The U.S. (Aug 14, 2025) and the U.K. (Aug 20, 2025) have escalated coordinated sanctions against Russia’s Garantex network — now operating through its successor Grinex and the ruble-pegged stablecoin A7A5 — accusing it of laundering ransomware proceeds and enabling cross-border payments to blunt Western restrictions. This is not a side-show: it’s the core plumbing of a Kremlin-aligned shadow rails strategy that moves billions and targets weak links in Central Asia. Key Points OFAC re-designated Garantex and designated Grinex; also hit executives and enablers (InDeFi Bank, Exved) and the A7/A7A5 issuer Old Vector tied to PSB and Ilan Shor. State Dept rewards up to $6M target the leadership (Sources: U.S. Department of the TreasuryCyberScoop). U.K. followed on Aug 20, listing GRINEX LLC, OLD VECTOR LLC, CJSC Tengricoin (Meer) and Capital Bank of Central Asia, citing a rouble-token A7A5 that moved $9.3B in four months (Source: GOV.UK). A7A5 has processed >$51B overall; activity spikes Monday–Friday — a business rails, not a retail coin. Grinex is the primary venue (Sources: Chainalysis). Law-enforcement takedown (Mar 6–7, 2025) seized Garantex domains/servers and froze >$26M; Garantex traffic and users were migrated to Grinex almost immediately (Sources: secretservice.gov). EU already listed Garantex in its 16th sanctions package (Feb–Mar 2025), the bloc’s first direct strike on a crypto exchange (Sources: icij.orglw.com). Short Narrative For years, Garantex was Russia’s cash-out of choice for ransomware, darknet markets, and sanctions evasion. When U.S. and European agencies seized its infrastructure in March, the operators didn’t fold — they rebranded the escape hatch: Grinex. Liquidity and users were bridged with a purpose-built ruble token, A7A5, issued out of Kyrgyzstan and backed by deposits at Promsvyazbank (PSB) — all designed to make sanctions friction disappear. Washington and London just called this out for what it is: state-aligned financial engineering masquerading as innovation (Sources: secretservice.gov,U.S. Department of the TreasuryChainalysis). Extended Analysis 1) The architecture — Grinex + A7A5 as the bridge.OFAC says Grinex was created by Garantex staff to continue operations post-takedown, explicitly marketed as the place to recover frozen balances. The A7A5 token — issued by Kyrgyz firm Old Vector — became the settlement layer to credit users and move value out of reach of seizures. OFAC also listed A7 LLC, A71, and A7 Agent, with links to Ilan Shor and PSB. This is a vertically integrated workaround: exchange → token issuer → sanctioned bank (Sources: U.S. Department of the Treasury). 2) Volumes and usage patterns — a business payments rail.Independent on-chain analysis shows A7A5 clearing >$51B since launch, with volumes concentrated on weekdays — a signature of B2B settlement. The primary order book is at Grinex; early liquidity traces back to Garantex, confirming the continuity of operations across the “rebrand” (Sources: Chainalysis). 3) Jurisdictional arbitrage via Kyrgyzstan.The U.K. explicitly targeted Kyrgyz nodes (Grinex LLC, Old Vector, CJSC Tengricoin/Meer, Capital Bank CA), reflecting how Russia leverages nearby licensing regimes to route trade and finance — including dual-use goods. Kyrgyz leadership protested publicly the next day — a sign the pressure is landing in the right place (Sources: GOV.UK, Reuters) 4) Crime-tech backbone — not “just” sanctions.U.S. authorities tie Garantex to hundreds of millions in criminal proceeds and list exposures to Conti, Black Basta, LockBit, Ryuk, NetWalker, Phoenix Cryptolocker. In total, $96B in lifetime transactions flowed through Garantex (2019–Mar 2025), underscoring its centrality to Russia’s illicit finance (Sources: CyberScoop). 