing approach—and to Cyprus’s historical role as a regulatory “light-touch” jurisdiction for questionable financial services firms. Internal and External Criticism Remarkably, the FMA itself—alongside France’s AMF and Italy’s CONSOB—has co-authored a position paper calling for strengthened MiCA supervision. The September 2025 joint statement warned: MiCA’s application is “fragmented across jurisdictions” National authorities cannot require cybersecurity certification at the authorisation stage The location of large CASPs outside the EU “weakens the reach of European regulation” Supervisory convergence “quickly reaches its limits” The three regulators proposed direct ESMA supervision of significant CASPs—a tacit admission that national authorities may lack the resources and extraterritorial reach to supervise globally active exchanges. France’s AMF has gone further, warning it may refuse to honour MiCA passports from other jurisdictions—a threat that would undermine the entire single-market framework. Verdict: Is Vienna the MiCA Hub? Partially—but for the wrong reasons. Vienna is not the EU’s largest MiCA licensing centre (that honour goes to Germany and the Netherlands), but it has become disproportionately attractive to offshore exchanges with regulatory baggage. The FMA’s willingness to license KuCoin—ten months after a $297 million US guilty plea—and Bybit—months after a $1.5 billion hack attributed to North Korean state actors—raises legitimate questions about the depth of due diligence applied. The FMA may not yet be “the new CySEC,” but its trajectory deserves scrutiny. If the Austrian regulator continues to authorise exchanges that other jurisdictions have fined, rejected, or placed on warning lists, Vienna risks becoming a regulatory arbitrage destination—precisely the outcome MiCA was designed to prevent. For lawyers and compliance professionals advising crypto firms, Austria offers speed and accessibility. For regulators concerned about investor protection and systemic risk, the FMA’s licensing record warrants close monitoring. Share Information via Whistle42

Viennese lawyer Oliver Stauber is now CEO of KuCoin EU and one of the central figures of Austria’s emerging “MiCA hub.” A long-time crypto lawyer, former Chief Legal Officer of Bitpanda, FinTech adviser to the Austrian government and vice president of the Digital Assets Association Austria (DAAA), he sits exactly at the intersection of politics, regulation and high-risk exchanges like KuCoin. Key Facts Name: Oliver Stauber Current role: CEO, KuCoin EU Exchange GmbH (Vienna) (Source: LinkedIn). Background: Attorney at Stadler Völkel; former CLO & MD at Bitpanda; board roles at Blocktrade and other token projects Stadler & Partner, Brutkasten). Policy roles: Member of the former FinTech-Beirat at the Federal Ministry of Finance; founding board member and now VP of DAAA Other functions: Founder and chairman of vidaflex, an ÖGB-backed initiative for self-employed workers (Source: Vidaflex). Read our KuCoin Compliance Report 2025 here. Narrative Profile Stauber is well-connected with the Austrian Social-democratic party. He built his reputation in Vienna as an early “crypto lawyer” with Stadler Völkel, focusing on ICOs, tokenisation and capital-markets regulation (Source: Stadler & Partner). In 2020 he switched from advisor to operator by joining Bitpanda as Chief Legal Officer, shaping the legal and compliance architecture of Austria’s best-known crypto unicorn and representing it at conferences and policy panels (Source: brutkasten). Alongside his corporate roles, Stauber positioned himself as a bridge between startups, regulators and labour interests: he co-founded the DAAA to lobby on digital-asset regulation and created vidaflex with trade union ÖGB as a service platform for one-person businesses (Sources: Extrajournal, DAAA, Brutkasten) Regulatory / MiCA Footprint Through the Finance Ministry’s FinTech advisory board and DAAA, Stauber has been involved in consultations around EU financial-market rules, including the rollout of MiCA and related regimes (MiFID, DORA, GDPR) as they hit the crypto sector (Source: Arena Digitale). Public statements emphasise “constructive dialogue” with supervisors like the FMA and the need to turn Europe’s rulebook into a functioning market (Source: LinkedIn). Importance for KuCoin & the “Austrian MiCA Hub” For KuCoin – a group with a heavy enforcement history in the U.S., Canada and multiple EU states – Stauber is strategically central. As CEO of KuCoin EU and managing director of the Austrian entities, he is the face that connects a controversial global exchange to Vienna’s regulator-friendly narrative of a “secure, MiCA-compliant” hub (Source: KuCoin, CryptoRank). His network spans Bitpanda alumni, DAAA board members, Austrian policy circles and European crypto projects, making him a key gatekeeper for how KuCoin positions itself toward regulators, institutions and the local ecosystem. Call for Information FinTelegram invites insiders, former colleagues, regulators and industry partners to share additional information on Oliver Stauber’s role in KuCoin’s MiCA application, his interactions with the FMA, and his wider influence on Austrian crypto policy. Information can be provided confidentially via Whistle42. Share Information via Whistle42

Seychelles-born, Hong Kong-owned, U.S.–sanctioned KuCoin has just won one of Europe’s most coveted trophies: a MiCA crypto-asset service provider (CASP) licence from Austria’s FMA via KuCoin EU Exchange GmbH. This licence gives KuCoin passported access to (almost) the entire EEA – despite a fresh U.S. criminal guilty plea for unlicensed money transmission and serious AML failures, a record fine in Canada, and a history of red-flag regulator warnings worldwide (Sources: KuCoin, Reuters, Reuters). The “Austrianization” of KuCoin raises uncomfortable questions about MiCA’s fit-and-proper tests, the FMA’s risk appetite, and whether Vienna is becoming the rehab clinic for high-risk global crypto exchanges. 