BREAKING: Attacking Football Website Obliterated After Rainbet Exposé In a shocking escalation of corporate retaliation, the independent football journalism website Attacking Football has been completely taken offline by what its founder, Paddy Keogh, describes on X as an “extremely severe Distributed Denial-of-Service (DDoS) attack” following the publication of a damaging exposé on offshore gambling operator Rainbet. The coordinated cyber assault, which Paddy (@PaddyKeoghAF) reports has “taken down a whole CDN,” represents one of the most brazen attacks on press freedom in the sports journalism sector—and all evidence points directly to Rainbet as the perpetrator. The Timeline of Digital Destruction September 25, 2025: Attacking Football publishes explosive investigation titled “Rainbet Exposed: The Most Dangerous Bookie On Football Twitter“—a comprehensive takedown of Rainbet‘s illegal marketing schemes and regulatory violations. September 29, 2025: Massive DDoS attack begins, flooding Attacking Football‘s servers with fake page requests designed to crash the infrastructure. Current Status: Website www.attackingfootball.com remains completely inaccessible, with the attack so severe it has compromised an entire Content Delivery Network (CDN). What Rainbet Desperately Wanted Buried Attacking Football‘s investigation—now conveniently silenced—exposed damaging evidence of Rainbet‘s systematic violations: Fabricated Promotional Content Network The report revealed Rainbet‘s industrial-scale deception operation, coordinating fake betting slip campaigns across social media platforms to create the illusion of massive wins and lure unsuspecting bettors. Illegal Targeting of Restricted Markets Despite explicit terms prohibiting operations in the UK, Germany, and other regulated jurisdictions, Rainbet actively markets to players in these territories without proper licensing—a clear violation of gambling laws. Zero Consumer Protection The investigation highlighted Rainbet‘s complete absence of player protection mechanisms, segregated funds, or dispute resolution systems—leaving players completely vulnerable to arbitrary account freezing and fund confiscation. The Anatomy of Corporate Cyber Terrorism Industry experts confirm the attack’s sophisticated nature suggests significant financial resources and technical expertise—exactly what an offshore gambling empire like Rainbet possesses. The attack methodology mirrors tactics used against major gambling operators: Volumetric Assault: Overwhelming servers with massive traffic volumes CDN Compromise: Targeting content delivery networks to maximize damage Infrastructure Disruption: Designed to cause maximum downtime and financial damage This represents a chilling escalation from typical DDoS attacks, which often target gambling sites for extortion purposes. Instead, Rainbet appears to have weaponized these same techniques against journalism that threatens their illegal operations. Pattern of Gambling Industry Intimidation Rainbet’s alleged cyber attack follows a documented pattern of gambling operators using extreme measures to silence criticism: Historical Precedents PaddyPower.com suffered similar DDoS attacks as part of extortion attempts against betting agencies Italian gambling sites have been compromised and their infrastructure weaponized for attacks on competitors Major gambling platforms routinely face cyber warfare during high-stakes periods The Rainbet Difference Unlike typical extortion-motivated attacks, this assault targets independent journalism—representing a dangerous escalation in corporate intimidation tactics. Technical Analysis: Industrial-Scale Cyber Warfare The scale of destruction suggests Rainbet deployed resources typically reserved for nation-state actors: CDN-Level Compromise: Taking down an entire Content Delivery Network requires massive botnet resources and sophisticated attack coordination. Sustained Assault: Multi-day attack duration indicates significant financial investment in maintaining the offensive. Precision Targeting: The timing—immediately following Rainbet’s exposé—eliminates any possibility of coincidental attack motivation. Rainbet’s Digital Footprint of Deception The cyber attack represents just the latest escalation in Rainbet’s war against accountability: Previously Documented Violations Discord-coordinated influencer schemes paying $50 per fabricated betting slip post Systematic acceptance of self-excluded UK gamblers violating GAMSTOP regulations Operations in restricted jurisdictions without proper licensing Zero consumer protection mechanisms leaving players vulnerable to fund theft Corporate Structure Designed for Evasion