5) Europe caught up.The EU’s 16th package (Feb–Mar 2025) added Garantex — the bloc’s first direct crypto-exchange listing — aligning Brussels with Washington and preparing the ground for coordinated transatlantic enforcement seen this month (Sources: icij.orglw.com). Actionable Insight (Compliance Playbook) Zero-tolerance exposure: Add Garantex, Grinex, A7, A71, A7 Agent, Old Vector, InDeFi Bank, Exved and A7A5 (all contract addresses/aliases) to your KYT/KYV blocklists; screen historical flows for A7A5 touchpoints (TRON/Ethereum) (Sources: U.S. Department of the Treasury,Chainalysis). Secondary-sanctions risk: Non-U.S. FIs dealing with listed entities risk secondary measures; ensure correspondent banks affirm no A7A5/Grinex exposure in reps & warranties (Source: TRM Labs). P2P & OTC choke points: Raise EDD on Russia-adjacent P2P markets (e.g., Bitpapa/NetEx24) and Kyrgyz-licensed VASPs; require source-of-funds for ruble-linked stablecoin flows (Source: TRM Labs). Incident triage: If you detect A7A5/Grinex exposure, freeze, file SAR/STR, and contact counsel; align with OFAC 50% rule and EU/UK ownership/control tests (Source: U.S. Department of the Treasury). Threat intel loop: Subscribe to OFAC updates and vendor intel (Chainalysis/TRM) to catch token migrations or DEX bridges that could launder A7A5 into dollar stablecoins(Sources: Chainalysis). Call for Information We are compiling a whistleblower dossier on Grinex/A7A5 routing, Kyrgyz VASP licensing, and PSB-linked settlement channels. Insiders, compliance officers, and engineers with knowledge of operational playbooks, wallet clusters, or fiat on/off-ramps: contact FinTelegram via Whistle42.com (confidential). Share Infornformation via Whistle42

Self-styled tycoon Valeriy Zolotukhin a/k/a Valery Zolotukhin a/k/a Valerii Zolotukhin (Валерий Золотухин) markets IMPACT Capital as a global VC juggernaut that “beats the S&P 500 nine years in a row.” Leaked ledgers, Russian corporate filings and whistle-blower testimony instead show a lattice of empty shell firms, investor wash-outs, and a controversial bid for a U.S. talent visa built on fabricated net-worth claims. Regulators on three continents are quietly probing what looks less like venture capital and more like a border-hopping pyramid. KEY POINTS Scam-Or exposé: A 19-page investigation labels Zolotukhin a “con-artist” who siphoned ≈₽350 M ($4.3 M) from IMPACT Capital to personal accounts while returning zero to 200+ investors (Source: scam-or). Visa-playbook: The same report alleges he is “blatantly lying” to USCIS to secure an EB-1 talent visa, funded by shareholder money (Source: scam-or). Micro, not mega: Public registry shows IMPACT Capital’s authorised capital at just ₽1.05 M and a head-count that fell to 7 staff in 2024—hardly a billion-dollar bank (Source: rusprofile.ru) Terrible trust score: Russian crypto site Coinspot rates IMPACT Capital 1.7/5, citing “predominantly negative reviews” and lack of audited results (Source: Coinspot). Shell-game footprint: Entities span Cyprus, UAE (FZCO), Delaware and the UK, with ownership shuffling to nominees in 2023—classic red-flag layering to evade scrutiny. SHORT NARRATIVE Zolotukhin (Facebook profile) shot to Telegram fame flogging high-yield “startup” tickets and posting glam reels from Dubai yachts. Investors wired minimum cheques of $50 000 into syndicates that promised 70% USD returns. Internal docs leaked to Scam-Or reveal a different flow: funds enter Moscow-based AO Impact Capital, bounce through UAE SPVs, then land in Zolotukhin family accounts labelled “loan repayment.” Meanwhile, Instagram brags of keynote spots in Miami and “global unicorn hunts.” The coup-de-grâce: a talent-visa dossier claiming billionaire status—while official Russian filings show a thinly capitalised software boutique on Electric Lane, Moscow. Impact was recognized as the best investment company according to Russian Venture in 2023, and the dating app Twinby (of which Impact was the first investor) was downloaded by 4.5 million people in a year. Valerii Zolotukhin on LinkedIn (link) EXTENDED ANALYSIS DimensionFindingsCompliance & Enforcement RiskLegalAlleged misappropriation of investor funds; possible false statements to USCIS.U.S. visa-fraud (18 U.S.C. §1546) exposure; Russian investors could bring criminal breach-of-trust claims.RegulatoryNo SEC, FCA or VARA registration; Central Bank of Russia flagged unlicensed fundraising in 2021. Cross-border offering without prospectus = securities-law breach; potential FATF predicate for money-laundering.Operational7-employee core masking >260 “related” entities; aggressive