1. The Setup: MiCA Passport, Austrian Gateway At the end of November 2025, KuCoin EU Exchange GmbH announced that it had obtained a Markets in Crypto-Assets (MiCA) licence from the Austrian FMA. The licence allows KuCoin EU to offer MiCA-regulated services across 29 EEA countries (Malta excluded) via passporting (Source: Coindesk). Austria is positioning itself aggressively as a MiCA hub. Alongside KuCoin, the FMA has now authorised Bitpanda, Bybit EU GmbH, AMINA (Austria) AG, Cryptonow and FIOR Digital as CASPs under MiCA (Source: LinkedIn). Only Bitpanda is genuinely Austrian; the others (including KuCoin) are foreign groups using Vienna as their EU beachhead. Under MiCA, NCAs like the FMA must assess the “good repute” of CASP management and qualifying shareholders, including the absence of serious AML/CTF penalties, and ensure robust governance, capital and client-asset safeguards (Source: ESMA, A&O Sherman). Against this backdrop, KuCoin’s licence looks anything but routine. Download the full KuCoin Compliance Report 2025 here. 2. The Austrian KuCoin Cluster: People & Structure 2.1 Corporate structure in Austria According to Austrian company records and press releases, KuCoin has quietly built a mini-conglomerate in Vienna (Source: Northdata): Coper Frontier Tech Holding Limited (Hong Kong) Private company limited by shares, incorporated 29 May 2024 in Hong Kong (Source: Companies Register) Acts as 100% shareholder of KuCoin EU Holding GmbH, Vienna (Source: Companies Register). Role: Austrian holding company. Shareholder: Coper Frontier Tech Holding Ltd (Hong Kong). Managing directors: Oliver Peter Stauber, Bochong (BC) Wang. Subsidiaries of KuCoin EU Holding GmbH (all Vienna): KuCoin EU Exchange GmbH – the MiCA-licensed CASP and European trading platform. KuCoin EU Financial Services GmbH – described as providing “financial services,” likely B2B or ancillary activities. KuCoin EU Payment Services GmbH – designed for payment-related services in the group. KuCoin EU Capital Markets GmbH – corporate object explicitly includes “Ausgabe von Finanzderivaten” (issuance of financial derivatives), indicating ambitions beyond spot trading. This is a fully-fledged European platform structure, not a minimal branch. It is built in just a few months (most entities founded or renamed in November 2025), clearly tailored for MiCA and possibly future MiFID-style activities. 2.2 Key people From Austrian registers and KuCoin’s own communications: Oliver Stauber – CEO of KuCoin EU; managing director of KuCoin EU Holding and several subsidiaries; Austrian lawyer, previously at Bitpanda and active in local crypto industry associations. Christian Niedermüller – COO of KuCoin EU. Christian Derler – Chief Compliance Officer (CCO) and managing director of KuCoin EU Capital Markets GmbH. Tamara Rubey – General Counsel and managing director of KuCoin EU Payment Services GmbH. Bochong (“BC”) Wang – CEO of the global KuCoin operator Peken Global Limited and managing director of KuCoin EU Holding GmbH. He signed the U.S. criminal plea on behalf of KuCoin’s Seychelles entity. Whale Hunting+1 In other words: the same top executive who admitted U.S. felony-level AML failures for KuCoin now co-controls the Austrian holding that owns the MiCA-licensed EU platform. The ultimate beneficial owners behind Coper Frontier Tech Holding Limited are not publicly disclosed in the open Hong Kong registry sources used here, meaning EU investors and counterparties cannot easily verify who ultimately controls the Austrian KuCoin cluster. 996co.com+1 3. KuCoin’s Track Record: Warnings, Charges, Guilty Pleas 3.1 Global regulatory warnings KuCoin has long been on regulators’ radar: Spain – CNMV issued a public warning in 2022 against KuCoin (Mek Global Limited / kucoin.com) for operating without registration (Source: CNMV) Netherlands – DNB warned in 2022 that KuCoin was operating without mandatory AML registration and “illegally offering services” (Source: Wikipedia) UK – FCA added KuCoin/kucoin.com to its warning list of unauthorised firms in October 2023 (Source: FCA). Canada – OSC (Ontario Securities Commission) warned investors that KuCoin and related entities were not registered to trade securities (Source: TheBlock). FinTelegram has previously summarised these warnings and KuCoin’s poor Trustpilot ratings in earlier reports. Read our KuCoin reports here. 3.2 U.S. criminal case & CFTC action In March 2024, the U.S. Department of Justice (SDNY) unsealed an indictment against KuCoin and founders Chun Gan and Ke Tang for conspiracy to violate the Bank Secrecy Act and operate an unlicensed money transmitting business (Source: US DOJ). Parallelly, the CFTC filed a civil complaint alleging KuCoin (Source: CFTC): ran an unregistered futures commission merchant, offered off-exchange leveraged crypto transactions and swaps to U.S. retail, failed to implement an effective Customer Identification Program (CIP) and AML measures, allowed up to 50% of customers to be U.S. residents despite geoblocking claims. 3.3 Guilty plea and $297m settlement On 27 January 2025, KuCoin’s Seychelles entity Peken Global Limited pleaded guilty in SDNY to operating an unlicensed money transmitting business and agreed to pay over $297m in fines and forfeiture. Prosecutors highlighted that KuCoin: failed to implement KYC and AML controls, did not file suspicious activity reports, facilitated billions of dollars in suspicious transactions linked to darknet markets, ransomware, and fraud, earned at least $184.5m in fees from U.S. users alone. As part of the plea, KuCoin must exit the U.S. market for at least two years, and founders Gan and Tang entered deferred prosecution agreements and stepped away from management (Source: Reuters). The plea agreement names Bochong Wang as the CEO authorised to bind Peken Global to the guilty plea – the same Wang who is now a managing director of KuCoin’s Austrian holding company. Whale Hunting+1 3.4 Canadian AML penalty In September 2025, Canada’s AML agency FINTRAC imposed a C$19.6m penalty on Peken Global Limited, the KuCoin operator, for failing to report suspicious transactions and large virtual currency receipts, describing this as its largest fine to date – before an even larger penalty against another crypto dealer in October. KuCoin has reportedly appealed the FINTRAC decision. 