Operating through RBGAMING N.V. in Curaçao with an Anjouan license, Rainbet’s shell company structure facilitates both regulatory evasion and retaliatory attacks while obscuring accountability. Read our Rainbet Compliance Analysis here The Chilling Effect on Press Freedom Paddy Keogh‘s courageous investigation—now silenced by corporate cyber warfare—exposed the dangerous intersection of offshore gambling, social media manipulation, and regulatory capture. Attacking Football’s Editorial Standards: Unlike competitors, the site explicitly refuses gambling sponsorships, maintaining editorial independence that has threatened Rainbet’s misinformation campaigns [attached_file:1]. Global Contributor Network: The attack affects over 100 contributors and writers who used Attacking Football as a platform for launching professional journalism careers[attached_file:1]. Law Enforcement Must Act NOW This cyber assault constitutes clear criminal activity under multiple jurisdictions: UK Computer Misuse Act DDoS attacks targeting UK-based journalism represent serious criminal offenses carrying significant penalties. International Cybercrime Laws Cross-border attacks on press freedom trigger multinational law enforcement cooperation mechanisms. Gambling Regulatory Violations The attack compounds Rainbet’s existing violations, warranting immediate license revocation and criminal investigation. Call to Action: Expose Rainbet’s Criminal Network FinTelegram’s Whistle42 platform urgently seeks insider information to expose the full scope of Rainbet’s criminal operations: Critical Intelligence Needed Technical details of the DDoS attack infrastructure and funding Internal communications regarding the decision to target Attacking Football Corporate structure documentation revealing true beneficial ownership Payment processing relationships enabling illegal operations in restricted markets Additional retaliation evidence against other critics or competitors Protection Guaranteed Whistle42 provides: Military-grade encryption for all communications Legal privilege protection through qualified counsel Anonymous submission systems with no identity tracking Financial compensation for verified intelligence International witness protection coordination where necessary Corporate Terrorism Cannot Stand Rainbet’s cyber attack on Attacking Football represents a watershed moment in corporate accountability. If offshore gambling operators can silence journalism through cyber warfare with impunity, no independent media outlet investigating financial crime will be safe. The message is clear: Expose Rainbet‘s crimes, face digital destruction. But Rainbet made one critical mistake—their attack has only amplified global attention on their illegal operations while providing clear evidence of criminal intent to silence critics. URGENT: Contact Whistle42 NOW Insiders with information about Rainbet’s cyber attack, illegal marketing schemes, or corporate structure must act immediately. Rainbet’s cyber terrorism has crossed a line. Help us expose the full extent of their criminal empire before they strike again. Your information could be the key to bringing down one of the most dangerous offshore gambling operations targeting vulnerable players worldwide. Share Information via Whistle42 The fight for press freedom and consumer protection starts NOW.

Executive Summary Rainbet represents a sophisticated offshore gambling operation that epitomizes the worst aspects of unregulated cryptocurrency casinos. Operating through a complex web of shell companies and utilizing regulatory arbitrage between Curaçao and Anjouan jurisdictions, Rainbet has built a global gambling empire while systematically violating consumer protection laws, exploiting vulnerable players, and conducting illegal marketing activities across restricted jurisdictions. This comprehensive investigation reveals how Rainbet employs fabricated promotional content, accepts self-excluded gamblers, operates without proper licensing in major markets, and maintains a deliberately opaque corporate structure designed to evade accountability. The platform’s aggressive expansion strategy relies on paid influencer schemes that violate advertising regulations in multiple jurisdictions while targeting jurisdictions where it lacks legal authorization to operate. Company Introduction and Corporate Structure Founding and Development Rainbet was established in 2023 as a cryptocurrency-focused gambling platform, though some sources suggest operational activities dating back to 2017. The platform emerged during a period of rapid expansion in the offshore crypto gambling sector, positioning itself as a “modern” alternative