marketing via 1 600 referral agents. High KYC/AML risk for any FI transacting with Impact SPVs; enhanced due diligence warranted.ReputationalCoinspot & Scam-Or brand him “fraudster”; social feeds packed with luxury click-bait.Banks, accelerators and LPs tied to IMPACT may face ESG backlash and claw-back demands. ACTIONABLE INSIGHT Follow the “loan repayments,” the investigative platform Scam-Or suggests. Subpoena UAE bank statements of IMPACT SPV I Investment L.L.C and cross-match with Moscow AO Impact Capital outflows dated Feb 3–4 2025 (≈$1.6 M). Trace onward wires to personal IBANs linked to Valeriy or spouse Anna Zolotukhina—an obvious conduit for proceeds-of-fraud. Summarizing Table Valeriy Zolotukhin a/k/a Valery Zolotukhin a/k/a Valerii Zolotukhin (Валерий Золотухин)Russian-born entrepreneurImpact Capital founderSocial MediaLinkedIn, InstagramImpact Capitalwww.impact-capital.commena@impact-capital.com+971504132750Investment company für entrepreneurs and investors founded by Zolotukhin in 2019Val ZolotCEO of IMPACT CapitalRuslan GatykaevManaging Director IMPACT Middle EastLeon KulakovManaging Director IMPACT DACH CALL FOR INFORMATION Were you pitched IMPACT Capital & RANKS analytics, or “Downside Protection” insurance? Have screenshots, term-sheets or wiring instructions? U.S. and UAE agencies have open case numbers—your documents can accelerate asset-freezes. Share your information via our whistleblower system, Whistle42. Share Information via Whistle42.

Valentin Stalf, an Austrian entrepreneur and co-founder of N26, is leaving day-to-day management to join the Supervisory Board after a transition period. The move follows mounting investor pressure and renewed scrutiny from Germany’s BaFin. Stalf frames the shift as a forward-looking role change to support strategy while developing his family office—keeping a major shareholder role. N26’s DNA has always been distinctly Austrian (both founders are Austrian; deep Vienna ties) even as the company built its license, scale, and brand from Berlin. Key Facts ItemDetailNameValentin StalfNationalityAustrian (Vienna roots; studies at University of St. Gallen; exchange at Sophia University, Tokyo) Sources: assets.ctfassets.netSocial MediaLinkedInRole (new)Member, N26 Supervisory Board (after transition) Source: N26Role (previous)Co-founder & CEO (since 2013; rebranded Number26 → N26; full German banking license in 2016) Source: N26Co-founderMaximilian Tayenthal (also Austrian; remains on Executive Leadership/Management Board) Sources:assets.ctfassets.net,N26Company baseBerlin (Germany) with hubs incl. Vienna—Austrian founders, Berlin operations N26Trigger for changeInvestor demands amid reports of fresh BaFin pressure; governance reset. Source Financial Times,bankingdive.comNotable quote (press)Move is “forward-looking” to strengthen N26; time for family office & other pursuits. Source: N26 Narrative Profile Stalf co-founded N26 in 2013 with fellow Austrian Maximilian Tayenthal, launching as Number26 before securing a full German banking license in 2016 and rebranding to N26. Prior to N26, he worked as an Entrepreneur in Residence at Rocket Internet, building payments ventures—experience that shaped N26’s mobile-first approach. He studied at University of St. Gallen (M.A. HSG) and expanded his outlook with studies at Sophia University, Tokyo; he later served on the University Council of Vienna University of Economics and Business (2018–2023). While headquartered in Berlin, N26’s founding team and some governance ties remained anchored in Austria—both founders are Austrian, Vienna has been a company hub, and the founders’ networks draw heavily on the Austrian startup and academic scenes. In essence, the “Austrian fintech run from Berlin” characterization reflects the founders’ origin and network even as the license and core operations sit in Germany. Regulatory / Legal Notes (Context) BaFin actions: From 2021, BaFin imposed a growth cap and fines over AML reporting delays; the cap was fully lifted effective June 1, 2024, but a monitor remained and fresh deficiencies were later reported—fueling investor concerns. Operational impact: Regulatory remediation constrained