4. MiCA vs. KuCoin: Fit & Proper or Regulatory Arbitrage? MiCA’s CASP regime is explicit: NCAs must assess the good repute of management and qualifying shareholders, including absence of serious penalties for AML/CTF and fraud, and ensure sound governance, capital and client-asset protections (Source: Ramparts). Yet Austria has now authorised, as a MiCA CASP: a group whose core operating entity (Peken Global) has just pleaded guilty in the U.S. to unlicensed money transmission and systemic AML failures, whose CEO, Bochong Wang, personally signed that plea and simultaneously manages the Austrian holding, whose operator has been hit with a record AML fine in Canada, which has accumulated a long list of regulatory warnings across major jurisdictions. At the same time, EU regulators are openly worried about a “race to the bottom” in MiCA licensing. Reuters reported that some large crypto companies were poised to obtain EU-wide licences amid concerns that certain NCAs are too lenient; France has even floated the idea of blocking passporting for firms approved in “soft” jurisdictions (Source: Reuters). Against this backdrop, KuCoin’s Austrian MiCA licence looks less like a triumph of “trust and compliance” and more like a test case for regulatory arbitrage: Reputation & conduct risk – A MiCA-licensed CASP with fresh U.S. felony-level AML failings and Canadian AML penalties is, by definition, a high-risk counterparty. The FMA must have concluded that its remediation and new EU governance outweigh the history – a judgement that deserves scrutiny. Fit & proper of key managers – Even if Wang is not personally convicted, MiCA and ESMA guidance push NCAs to evaluate collective responsibility and track record of management. Putting the CEO of the guilty entity at the top of the EU holding raises serious questions about the practical application of “good repute”. Opaque ultimate ownership – With Coper Frontier Tech Holding Ltd as a recently-incorporated Hong Kong shareholder and no easily discoverable beneficial ownership data, MiCA supervisors must rely heavily on confidential filings. From an external perspective, UBO transparency remains poor. Group complexity & risk migration – The additional Austrian entities for financial services, payment services and capital markets indicate a platform strategy that could extend into derivatives and structured products. Given KuCoin’s U.S. history with unregistered derivatives, this is a segment where EU NCAs cannot afford a repeat of the “offshore shadow-exchange” model under a MiCA label. MiCA as a badge – or smokescreen? – KuCoin’s blog and PR materials lean heavily on MiCA as evidence of “top-tier compliance” and “trust architecture,” listing SOC2/ISO certifications and PoR audits. But certifications and buzzwords do not erase years of documented AML lapses; they simply make it easier to market a high-risk exchange to EU retail. For Austria, the reputational question is straightforward: Is the FMA building a European compliance fortress – or a comfortable harbour for globally challenged exchanges looking for a second chance? 5. Summary Table – KuCoin Group & Austrian Structure Brand / DomainLegal Entity (key)Role / FunctionKey People (selected)JurisdictionRegulatory / Enforcement NotesKuCoin / kucoin.comPeken Global Ltd (operator), plus Mek Global Ltd, PhoenixFin Pte Ltd, Flashdot Ltd cftc.gov+1Global exchange, spot & derivativesFounders Chun Gan, Ke Tang; CEO Bochong (BC) WangSeychelles, Singapore, etc.U.S. DOJ indictment (BSA & unlicensed MSB); CFTC complaint (unregistered FCM, AML failures); U.S. guilty plea & $297m penalty; U.S. market exit ≥2 years. KuCoin EUKuCoin EU Exchange GmbHMiCA-licensed CASP (EU trading & custody)Oliver Stauber (CEO), Christian Niedermüller (COO), Christian Derler (CCO)Lim Shu Ting AustriaMiCA licence from FMA; passporting across 29 EEA states (ex Malta). –KuCoin EU Holding GmbHAustrian holding for all EU subsOliver Stauber, BC Wang (MDs)Austria100% owned by Coper Frontier Tech Holding Ltd (Hong Kong). –KuCoin EU Financial Services GmbHFinancial / ancillary servicesMD: Oliver StauberAustriaNewly structured in late 2025; potential B2B and structured offerings. –KuCoin EU Payment Services GmbHPayments and fiat on/off-ramp servicesMD: Tamara Rubey (GC of KuCoin EU)AustriaPotentially subject to PSD2-like oversight if applying for payment licence in future. –KuCoin EU Capital Markets GmbHDerivatives / capital markets (“Ausgabe von Finanzderivaten”)MDs: Oliver Stauber, Christian DerlerAustriaSuggests ambitions to issue or distribute structured crypto-linked products in EU. Coper Frientier Tech Holding Coper Frientier Tech Holding LtdParent company of KuCoin EU Holding GmbH–Hong KongUltimate Beneficial Owners (UBOs) unknown 6. Conclusion & Call for Information (Whistle42) From a MiCA perspective, KuCoin EU’s Austrian licence is a stress test: Can a CASP whose core operator just pleaded guilty in the U.S. and was fined in Canada credibly pass Europe’s fit-and-proper and good-repute tests within months? Does the use of a fresh Hong Kong holding company as shareholder, combined with a large Austrian entity cluster, increase transparency – or obscure accountability? And what exactly convinced the FMA that KuCoin’s remediation is sufficient to protect EU retail and professional clients from a repeat of its U.S.-style AML failures? FinTelegram will continue to map KuCoin’s global corporate ecosystem and its interactions with regulators worldwide. Call for Information: We explicitly invite insiders, current or former employees, compliance officers, partners, and affected clients of KuCoin, KuCoin EU, Coper Frontier Tech Holding Ltd, or any related payment/derivatives entities to share information with us. If you have documents, internal communications, or first-hand knowledge about: KuCoin’s AML/KYC practices and remediation programmes, the true beneficial owners behind Coper Frontier Tech Holding Limited, the planned activities of KuCoin EU Financial Services, Payment Services, or Capital Markets GmbH, or the internal process behind obtaining the MiCA licence in Austria, please contact FinTelegram confidentially via our whistleblower platform, Whistle42. Share Information via Whistle42 Your information can help regulators, law-abiding market participants, and investors understand whether MiCA is truly raising the bar – or simply putting a new label on old risks.