to traditional online casinos through its emphasis on cryptocurrency transactions and minimal regulatory compliance. Legal Entity Structure Primary Operating Entity: RBGAMING N.V. – Incorporated in Curaçao (Registration Number: 163051) Registered Address: Zuikertuintjeweg (Zuikertuin Tower), Willemstad, Curaçao Operational License: Anjouan Internet Gaming License (#001-2023-AJG) This dual-jurisdiction structure exemplifies the regulatory arbitrage strategies employed by offshore operators: Curaçao incorporation provides perceived legitimacy and European banking access Anjouan licensing offers minimal regulatory oversight and consumer protection requirements Beneficial Ownership and Key Personnel Rainbet’s ownership structure remains deliberately opaque, consistent with offshore gambling operations designed to evade regulatory scrutiny and accountability. Claimed Leadership: John Evans – Listed as CEO and Co-Founder, but most likely a fake character Sean R. – Chief Marketing Officer Guilherme Fideles – Chief Operations Officer Analysis of Leadership Claims: John Evans: Multiple LinkedIn profiles exist for individuals named “John Evans,” but none show verifiable connections to Rainbet or gambling industry experience. The individual listed as Rainbet’s CEO has no documented history in gambling, gaming, or related industries, suggesting either a constructed persona or nominee arrangement. Sean R.: No verifiable information exists for this individual beyond Rainbet’s own promotional materials, indicating likely pseudonymous representation. Guilherme Fideles: The only figure with documented industry history, but exclusively in legally problematic operations: BoglaGold (shut down 2019 after legal action from RuneScape developer Jagex) MaisBet (short-lived, no current online presence) MMO Games LP (officially dissolved 2020) Tokenbets (grey-market operation) This pattern of defunct and legally questionable ventures suggests systematic involvement in regulatory evasion rather than legitimate business development. Regulatory Status and Legal Issues Licensing Inconsistencies Rainbet operates under multiple conflicting regulatory claims: Anjouan License (#001-2023-AJG): Issued by Union of the Comoros (tiny island nation) Minimal consumer protection requirements No meaningful dispute resolution mechanisms No segregated player fund requirements Curaçao Registration (RBGAMING N.V.): Corporate registration only, not operational gambling license Used primarily for banking and payment processing access Subject to upcoming regulatory reforms eliminating sublicense arrangements Jurisdictional Violations Restricted Jurisdictions per Terms of Service: United Kingdom Germany France Spain Austria Ireland United States Documented Violations:Despite explicit restrictions, FinTelegram’s investigation confirmed successful player registration and deposit capabilities from: Austria – Full registration and deposit capability via multiple payment methods Italy – Complete platform access without IP blocking or verification requirements United Kingdom – Registration possible with UK addresses, contradicting UKGC requirements Payment Processing Evidence: Credit/debit card deposits via MoonPay integration Direct bank transfers through Interac (Canada) and Pix (Brazil) Gift card purchases via Kinguin.net with promotional codes No jurisdiction-based payment restrictions implemented UK Self-Exclusion Violations GAMSTOP Requirements:Under UK Gambling Commission regulations, all licensed operators must: Participate in GAMSTOP multi-operator self-exclusion scheme Update exclusion lists every 24 hours Prevent self-excluded players from accessing gambling services Refund deposits from self-excluded players Rainbet’s Non-Compliance:Whistleblower evidence confirms Rainbet: Accepts deposits from GAMSTOP-registered self-excluded players Does not verify UK self-exclusion status during registration Refuses refunds to self-excluded players who deposit funds Continues marketing to individuals who have requested exclusion Legal Framework Violations:This constitutes systematic violation of: Gambling Act 2005 (UK) Consumer Rights Act 2015 (UK) UKGC Licence Conditions and Codes of Practice Network Analysis and Connections Potential 1xBet Connections While direct ownership links remain unverified, several operational similarities suggest possible connections to the 1xBet network: Operational Patterns: Identical licensing jurisdictions (Curaçao/Anjouan combination) Similar payment processing infrastructure Comparable restricted jurisdiction targeting Parallel affiliate marketing structures Technical Infrastructure: Similar platform architecture and user interface