growth, complicated fundraising, and intensified board-level governance negotiations—culminating in Stalf’s move upstairs. Analysis Stalf’s step to the Supervisory Board looks less like a personal sabbatical and more like a governance compact: investors want a demonstrably independent operating regime to satisfy BaFin and stabilize scale. With Tayenthal remaining operational for now, the board can inject risk-management depth (new CRO announced for December) and impose remediation-first KPIs before reigniting expansion. For a founder-led bank, this is the classic European trade-off: license durability over hypergrowth—and a reminder that neobank valuations live or die by regulator confidence. Call for Information FinTelegram invites current/former N26 staff, vendors, and advisers with first-hand knowledge of AML operations, remediation milestones, board-level governance changes, or investor term-sheet negotiations to contact us confidentially via Whistle42. Share Information via Whistle42

N26 co-founder Valentin Stalf is stepping down as CEO and moving to the bank’s Supervisory Board after a transition period—an outcome driven by a showdown with key investors and renewed friction with German regulator BaFin. The exit caps months of governance negotiations and follows fresh regulatory criticisms that jeopardized scaling plans and spooked backers. Key Points What happened: N26 announced that Stalf will relinquish operational duties and transition to the Supervisory Board after an initial handover. Co-founder Maximilian Tayenthal remains for now; Chair Marcus Mosen has been floated as interim co-CEO in some reports (Sources: n26.com,Financial Times). Why now: Major investors pushed for leadership change after BaFin identified fresh control weaknesses, with possible new sanctions discussed—barely a year after the growth cap was lifted (Sources: Financial Times,n26.com). Governance dealmaking: Negotiations reportedly included the founders giving up special voting rights in exchange for moderated investor economics and board nominations; the board warned against immediate re-appointments without a cooling-off period (Sources: Financial Times+1). Stalf’s message: In line with his LinkedIn note, the move is framed as a transition—not a departure from N26—while he stays engaged at the board level (Source: n26.com). Short Narrative The Berlin neobank’s long-running regulatory saga has come full circle to the C-suite. After BaFin lifted N26’s onboarding cap in June 2024, the bank touted renewed growth and a first profitable quarter. But subsequent audits and warnings reignited investor concerns over risk management and AML controls. That pressure culminated this week with Stalf’s resignation from the CEO post—an investor-driven reset aimed at convincing BaFin and the market that N26 can execute controls at scale (Sources: n26.com,Sifted,Financial Times). Extended Analysis Regulatory backdrop: BaFin’s 2021 measures (including a growth cap) and fines for AML reporting weaknesses were emblematic of systemic control gaps at N26. The cap was fully lifted effective June 1, 2024, but new findings in late-2024/2025—covering internal controls, processes, and organizational setup—sparked talk of additional sanctions and a special monitor. For an app-only bank pursuing scale, these findings translate directly into operational friction: slowed product rollout, audited back-books, and capital raise headwinds (Sources: n26.com,FinTech Futures,PYMNTS.com). Investor calculus: The 2021 Series E round set high return expectations (reportedly ~25% annualized). With public markets still choppy for fintech listings and growth constrained by compliance overhangs, investors pivoted to governance reform: swap out founders from day-to-day control, rebalance rights/economics, and insert a transitional operator to stabilize risk and regulatory relations (Sources: Financial Times+1). Read-through for EU neobanks: N26’s journey underscores a structural reality: in Europe’s bank-licensed fintech model, sustained scale requires regulator-grade risk frameworks that keep pace with customer growth and product complexity (e.g., mortgages via cross-border entities). Growth