A FinTelegram whistleblower describes how the alleged “fund recovery” specialist Nexora.Finance and individuals claiming to act from the “Payback finance department” turned an existing bank-fraud victim into a serial target: more than €28,000 in new losses, double payments “because of blockchain errors,” and crypto routed via an Austrian P2P dealer. Regulators and law enforcement already flag both names or their networks – yet the machinery keeps running. Key Facts At A Glance Whistleblower loss to Nexora.Finance: >€20,000 in “upfront fees” for promised recovery of funds lost in a German/Netherlands bank scam; pressured to repeat the same transfer due to alleged “technical issues with XRP and ETF crypto.” Whistleblower loss to Payback side: €8,511 to individuals identifying themselves as “Jordan Mitchell” and “Steve” from the “Payback.finance department”; money routed via Austrian P2P crypto dealer Hans Klemen with the classic “send the same amount again to unlock your crypto” pressure tactic. CSSF warning: Luxembourg regulator CSSF explicitly warns about fraudulent activities by unknown persons misusing the name of Nexora SARL-S, via website www.nexora.finance, and stresses that the real Nexora SARL-S is not involved (Source: CSSF). Global law-enforcement focus on PayBack network: The FBI has seized web domains of Payback LTD as part of a cryptocurrency recovery fraud investigation, describing a pattern of high promises, upfront fees, and no real recovery (Source: Federal Bureau of Investigation). Regulatory & watchdog alerts: Multiple regulators (FCA, BaFin, ASIC) and NGOs like EFRI and FinTelegram have warned that PayBack-branded “recovery services” and clones target fraud victims with new scams (Sources: FinTelegram, FCA, BaFin, ASIC). 1. What the Whistleblower Describes – A Classic Recovery-Scam Pattern According to the victim, the story begins with a bank scam in Germany and the Netherlands in July 2024, resulting in a loss of around €50,000. In the aftermath, the victim is contacted by Nexora.Finance and later by people claiming to act for “Payback.finance.” Phase 1 – Nexora.Finance: Nexora promises to recover the bank-scam losses. The victim pays over €20,000 up front. When crypto transfers allegedly run into “technical XRP and ETF blockchain issues,” Nexora demands the same transfer again, claiming this is needed to complete or “unlock” the recovery. The “recovered funds” are presented as even higher than the original loss, allegedly because the original scammers had “invested and grown” the funds – a classic psychological hook to keep the victim paying. Phase 2 – Payback side & Austrian P2P dealer: The victim is told that recovered funds are now sitting in an Exodus wallet. Two individuals, “Jordan Mitchell” and “Steve,” present themselves as part of a “Payback.finance Department” and instruct the victim to send €8,511 to an Austrian P2P crypto dealer, Hans Klemen. When the transfer is “rejected” in Exodus, the victim is told to repeat the exact same payment to unlock the funds on the blockchain – another very typical “double payment to unlock” trick. At this point, the victim finally cuts contact. Everything about this sequence – upfront fees, technical excuses, doubling payments, routing money via third-party crypto dealers – matches what regulators and law enforcement describe as recovery fraud. 2. Nexora.Finance – Identity Theft & Recovery Pitch On its website, Nexora.Finance presents itself as a polished “non-bank financial service” offering crypto-recovery and payment resolution with glowing testimonials and claims of “cutting-edge technology” to recover lost crypto (Source: nexora.finance) But Luxembourg’s CSSF pulls the emergency brake: The CSSF explicitly labels the operation as “fraudulent activities by persons misusing the name of Nexora SARL-S.” It identifies www.nexora.finance as the website used, with an alleged office at 37A, Avenue Kennedy, Luxembourg, and clarifies that the real Nexora SARL-S, based at 466, Route de Longwy, has nothing to do with these activities. There is also a NEXORA FINANCE LIMITED registered in the UK (Wakefield address), but there is no public evidence linking this UK company to the website or to the Luxembourg identity theft – adding to the confusion for victims (Source: UK Companies House). Additional red flags: Public Q&A platforms show people asking whether Nexora Finance is legitimate after cold approaches about “recovering your scam losses,” indicating pro-active targeting of victims (Source: JustAnswer). Trustpilot pages show a mix of reviews, including negative reports describing Nexora as a scam and complaining about upfront fees, with little or no visible engagement from the company (Source: uk.trustpilot). In FinTelegram’s view, any operation trading under Nexora.Finance and pitching “fund recovery” must be treated as a high-risk recovery scam, especially given the CSSF’s explicit language and the whistleblower’s loss scenario. 3. PayBack – From “Fund Recovery” Brand to Law-Enforcement Target The PayBack brand (Payback.com, Payback Ltd, various “Payback-recovery” domains and clones) presents itself as a global scam-recovery specialist. Its websites sell “investigation reports” and “crypto tracing reports,” stating that they “do not engage in financial services” and charge case-based fees (Source: Payback, Payback) However, regulators and law enforcement tell a different story: The FBI San Diego office seized domains of Payback LTD, MyChargeBack, and Claim Justice in a cryptocurrency recovery fraud investigation, stating that these companies charged significant upfront fees and commissions while having no real record of successfully recovering funds. ASIC and MoneySmart warn about payback-recovery.com impersonating regulators with fake documents and offering money-recovery services to scam victims. The FCA and BaFin flag PayBack LTD / Money Back Ltd as part of a clone-firm setup that preys on victims of investment fraud. The European Funds Recovery Initiative (EFRI) explicitly urges victims to “strictly avoid recovery scammers especially Payback Ltd,” documenting a long pattern of complaints from victims. FinTelegram has already published a detailed warning about the PayBack fund recovery scam, including references to directors and beneficial owners and to unlicensed activities in multiple jurisdictions. Against this background, any contact from people claiming to act for “Payback” or a “Payback finance department” should ring alarm bells, particularly when they ask for upfront crypto payments via P2P dealers – exactly what our whistleblower describes. 