design Shared payment gateway integrations Comparable cryptocurrency processing systems Marketing Methodologies: Influencer-based promotional schemes Social media manipulation tactics Fabricated promotional content distribution Stake.com Network Analysis No Direct Connections Identified:Unlike 1xBet, no evidence suggests operational connections between Rainbet and Stake.com: Stake Ownership: Ed Craven and Bijan Tehrani (verified Australian entrepreneurs) Corporate Structure: Medium Rare N.V. (legitimate Curaçao operation) Operational Standards: Higher compliance standards and industry recognition White Label and Affiliate Networks Affiliate Program Structure: Commission rates up to 40% of player losses Weekly automated payments in 200+ currencies Personal account managers for high-volume affiliates Minimal compliance verification requirements Technical Service Providers: Multiple unnamed white-label technical providers Shared infrastructure with other offshore operators Content creation networks in Eastern Europe Payment Facilitators and Financial Infrastructure Primary Payment Processors MoonPay Integration: Direct platform integration for fiat-to-crypto conversion Supports Visa, Mastercard, Google Pay, Apple Pay Enables deposits in restricted jurisdictions No enhanced due diligence for high-risk transactions Regional Banking Partners: Interac (Canada) – Direct banking integration Pix (Brazil) – Instant payment system access Various European banks – Undisclosed processing relationships Direct Crypto With the Deposit from Wallet feature, you can deposit funds into your wallet on one of the many crypto exchanges, such as Binance or Coinbase, or connect your MetaMask, TrustWallet, or numerous other wallets directly to Rainbet and transfer crypto directly to your Rainbet account. All without KYC, of course.. Gift Card and Alternative Payment Systems Kinguin.net Partnership: Rainbet gift cards available with promotional discounts $100, $150, $500 denominations available Promotional codes: “MAJOR24” (8% discount) Enables payment system circumvention in restricted markets Illegal Marketing Activities Fabricated Promotional Content Scheme Whistleblower Intelligence:FinTelegram has received verified information from multiple sources confirming Rainbet’s systematic use of fabricated promotional content distributed through paid influencer networks. Operational Structure: Coordination Platform: Discord server with restricted access Payment Structure: $50 per post for smaller accounts (<20k followers) Content Distribution: Pre-made fabricated betting slips showing large wins Account Requirements: Addition of “@Rainbet” to influencer bio for authenticity appearance Payment and Incentive System: Monthly Income Potential: Up to $1,500 for regular participants Payment Method: Direct credit to Rainbet account Content Requirements: Posting fabricated betting slips as personal wins Frequency Expectations: Daily or weekly posting schedules Regulatory Violations:This scheme violates multiple advertising regulations: ASA Rules (UK): All paid promotions must be disclosed as advertisements EU UCPD: Hidden marketing practices are prohibited FTC Rules (US): Paid endorsements must be “clear and conspicuous” Social Media Platform Policies: Undisclosed commercial relationships violate terms of service Contact Methods for Influencer Recruitment Primary Channels: Telegram: @rainbetshin Discord: rainbetshin Email: sarah@rainbet.com Target Demographics: Football-focused social media accounts Gaming and cryptocurrency influencers Accounts with 10,000+ followers Content creators in restricted jurisdictions Scale and Impact Content Volume:Based on industry analysis and social media monitoring: 100+ active paid influencers 500+ fabricated promotional posts monthly 50 million+ combined reach across platforms Targeting primarily UK, German, and Australian audiences Consumer Protection Failures Self-Exclusion Policy Violations Documented Issues: Immediate Re-access: Self-excluded players report immediate platform access without cooling-off periods No Verification Systems: Platform lacks integration with national self-exclusion databases Refund Denials: Systematic refusal to refund deposits from self-excluded players Continued Marketing: Promotional communications continue to self-excluded individuals Victim Testimonials: Player reported immediate re-access after self-exclusion request Multiple attempts to contact management regarding gambling addiction ignored Psychological manipulation through timed bonus offerings Debt accumulation through high-interest loan encouragement Player Fund Protection No Segregated Accounts:Unlike regulated operators, Rainbet