wins headlines; remediation wins permissions. Expect peers to tighten second-line independence, SAR timeliness, model validation, and board-level risk expertise (Sources: Sifted) What Stalf said (and didn’t): His public framing—echoed by the company release—emphasizes continuity (support from the Supervisory Board) rather than a break. But the timing dovetails with investor demands and BaFin’s renewed critiques—making this less a personal career move and more a governance settlement to de-risk the license (Sources: n26.com,Financial Times). Actionable Insight For regulators: Tie any supervisory relief to measurable milestones: SAR timeliness, KYC refresh backlogs, model risk documentation, and independent testing of first-line monitoring. For investors: Underwrite the turnaround to explicit KPIs (regulatory remediation plan deliverables, time-to-yes for new products, incident rates) and link management comp to risk outcomes—not just topline growth. For banks/fintechs: Treat “growth caps” as early-warning signals. Invest pre-emptively in AML ops capacity, adverse media screening quality, and real-time onboarding controls—especially when expanding credit or mortgage pipelines cross-border. Call for Information FinTelegram invites current and former N26 staff, vendors, and partners with first-hand knowledge of AML operations, control testing, audit findings, or governance negotiations to contact us confidentially via Whistle42. Share via Whistle42

Austria is finally moving from raids and remand to courtroom action: the first indictment against René Benko is final, and the first criminal trial is calendared for 14–15 October 2025 in Innsbruck on charges of betrügerische Krida (fraudulent depletion in insolvency). Meanwhile, the World Economic Council (WEC)—a Vienna-registered GmbH, not an NGO—keeps surfacing in Benko’s shadow structures. WEC’s leaders, Thomas Limberger and Robert Schimanko, joined Benko-related foundations in November 2024, just as assets were allegedly shuffled and gold liquidations occurred. With ex-Chancellors Alfred Gusenbauer and Sebastian Kurz orbiting the Signa complex for years—and with documented German political touchpoints—Austria’s justice system still seems curiously reluctant to probe the political facilitation layer that made Signa’s rise possible. Key Points Court phase begins: Indictment filed by WKStA and accepted; trial set for 14–15 Oct 2025 (LG Innsbruck). Charge: betrügerische Krida involving ~€660k (villa prepayment + family gift) (Sources: justiz.gv.at,Die Presse,Tiroler Tageszeitung Online). Remand continues: Benko has been in U-Haft since 23 Jan 2025; detention repeatedly extended on risk-of-reoffense grounds (Sources: MeinBezirk.at,Krone) WEC is a Vienna company: WEC World Economic Council GmbH, FN 591313 d, Tuchlauben 7A, 1010 Vienna—a private limited company, not a public NGO (Sources: wec.globa,lFirmenABC). Foundation switch-ins (Nov 2024): Schimanko into INGBE (Liechtenstein), Limberger onto the Laura Privatstiftung board. ORF/Krone/News confirm (Sources: news.ORF.at,Krone,News.at) Auctions & asset trails: Insolvency auctions sold Benko luxury assets; reporting places Schimanko and Benko pilot Jauschnegg as buyers in 2024; investigators flagged attempted repurchases via proxies (Sources: News.at,Die Presse,profil.at). Gold moves: INGBE reportedly sold 360 kg gold (€30m) on 11 Mar 2025 during Benko’s detention, triggering red flags (Sources: News.at). Political facilitation layer: Gusenbauer (ex-chancellor) long served atop Signa boards; Kurz reportedly retained by Signa; German political interactions are documented in Bundestag papers and press (Sources: SWI swissinfo.ch,News.at,dserver.bundestag.de). Disclaimer: Unschuldsvermutung/Presumption of innocence applies to all named individuals. Short Narrative With the indictment now final and dates fixed in Innsbruck, the Benko case is leaving the rumor mill and entering court. Yet the network story remains oddly under-lit. At its center is the WEC, a private GmbH in Vienna—not a civic NGO—fronted by Limberger and Schimanko. In November 2024, Schimanko joined the INGBE foundation in Liechtenstein while Limberger entered the Laura