4. The Nexora–PayBack Connection: A Serial-Victim Business Model The whistleblower’s case suggests an operational link or at least a coordinated flow between Nexora.Finance and individuals claiming to be Payback staff: Nexora first monetises the original bank fraud by charging a large upfront “recovery” fee (>€20,000). Funds allegedly recovered are shown as crypto in an Exodus wallet, creating the illusion of success. Payback-branded actors then step in to “help release” these crypto funds – but only if the victim sends fresh money via a local P2P crypto dealer (Austria), with the classic “repeat the identical transaction to unlock the blockchain” lie. From a compliance perspective, this model: Recycles victims from one scam to the next (“double or triple victimisation”). Uses opaque third-party P2P dealers and bank accounts – typical layering behaviour from an AML point of view. Leverages recovery-industry branding (“crypto tracing,” “investigation report”) to create a veneer of legitimacy. The question practically asks itself: How many more victims are being circulated through this Nexora–PayBack pipeline right now? FinTelegram Warning & Call for Information FinTelegram strongly warns consumers and investors NOT to engage with Nexora.Finance or any PayBack-branded recovery offer that demands upfront payments, crypto transfers, or repeat “unlock” payments. If you have already paid such entities, do not send further money, keep all documents, emails, WhatsApp chats, and payment receipts. File complaints with your local police, financial regulator, and – where relevant – reference the CSSF warning on Nexora and the FBI/ASIC/FCA/BaFin actions on PayBack-type schemes. Call to victims & insidersFinTelegram is investigating the global network behind Nexora.Finance, PayBack LTD, and connected P2P dealers. If you: have worked for these entities, processed payments for them, or have been approached or harmed by similar “fund recovery” offers, please share your information, documents, and screenshots confidentially via our whistleblower platform Whistle42. Your evidence can help expose this network and protect countless other victims from being scammed a second and third time. Share Information via Whistle42

Russian entrepreneur Vladimir Gorbunov presents himself as a visionary “cryptofounder.” In reality, he sits at the center of a complex cluster of brands and entities – Crypterium, Choise.com / Choise.ai, vbanq, Vault.ist and related offshore companies – that has left thousands of users with heavy losses, locked funds, and unanswered questions. Public records, marketing materials, and liquidation documents show that the same small group of founders and entities keeps reappearing as projects are rebranded or wound down and relaunched under new names. This continuity of people and infrastructure, combined with opaque ownership and cross-border structures, calls for intense regulatory scrutiny and insider testimony. Introduction Gorbunov’s own LinkedIn and public interviews paint a clear timeline (Source: LinkedIn): 2017: Launch of Crypterium AS in Estonia and the CRPT ICO, raising tens of millions of dollars for a “cryptobank for cryptopeople.”​ 2022: Rebrand to Choise.com / Choise.ai – explicitly described by Gorbunov as “the next step in the development of Crypterium,” built on the same infrastructure and tokenomics.​ 2023+: Launch of Vault.ist and vbanq as “cryptobanking white‑label and API solutions,” which Gorbunov openly states are fully built on top of the Choise/Crypterium infrastructure.​ In his own words, Vault is “one of the leading digital/crypto banking companies worldwide,” and its infrastructure “is fully built on the foundation of Choise.com’s infrastructure,” into which he claims to have invested tens of millions (Source: TradingView) That means the same technology stack, the same “crypto‑fiat banking” logic, and many of the same people – just wrapped in new brands.​ Read our Crypterium report here. Yet while Gorbunov boasts of more than $35–60 million invested and “over $1 billion” in project capitalization at the beginning of 2022, CRPT and CHO token holders have seen their investments implode by over 99%, and Choise’s EU VASP entity is now in liquidation. So the question practically asks itself: whose capitalization was being built – and at whose expense? Key Facts Table ItemDetailsNameVladimir GorbunovNationalityRussian (as described in multiple project materials and interviews) Choise.com+1Social MediaLinkedInKnown rolesCo-founder of Crypterium; CEO & Founder of Choise.com; driving force behind rebrand from Crypterium to Choise.com; key founder figure in wider Choise / Choise.ai / Vault.ist / vbanq infrastructure. Earlier venturesCo-founded PayQR (PayQR.ru), a Russian-Cyprus-based contactless payments company, and several other fintech projects. PartnersGleb Markov (LinkedIn)Slava Semenchuk (LinkedIn)Kimm Austin (LinkedIn)Andrey Diyakonov (LinkedIn)ICO / token historyCore founder behind the Crypterium ICO (CRPT token) and later CHO token for Choise.com. Current ecosystemLinked by public sources and critics to Choise.com / Choise.ai, vbanq and Vault.ist – a white-label “crypto-friendly banking” and “Digital Banking-as-a-Service” stack. ControversiesUsers and commentators report locked funds, heavy losses and a problematic liquidation process at Choise.com; some label the projects as “scams.” Regulatory status (key entity)Lithuanian operating entity UAB Choise Services is formally under liquidation. Read our vbanq / Vault report here. Narrative Profile – From “Cryptobank” Pioneer to Serial Rebrander Gorbunov entered the public crypto stage as one of the founders of Crypterium, a 2017 “cryptobank” ICO that promised card-based spending of cryptocurrencies and seamless payments. KPMG’s Fintech100 list and independent reports name him among Crypterium’s key people, alongside Gleb Markov, Austin Kimm, and others (Source: KPMG). In June 2022, he personally announced the rebranding of Crypterium to Choise.com, calling it “the next step in Crypterium’s evolution” and promising a MetaFi ecosystem that would blend CeFi and DeFi and open “new ways to earn more” (Source: Choise.com). Choise.com rolled out interest-bearing accounts, yield products, NFTs and a CHO token, heavily marketed as the natural continuation of the Crypterium story (Source: Choise.com). At the same time, Gorbunov cultivated a media persona as a seasoned fintech innovator with “projects exceeding $1 billion in capitalization,” giving podcasts and interviews on proof-of-reserves and risk management (Source: Spotify for Creators). Fast-forward to 2024–2025: The Lithuanian operating company UAB Choise Services is now in liquidation, with an official status of “Under Liquidation” in the Lithuanian registry (Source: Okredo.com). Users on LinkedIn and Trustpilot complain that funds have been locked for months, settlements are slow, and losses are massive, even as the group insists the process complies with Lithuanian law. Critics on social media explicitly describe Crypterium/Choise tokens and NFTs as “scamcoins”, singling out Gorbunov and his close associates by name – allegations he and the companies dispute. While the liquidation plays out, new brands have surged to the foreground: Choise.ai, presented as an AI-driven RWA and crypto-fiat infrastructure. fintelegram.com+1 Vault.ist / vbanq, marketed as “Digital Banking-as-a-Service” and a “crypto-friendly banking platform,” offering white-label cards, accounts and digital-asset services for partners. Public profiles and corporate registry summaries now describe Gorbunov as founder of Choise.com and Crypterium and founder at Vault.ist – the same crypto-banking vision re-exported as infrastructure for other brands. THE ORG+2Gate.com+2 A natural question follows:Is this a story of continuous innovation – or of a troubled scheme