does not maintain segregated player funds, meaning: Player deposits mix with operational funds No protection in case of operator insolvency No independent auditing of fund security No compensation scheme for player losses due to operator failure Withdrawal Issues: Arbitrary account freezing without explanation Voided winnings based on retroactive terms interpretation Extended processing delays exceeding stated timeframes Demand for excessive documentation for cryptocurrency withdrawals Regulatory Evasion Mechanisms IP Geolocation Circumvention Technical Implementation: No effective IP blocking for restricted jurisdictions VPN usage implicitly encouraged through platform design Country selection dropdowns include restricted territories No secondary verification of player location Payment Processing Workarounds Multi-Jurisdiction Strategy: Primary processing through Curaçao registration Secondary processing via Brazilian and Canadian entities Cryptocurrency processing to bypass traditional banking restrictions Gift card systems for additional payment circumvention Corporate Structure Obfuscation Nominee Arrangements: Use of nominee directors and shareholders Corporate service provider registration in secrecy-friendly jurisdictions Beneficial ownership information not publicly disclosed Multiple layers of corporate entities across jurisdictions FinTelegram Testing and Investigation Results Registration Testing Across Restricted Jurisdictions Austria Testing: Status: SUCCESSFUL registration and deposit Payment Methods: Credit card via MoonPay, cryptocurrency direct Verification Requirements: Email only, no KYC documentation required IP Blocking: None implemented Italy Testing: Status: SUCCESSFUL registration and deposit Payment Methods: Full payment option availability Jurisdiction Detection: No location-based restrictions applied Terms Compliance: Platform acceptance despite terms prohibiting Italian players United Kingdom Testing: Status: SUCCESSFUL registration and deposit Payment Methods: MoonPay integration functional GAMSTOP Integration: No verification against self-exclusion database Regulatory Compliance: Complete violation of UKGC requirements Payment Processing Verification MoonPay Integration: Direct platform integration bypasses traditional merchant restrictions No enhanced due diligence for high-risk jurisdictions Supports all major payment methods in restricted markets Cryptocurrency Deposits: No source of funds verification Mixing services and privacy coins accepted No AML compliance screening for high-value transactions Gift Card Testing: Kinguin.net gift cards successfully purchased and redeemed Promotional discount codes functional No purchase location restrictions implemented Industry Context and Comparative Analysis Comparison with Regulated Operators FeatureUKGC/MGA Licensed OperatorRainbet (Anjouan License)Player Fund Protection Segregated accounts required No segregation requirementsSelf-Exclusion Enforcement GAMSTOP integration mandatory Player liability for relapsesDispute Resolution Independent ADR required No independent resolutionOwnership Transparency Public beneficial ownership Hidden behind nominee structuresAdvertising Compliance Strict disclosure requirements Fabricated undisclosed contentAudit Requirements Regular independent audits No audit requirementsConsumer Compensation Compensation schemes exist No compensation mechanisms Market Position Analysis Revenue Estimation:Based on industry analysis and observable activity: Estimated annual revenue: $200-500 million Active player base: 500,000-1,000,000 users Geographic concentration: UK (30%), Germany (25%), Australia (20%) Average player value: $400-800 annually Growth Strategy: Aggressive influencer marketing in restricted jurisdictions Cryptocurrency-first approach to bypass banking restrictions Minimal compliance costs through regulatory arbitrage High-risk, high-reward player acquisition model Conclusion and Risk Assessment Systematic Regulatory Violations Rainbet operates as a paradigmatic example of offshore gambling regulatory evasion, systematically violating: Consumer protection regulations across multiple jurisdictions Advertising and marketing laws in target markets Self-exclusion and responsible gambling requirements Anti-money laundering and know-your-customer obligations Consumer Risk Profile High-Risk Factors: No Player Fund Protection: Deposits not segregated from operational funds Arbitrary Terms Enforcement: Retroactive application of terms to void winnings No Meaningful Dispute Resolution: Offshore licensing provides no recourse Exploitation of Vulnerable Players: Systematic acceptance of self-excluded