Privatstiftung—a notable timing coincidence given auction repurchases of personal effects and gold liquidations soon discussed by investigators and media. Meanwhile, prosecution focuses on discrete insolvency facts (~€660k), but not yet on whether political facilitators greased Signa’s trajectory (Sources: news.ORF.at+1,wec.global,Krone,News.at+1). Extended Analysis 1) The Case Moves: Indictment → Trial Charge: Betrügerische Krida tied to a €360k villa prepayment and a €300k gift to relatives, allegedly worsening creditor outcomes pre-insolvency. Trial: 14–15 Oct 2025, LG Innsbruck. Penalty range: 1–10 years (Sources: justiz.gv.at,Die Presse,Tiroler Tageszeitung Online). Status of Detention: U-Haft renewed multiple times; courts cite Tatbegehungsgefahr (Sources: MeinBezirk.at,Krone). 2) The WEC Vector: Company, Not Council WEC World Economic Council GmbH is registered in Vienna (FN 591313 d). This matters: as a private company, governance, financing, and lobbying transparency differ markedly from an NGO. Leadership includes Limberger and Schimanko (Sources: wec.global,FirmenABC). Learn more about the asset whisperer Robert Schimanko here. 3) Foundations, Auctions, and Gold Board switches (Nov 2024): Schimanko → INGBE (Liechtenstein); Limberger → Laura Privatstiftung (Innsbruck). These moves preceded/overlapped insolvency auctions and reported asset repurchases via intermediaries—Jauschnegg and Schimanko appear in investigative accounts (Sources: news.ORF.at,Krone,News.at). Gold flows: Investigative reporting cites INGBE selling 360 kg gold (€30m) on 11 Mar 2025 while Benko sat in remand—consistent with earlier revelations of large gold holdings across Liechtenstein banks. This timing and jurisdiction complicate recovery efforts and raise money-laundering red-flag questions (Sources: News.at,Süddeutsche.de,Krone). 4) The Political Layer—Still Under-Probed Austria: Gusenbauer chaired key Signa boards; Kurz was reportedly retained by Signa from 2023. The structural question: did political gravitas shield decision-making and financing flows? SWI swissinfo.chNews.at Germany: Bundestag documents map political contacts around Signa/Kaufhaus policy and support. Even where the government downplays direct ties post-2023, the parliamentary record shows the topic’s salience and the request for transparency—including references to Gusenbauer/Kurz as lobbyists. Deutscher Bundestagdserver.bundestag.de 5) Hypothesis (Provocative, Investigative) We hypothesize that limited scrutiny of WEC–foundation–auction linkages owes partly to proximity between Robert Schimanko and Alfred Gusenbauer (former Signa supervisory board chair). The sequence—board entries (Nov 2024), asset repurchases, gold liquidation (Mar 2025), and political sensitivities—suggests coordination risk rather than coincidence. This does not assert guilt, but it does justify aggressive subpoenas, MLA requests to Liechtenstein, and expanded predicate-offense inquiry into asset shielding and influence-peddling (Sources: news.ORF.at,Krone,News.at+1). Actionable Insight (for regulators & creditors) Subpoena trail: Demand full board minutes & resolutions for Laura PS and INGBE from Nov 2024–Mar 2025; correlate with auction invoices, pickup logs, payment rails, and gold trade confirmations (deal tickets, bank SWIFTs) (Sources: news.ORF.at,News.at+1). WEC transparency test: Treat WEC GmbH as a corporate actor; compel beneficial-owner & financing disclosures; map overlaps with SilverArrow and other vehicles. Political-risk audit: Revisit decision points where Austrian and German political contacts influenced financing, bailouts, or regulatory forbearance; align with Bundestag records and Austrian U-Ausschuss materials (Sources: dserver.bundestag.de,Reuters). Call for Information (Whistleblowers & Insiders) Were you involved with WEC, SilverArrow, Laura Privatstiftung, INGBE, or Signa asset sales (auctions/gold) from Nov 2024–Mar 2025? Do you hold emails, term sheets, consignment lists, vault instructions, DHL/armored-car waybills, or chat logs referencing Limberger, Schimanko, Gusenbauer, or Kurz? Contact FinTelegram/Whistle42 securely. (Unschuldsvermutung gilt.) Share Information via Whistle42