constantly changing skins as user losses crystallize and regulators close in? Regulatory / Legal Notes The projects associated with Gorbunov have, at times, highlighted EU licensing and PCI/ISO certifications for Choise.com, presenting it as a “licensed, fully regulated financial institution in the EU.” However, the core Lithuanian entity is now being wound down, while the higher-profile brands migrate to AI, RWA and BaaS narratives under different entities in the UAE, Czech Republic and other jurisdictions (Source: Lithuanian Company Register). Publicly available terms of use for Choise.com reserve the right not to return assets used as collateral or for income generation in the event of bankruptcy or liquidation, a clause that may shock retail users who believed they were dealing with a “regulated, insured” platform. To date, there is no public record of a criminal conviction against Vladimir Gorbunov in relation to these projects. But the combination of ICO-era capital raising, complex cross-border company structures, high-risk yield products, and now a contentious liquidation inevitably raises red flags for regulators, banks, and law-enforcement agencies. Analysis – Patterns That Demand Answers From a compliance and investor-protection perspective, several patterns around Gorbunov’s ecosystem stand out and demand further investigation: Serial Rebranding with Continuity of Control Crypterium → Choise.com → Choise.ai and the shift towards Vault.ist / vbanq all feature similar promises (crypto banking, cards, yields) and overlapping leadership, with Gorbunov repeatedly presented as founder/CEO or strategic mastermind. Each cycle brings new branding and buzzwords (cryptobank, MetaFi, AI, BaaS) while legacy users struggle to recover funds. Jurisdictional Arbitrage & Offshore Anchors The ecosystem touches Estonia, Lithuania, Cyprus, the UAE, Czech Republic, Delaware, and offshore hubs, often via opaque companies and MSB/VASP registrations that are hard for retail users to interpret. Asymmetry Between Marketing Claims & Legal Reality Marketing talks about “regulated, insured, safe, fully compliant” platforms. Liquidation documents and ToS clauses, by contrast, stress that certain assets may not be returned and that recovery is subject to complex legal processes and cut-off dates. Investor & User Outcomes vs. Founder Narratives While founders tout billion-dollar project valuations and innovation awards, many token holders and wallet users face near-total losses and months-long waits. These are not technicalities. They go to the heart of the question: Has Gorbunov’s “cryptobank” vision primarily served users – or has it systematically transferred risk and loss to them while the corporate shell keeps mutating? Call for Information – Whistle42 FinTelegram considers Vladimir Gorbunov and the Crypterium / Choise / Choise.ai / vbanq / Vault.ist complex a high-risk structure that merits close scrutiny by regulators, banks, card schemes, and law-enforcement agencies. To move from suspicion to evidence, we urgently need insider information: Internal memos, investor decks, or liquidation instructions; Contracts between Choise entities, Vault.ist / vbanq and banks, PSPs or card issuers; Proof of how user funds, collateral, and token sale proceeds were actually handled; KYC/AML manuals, risk reports, or correspondence with regulators and liquidators. If you are or were an employee, contractor, consultant, partner bank, payment provider, or affected user, you can securely submit documents and information to FinTelegram via the Whistle42 whistleblower platform (Whistle42.com). Your information can help clarify who really controls this network, how capital has flowed through it, and whether users are being treated lawfully and fairly. Share Informatin via Whistle42

Vault / vbanq positions itself as a “crypto‑friendly secure banking platform” and “Digital Banking‑as‑a‑Service” provider, but the structure, disclosures, and history indicate a high‑risk, opaque scheme closely connected to the troubled crypto schemes Crypterium and Choise, led by Russian entrepreneur Vladimir Gorbunov. Open-source research shows that: A russian crew operates the scheme under the mastermind Vladimir Gorbunov. Vault IST DMCC (UAE) owns the Vault website/app and is licensed only as a Software House, not as a bank or financial institution (Source: Vault). Vault Fintech Solutions s.r.o. (Czech Republic) is registered as a virtual-asset service provider (VASP), providing crypto services for Vault (Source: Vault) Pure Digital Exchange LLC (Delaware, USA) – an MSB registered with both FINTRAC (Canada) and FinCEN (USA) – is part of the same structure and provides crypto-fiat transaction processing (Source: Vault). Payment cards are issued by Reap Technologies Limited (Hong Kong) under card terms where Vault Global Solutions Limited is the “Partner” dealing with cardholders and Lithuanian law is chosen as governing law (Sources: Vault, CR Hong Kong, Ltd Dir). vbanq.com / vbanq.net list Charism LLC (SVG) as the site owner – the same offshore entity used in the Crypterium / Choise scheme (Source: VBANQ). Leadership and documentation clearly tie Vault/Vbanq to the Russian-controlled Crypterium / Choise complex, which raised tens of millions in the 2017–2018 ICO boom and is now in liquidation in Lithuania (Choise Services UAB) after years of user complaints and scam allegations (Source: fintelegram.com). Read our compliance report on Crypterium here. From a compliance perspective, vbanq/Vault is best classified as a high-risk, multi-jurisdictional crypto-banking infrastructure cluster built on a problematic legacy, with notable transparency and investor-protection concerns. 2. Business Model & Marketing Vault (vault.ist) and vbanq (vbanq.com / vbanq.net) market a white‑label “banking + cards + crypto” stack that other brands can use as their own digital/crypto bank. Core promises include:​ Individually segregated IBAN accounts, Visa/Mastercard cards, Apple/Google Pay, and crypto‑friendly processing to 200+ countries.​ Crypto custody in 100+ coins, token integration, on‑/off‑ramp, and FX between fiat and digital assets.​ Ultra‑fast go‑to‑market: launch a “bank” in days, with low capex, and “millions saved” versus building and licensing in‑house.​ Vbanq is pitched as the end‑user front end: a business account “live in 24 hours,” with corporate banking, multi‑currency fiat (USD, EUR, INR), digital asset wallets (BTC, ETH, USDT), and third‑party payments via SWIFT, ACH, Fedwire, SEPA, NEFT. Both brands strongly blur the line between:​ Banking (accounts, cards, payments), and Technology/BaaS (pure software / integration), while not themselves being licensed banks or payment institutions, instead claiming to rely on unnamed “regulated partners.”