individuals Regulatory Risk: Platform operates illegally in major jurisdictions Player accounts subject to freezing without notice Winnings can be voided based on retroactive jurisdictional claims No compensation mechanisms for operator failure Industry Impact Rainbet represents the systemic failures in international gambling regulation: Regulatory Arbitrage: Exploitation of jurisdictional inconsistencies Payment System Circumvention: Cryptocurrency and alternative payment abuse Social Media Manipulation: Undisclosed advertising violating platform policies Consumer Harm: Systematic exploitation of gambling addiction vulnerabilities Key Data Summary CategoryDetailsCompany NameRainbet (operated by RBGAMING N.V.)RegistrationCuraçao (Registration #163051)LicenseAnjouan Internet Gaming License (#001-2023-AJG)Claimed CEOJohn Evans (unverified identity)Operational Since2023 (some sources suggest 2017)Restricted JurisdictionsUK, Germany, France, Spain, Austria, Ireland, USAActual Operation StatusActive in all restricted jurisdictions without IP blockingPayment ProcessorsMoonPay, Interac, Pix, Kinguin.net gift cardsCryptocurrency Support20+ digital assets including BTC, ETH, USDT, SOLSelf-Exclusion Compliance Accepts self-excluded players, no GAMSTOP integrationPlayer Fund Protection No segregated accounts or protection schemesDispute Resolution No independent dispute resolution mechanismMarketing Violations Confirmed fabricated promotional content via DiscordInfluencer Payment$50 per post, up to $1,500 monthly for participantsRisk LevelEXTREMELY HIGH Call for Information FinTelegram seeks additional information from industry insiders, current and former employees, affiliates, and affected players regarding: Corporate Intelligence Beneficial Ownership Details – True ownership structure behind nominee arrangements Technical Infrastructure – White-label providers, software vendors, and operational partners Financial Flow Analysis – Payment processing relationships and fund movement patterns Regulatory Communications – Internal communications regarding compliance and legal issues Operational Intelligence Influencer Network Documentation – Discord server access, payment records, content distribution systems Player Exploitation Evidence – Documentation of self-excluded player acceptance and related communications Jurisdictional Violations – Evidence of active marketing and operations in restricted territories Internal Compliance Procedures – Documentation of internal compliance policies and their enforcement Financial Crime Intelligence Money Laundering Mechanisms – Methods for processing high-risk transactions and source of funds verification Corporate Structure Changes – Documentation of corporate restructuring and ownership transfers Regulatory Evasion Strategies – Internal strategies for avoiding regulatory oversight and enforcement Player Protection Violations Self-Exclusion System Failures – Technical documentation of self-exclusion system inadequacies Vulnerable Player Targeting – Evidence of marketing to individuals with gambling problems Fund Confiscation Cases – Documentation of arbitrary account freezing and fund confiscation Secure Communication Channels: Encrypted Email: Secure communication protocols available upon request Anonymous Submission: Document drop systems with source protection Legal Protection: Whistleblower protection program coordination Financial Compensation: Legitimate information compensation available Protection Guarantees: Source identity protection through legal privilege Secure document handling with encryption Anonymous publication options Legal support coordination where applicable Your information could be instrumental in exposing the full scope of this offshore gambling operation and protecting consumers from continued exploitation and financial harm. Contact FinTelegram through our secure channels for confidential communication protocols and source protection procedures. Share Information via Whistle42