​ The privacy policy stresses that Vault IST DMCC “does not hold a banking or financial institution license” and that “all financial, card, and token services are provided by regulated third-party institutions under their respective licenses and jurisdictions.” This is a classic “synthetic banking” model: a software entity brands and sells “banking-like” services while legal responsibility is fragmented across third-party banks, card issuers, and MSBs. 3. Corporate Structure & Beneficial-Ownership Landscape Entities & roles (as disclosed by Vault and related sites): VAULT IST DMCC (UAE) DMCC-registered “Software House” (licence DMCC198149). Owns vault.ist website and app. Not a bank/EMI; tech platform only. Vault Fintech Solutions s.r.o. (Czech Republic) Company no. 21627002, Prague. Registered to provide virtual-asset services (crypto exchange / wallet). Provides crypto services for Vault. Pure Digital Exchange LLC (Delaware, USA) US LLC, MSB-registered with FINTRAC (Canada) and FinCEN (USA). Handles crypto-fiat processing and fiat payments. Vault Global Solutions Limited (Hong Kong) Hong Kong company no. 76127971, incorporated 16 Jan 2024. cr.gov.hk+1 Acts as “Partner” in Vault card terms and front-end contracting party for cardholders under Lithuanian law. Vault.ist Charism LLC (St. Vincent & Grenadines) SVG LLC (no. 1999 LLC 2022) used historically in Crypterium/Choise card and wallet terms; now also listed as vbanq website owner. Choise.com+1 Choise Services UAB (Lithuania) – “Legacy” Lithuanian VASP (crypto exchange and wallet operator) now in formal liquidation (“Likviduojamas”) since April 2025. rekvizitai.vz.lt+1 Key persons & likely controllers Vault’s “Meet the Team” page lists (Source: Vault): Vladimir Gorbunov, founder of vbanq /Vault, Crypterium, and Choise. Austin Kimm – Chairman of the Board & Co-Founder Also co-founder of Crypterium, which launched the “first ever crypto-payment card.” Andrey Diyakonov – CCO Credited with leading Choise.com to over 1m users and building its B2B platform. FinTelegram’s Choise analysis identifies Russians Vladimir Gorbunov, Gleb Markov, and Slava Semenchuk as founding figures behind Crypterium/Choise and describes Vault and Vbanq as B2B/white-label infrastructure brands within the same ecosystem. While formal shareholder registers for VAULT IST DMCC, Vault Fintech Solutions, Vault Global Solutions Limited and Charism LLC are not publicly disclosed, the continuity of founders (Kimm, Diyakonov) and corporate entities (Charism, Choise Services UAB) strongly suggests that beneficial ownership remains within the same Russian-centric founder circle that controlled Crypterium/Choise. 4. Historical Links to Crypterium & Choise The Vault story explicitly traces back to 2017–2018, when Crypterium marketed itself as the “world’s first cryptobank” and launched a widely advertised crypto card and high-yield “deposit” products. Key continuity indicators: Vault claims it launched the first “crypto-backed payment card” in 2018 – the same marketing claim long used for Crypterium. Vault’s C-level team (Kimm, Diyakonov) are prominently described as former leaders of Crypterium/Choise.com’s retail and B2B platform. Vault IST’s AML/KYC and anti-fraud policy PDFs still refer to “Choise Services UAB” and “Crypterium AS” in their definitions – strong evidence of document reuse and common infrastructure. FinTelegram’s Choise liquidation report explicitly lists Vault and Vbanq as white-label “cryptobanking” infrastructure extending the risk footprint of the Crypterium/Choise group. In parallel, Choise Services UAB is in liquidation and Crypterium AS (Estonia) has been struck off, while numerous user complaints and community posts accuse the group of locking funds and running a long-running scam. Against this backdrop, the emergence of vbanq/Vault as a “new” B2B2C bank-as-a-service solution looks less like a fresh start and more like a repackaging of the same infrastructure and people under different brands and jurisdictional wrappers. 5. Regulatory & Licensing Posture What is regulated (and where): Vault Fintech Solutions s.r.o. (CZ) – VASP registration (crypto-asset services) under Czech law. No banking/EMI licence. Pure Digital Exchange LLC (US) – MSB licence (FinCEN) + FINTRAC MSB registration (Canada), for crypto-fiat and payment processing. Reap Technologies Limited (HK) – card issuer under its own local authorisations. What is not regulated as a bank: Vault expressly states it is not a bank or financial institution, but markets “crypto-friendly banking”, global bank accounts, and FDIC-insured checking through partners. Vault.ist+2Vault.ist+2 Regulatory gaps and concerns: Bank-like branding without banking licences “Cryptobank”, “digital bank”, “checking accounts” and “FDIC-insured” language can easily mislead retail users into assuming bank-level prudential supervision and deposit protection, while actual client relationships and protections depend on opaque third-party banks/MSBs. Fragmented and opaque counterparty risk A client of vbanq/Vault may simultaneously be exposed to: VAULT IST DMCC (software house, UAE), Vault Fintech Solutions (CZ VASP), Pure Digital Exchange LLC (US/CA MSB), Reap Technologies (HK card issuer), Vault Global Solutions Limited (HK contracting entity), Charism LLC (SVG website owner). This multi-layered structure complicates AML/CTF supervision, complaints, and legal recourse. Legacy risk from Choise/Crypterium The only EU-regulated VASP in the old stack (Choise Services UAB) is now in liquidation, while offshore entities like Charism LLC continue to operate structurally similar products. rekvizitai.vz.lt+2Choise.com+2 Overall, the group appears to deliberately distribute functions over multiple jurisdictions with differing regulatory strictness, which is typical for high-risk “crypto banking” constructs. 6. Compliance Risk Assessment From a professional compliance perspective, Vault / vbanq should be treated as a high‑risk crypto‑banking scheme with significant conduct, AML/CFT, and investor‑protection concerns: The founder’s track record with Crypterium/Choise and associated investor harm is a major negative factor. Group structure is intentionally complex and opaque, with offshore and free‑zone entities and at least one contracting company that cannot be easily located in public registries. The brand markets “banking” services while explicitly stating it is not a bank and shifting responsibility to unnamed partners, which is inconsistent with best practices for transparency and consumer protection. Links to Charism LLC SVG and the earlier Choise scheme suggest a pattern of rebranding and relaunching under new names rather than resolving past issues. For regulated institutions and compliance officers: Flag Vault / vbanq, Vault IST DMCC, Vault Fintech Solutions s.r.o., Charism LLC (SVG), and any “Vault Global Solutions” entity as high‑risk counterparties. Apply enhanced due diligence (EDD) to any customer or transaction exposure, with particular attention to source of funds, beneficiary’s relationship to the Vault/vbanq ecosystem, and possible layering through those platforms. Carefully evaluate any proposed partnership or white‑label cooperation with Vault / vbanq, as reputational and regulatory risks are substantial. Where suspicious activity and fraud indicators are present, consider filing SAR/STRs with competent FIUs in your jurisdiction. For retail and SME users: Treat Vault / vbanq as a high‑risk, non‑bank fintech scheme. Avoid using it as a primary repository of funds or for critical business payments. Use only well‑regulated, clearly licensed banks and EMIs where entity, regulator, and country are all transparent. Preliminary assessment:For regulated institutions and payment partners, vbanq/Vault should be treated as a high-risk counterparty requiring enhanced due diligence (EDD), stringent contractual risk-allocation, and detailed verification of underlying bank/MSB relationships, KYC standards, and complaint/exit procedures. 