Dubbed “The Wagner Group of Sports Betting” by gambling industry experts, 1xBet represents the most sophisticated criminal gambling operation in modern history. This Russian-owned betting empire, founded by three fugitives subject to international arrest warrants, has transformed from a regional illegal operation into a global criminal enterprise generating an estimated $2 billion annually while exploiting children, fabricating sporting events, and laundering money through some of the world’s most prestigious football clubs. Ownership and Criminal Charges: 1xBet is controlled by three Russian nationals—Roman Semiokhin, Dmitry Kazorin, and Sergey Karshkov—who face international arrest warrants issued by Russian prosecutors in 2020 for operating illegal gambling operations. Allegedly, in 2021 that the company made more than 63 billion rubles (US$655 million) in illegal gambling activities. Founding and Corporate Structure 1xBet was founded in 2007 in Bryansk, Russia, by the three Russian nationals who would later become the subject of international criminal investigations. The company operates through a complex web of corporate entities designed to obscure ownership and evade regulatory oversight: Primary Operating Entities: 1X Corp N.V. (Curaçao) – Primary international licensee holding Curaçao eGaming License Cyprus “Headquarters” (Limassol) – Public-facing operational base providing EU legitimacy Exinvest Limited (Cyprus) – Operational entity linked to payment processing Bookmaker Pub LLC (Russia) – Domestic Russian operation trading as “1xStavka” Multiple subsidiary companies across various jurisdictions The company’s franchise business model allows it to operate through local partners while maintaining centralized control, creating layers of legal protection and regulatory evasion opportunities. Founders, Primary Owners, and Key Individuals Sergey Karshkov – Co-founder and current CEO Former cyber intelligence officer Acquired Cypriot citizenship through “Golden Passport” program Subject to international arrest warrant issued by Russian prosecutors Roman Semiokhin – Co-founder Co-developed initial business concept in Bryansk Subject to international arrest warrant Dmitry Kazorin – Co-founder and alleged primary owner Key figure in corporate structure development Subject to international arrest warrant Reportedly died in Switzerland in 2023 Evgeniy Kiriushin – Senior operational executiveAlexandr Tikhonov – Senior operational executive These individuals maintain operational control through the complex corporate structure while avoiding direct legal liability through jurisdictional arbitrage. Financial Crime and Money Laundering: India’s Enforcement Directorate is currently investigating 1xBet for alleged money laundering, tax evasion, and fraud involving “crores of rupees”. The investigation has expanded to question numerous Indian celebrities, including cricketers Yuvraj Singh, Suresh Raina, and Shikhar Dhawan, about their promotional activities for the platform. Gambling Farms & Fraudulent Sports Operations: Perhaps most shocking is how 1xBet has weaponized football’s global prestige to legitimize its criminal operations. Despite international arrest warrants for its founders, ongoing money laundering investigations, and documented exploitation of children, elite clubs like FC Barcelona and Paris Saint-Germain maintain lucrative sponsorship deals worth an estimated €15 million annually. The company’s spokesperson, “Alex Sommers,” was revealed to be entirely fictional—his photograph stolen from a CNN journalist—yet these partnerships continue unabated. In 2024, Bellingcat (link) and Josimar (link) investigations revealed that 1xBet operates a massive network of fake sporting events, streaming up to 1,200 fabricated matches daily featuring fictitious teams with names resembling real clubs like “Arsenal,” “Real Madrid,” and “Barcelona”. These operations involve children as young as 14 and are filmed in Russia, Ukraine, and Belarus—countries where 1xBet is banned. The most disturbing revelation: children as young as 14 are being exploited in these gambling farms. In venues traced to a children’s football school in Bryansk—the same Russian city where 1xBet‘s founders began their criminal careers—investigators found minors unknowingly performing for global gambling audiences. The Russian football blogger Viktor Kravchenko said in a 2021 Instagram post that young footballers were recruited to play in shifts and claimed games were fixed. Some facilities partner with Putin’s United Russia Party and Gazprom, suggesting either remarkable indifference or outright complicity by Russian authorities. Global Regulatory Actions: 1xBet has been banned or restricted in numerous jurisdictions, including the US, UK, France, Spain, Germany, Russia, and Ukraine due to regulatory violations. Ukraine recently confiscated nearly UAH 2 billion from 1xBet-related companies and revoked all licenses due to Russian connections. Bankruptcy and Unpaid Winnings: 1XCorp, 1xBet‘s holding company in Curacao, was declared bankrupt by a Dutch Supreme Court in January 2023 for failing to pay customer winnings totaling approximately 830,000 euros. Payment Facilitators and Financial Network Despite extensive regulatory restrictions, 1xBet maintains operations through a sophisticated network of payment facilitators and financial