7. Summary Table ItemDetailsCompliance ObservationsBrand & Front-EndVault (vault.ist), vbanq (vbanq.com / vbanq.net)Sells “crypto-friendly secure banking” and DigiBaaS; not itself a bank.Key Legal EntitiesVAULT IST DMCC (UAE), Vault Fintech Solutions s.r.o. (CZ), Pure Digital Exchange LLC (US), Vault Global Solutions Ltd (HK), Charism LLC (SVG)Functions split across multiple jurisdictions; only VASP/MSB licences visible; no banking/EMI licence for the brand. Founders / ManagementAustin Kimm (Co-Founder, Crypterium co-founder); Andrey Diyakonov (CCO, ex-Choise.com B2B lead); Russian Crypterium/Choise founders (Gorbunov, Markov, Semenchuk) in the wider groupStrong people-continuity with Crypterium/Choise ecosystem now under liquidation and heavy scam allegations.Business ModelWhite-label “crypto banking” (accounts, cards, wallets, token solutions) + consumer-facing vbanq appSynthetic banking: branding and UX by Vault; regulated legs by third-party banks, MSBs, card issuers. Marketing risk around FDIC/deposit-like claims.Legacy Track RecordCrypterium/Choise ICO (~USD 50–52m), high-yield products, user complaints, Lithuanian VASP liquidationIndicates serious investor-protection and governance failures in the predecessor scheme. fintelegram.com+1Risk Rating (Preliminary)High-risk crypto-banking infrastructure with opaque ownership and complex jurisdictional setup; red compliance!Partners should apply EDD, monitor ongoing regulatory developments, and consider strict limits or avoidance. 8. Call for Information – Whistle42 FinTelegram will continue to monitor vbanq / Vault / Vault IST DMCC / Vault Fintech Solutions / Charism LLC and their predecessors, Crypterium and Choise, especially with regard to: Actual beneficial ownership and shareholder structures, Use of client funds and flows between EU, UAE, SVG, HK, and US entities, The true identity of U.S. partner banks behind FDIC-labelled products, Internal policies on withdrawals, account freezes, KYC/AML, and complaint handling. We explicitly invite insiders, former employees, contractors, banking and payment partners, and affected clients to share documents, contracts, screenshots, and correspondence with us via our whistleblower platform Whistle42 (Whistle42.com). Submissions can be made confidentially. Verified information will help regulators, law enforcement agencies, and victims to understand the full picture behind vbanq / Vault and its connection to the Crypterium/Choise complex. Share Information via Whistle42

A new battle line has opened in U.S. crypto regulation. As SEC Chair Paul Atkins floats an “innovation exemption” to let crypto firms sell tokenised stocks without full broker-dealer or exchange regulation, the World Federation of Exchanges (WFE) – representing Nasdaq, Deutsche Börse and other major venues – has warned that such relief would let crypto platforms bypass safeguards that have protected investors for decades. For crypto-compliance, this is a test case: will regulators enforce same activity, same rules or create a lighter regime for crypto players? Key Facts Reuters scoop: The SEC is considering exemptive relief or no-action letters so crypto firms can sell tokens linked to listed equities to U.S. retail investors, even when the firms are not registered broker-dealers (Source: Reuters) WFE pushback: In a 21 November letter, the WFE told the SEC that broad exemptions for tokenised stocks could harm market integrity and undermine investor protection, and that crypto platforms must not be allowed to “bypass regulatory principles that have safeguarded markets for decades” (Source: SEC) Tokenised stocks = mimicked equities: WFE and ESMA have repeatedly warned that many tokenised equities merely track a share’s price without conferring shareholder rights, governance or recourse, creating a false sense of owning the underlying stock (Source: WFE). Project Crypto & innovation exemption: In his “Project Crypto” speeches, Atkins frames the exemption as a way to experiment with new token models while tailoring future rules – a clear pivot towards a more industry-friendly stance under the current U.S. administration. Short Analysis From a compliance perspective, the WFE letter is more than industry lobbying – it is a public warning that the SEC may be about to create a parallel regulatory lane for tokenised equities. If crypto platforms can distribute equity-linked tokens to retail users without becoming broker-dealers or listing on regulated exchanges, core pillars of securities regulation – disclosure, best execution, market surveillance, customer protection – risk being outsourced to largely opaque crypto venues. The concern is not tokenisation per se. Both WFE and ESMA explicitly describe tokenisation as a “natural evolution” of capital markets – if implemented inside the existing rulebook (Source: WFE). The fault line is between genuine market-infrastructure upgrades (e.g. DLT settlement under full securities law) and “mimicked” stocks issued and traded in loosely regulated crypto ecosystems that promise 24/7 fractional exposure but provide none of the rights or protections of real shares. Under the Howey and Reves tests, most equity-linked tokens marketed for investment are plainly securities. Creating a bespoke exemption risks signalling that form (token vs. share) matters more than substance (exposure to an issuer’s equity). That would cut directly against decades of anti-arbitrage doctrine in U.S. securities law. Compliance Assessment & Implications For FinTelegram, several red flags stand out: Regulatory arbitrage: Crypto firms are effectively asking the SEC to bless a structure that competes with regulated exchanges while ducking exchange, ATS or broker-dealer obligations. Fragmented investor protection: Retail investors could end up in a weaker regime simply because they accessed “stocks” via a token app instead of a broker. Global spill-over: Any SEC green light would embolden token-stock issuers serving EU clients, even though ESMA has already warned that these products risk serious “investor misunderstanding.” FinTelegram’s view: tokenised equities should sit under the same or stricter rules as the underlying shares. If the SEC wants to encourage innovation, it should do so through carefully scoped sandboxes with hard investor-protection conditions – not through broad no-action comfort that crypto platforms can re-wrap equities and escape the core architecture of U.S. securities law. Call for Information FinTelegram invites insiders at crypto platforms working on tokenised stocks, regulated exchanges, brokers, custodians and regulators to share documents, internal memos or risk analyses related to tokenised-equity projects and any SEC outreach surrounding the proposed innovation exemption. Information can be submitted securely and anonymously via our whistleblower platform Whistle42 (whistle42.com). Share Information via Whistle42