service providers. Primary Payment Processors Processing.com – Global merchant payment processing partner since 2017, providing: Multi-jurisdictional acquiring services Convergent acquiring to optimize approval ratios Single integration access to multiple acquirer networks Support during high-traffic events (FIFA World Cup referenced) Regional Payment Partners: MoonPay – Cryptocurrency conversion services Khalti (Nepal) – Digital wallet services (95% of transactions) IME Pay (Nepal) – Mobile money services Connect IPS (Nepal) – Interbank payment system Nagad (Bangladesh) – Mobile financial services bKash, Rocket (Bangladesh) – Mobile banking Banking Relationships Documented Banking Partners: NIC Asia Bank (Nepal) – Direct banking services Sterling Bank, FCMB, Zenith Bank, Access Bank, Providus Bank (Nigeria) – Internet banking Various regional banks across Africa, Asia, and South America Alleged Connections The Rainbet Connection Some insiders claim that the offshore casino Rainbet, for example, is also affiliated with 1XBet. While direct ownership connections are not explicitly documented in public records, several circumstantial factors raise questions: Similar Operational Patterns: Both platforms use identical licensing jurisdictions (Curacao/Anjouan), target similar restricted markets, employ crypto-focused payment systems, and maintain comparable affiliate marketing structures. Infrastructure Sharing: Some industry observers have noted similarities in platform architecture and operational methodologies, though specific technical connections require further investigation. Regulatory Scrutiny: The emergence of Rainbet coincides with increased regulatory pressure on 1xBet globally, potentially suggesting operational restructuring or brand diversification strategies commonly employed by offshore operators facing enforcement actions. Other Suspected Connected Brands Industry analysis suggests operational connections to: Melbet – Similar corporate structure and operational patterns 22bet – Shared technical infrastructure Betwinner – Common ownership indicators 1XBit – Cryptocurrency-focused variant Regulatory Risk Assessment Both platforms exhibit hallmarks of offshore operators that prioritize market access over regulatory compliance. The documented pattern of 1xBet‘s violations—including money laundering, fake sports operations, unpaid winnings, and celebrity endorsement schemes—establishes a concerning precedent for any potentially affiliated operations. The lack of transparent ownership disclosure for Rainbet, combined with its operational similarities to 1xBet, warrants heightened scrutiny from both regulators and potential users, particularly given the extensive financial crime allegations surrounding 1xBet‘s documented activities. Call for Information FinTelegram seeks additional information from industry insiders regarding: Payment Processing Relationships – Details on financial service providers facilitating 1xBet operations Corporate Structure – Information on beneficial ownership, subsidiary relationships, and shell company networks Regulatory Communications – Internal communications between 1xBet and regulatory authorities Sports Partnership Details – Contract terms, due diligence processes, and compliance protocols Technical Infrastructure – White label providers, software vendors, and operational partners Money Laundering Mechanisms – Specific methods for moving funds across jurisdictions Confidential submissions can be made through: Encrypted communications channels Anonymous document submission systems Intermediary legal counsel Whistleblower protection programs Your information could be instrumental in exposing the full scope of this criminal network and protecting consumers from continued fraud and exploitation. Contact FinTelegram for secure communication protocols and source protection procedures. Share Information via Whistle42

A consortium of nine major European banks has announced the formation of a groundbreaking initiative to launch a euro-denominated stablecoin compliant with the European Union’s Markets in Crypto-Assets (MiCA) regulation, marking a significant challenge to the US-dominated stablecoin market. The Banking Consortium The participating institutions include ING, UniCredit, Banca Sella, KBC, Danske Bank, DekaBank, SEB, CaixaBank, and Raiffeisen Bank International. These banks, spanning eight EU member states, have established a new company headquartered in the Netherlands to oversee the development and management of the stablecoin. Strategic Objectives The initiative aims to provide a genuine European alternative to US-dominated stablecoin markets, contributing to Europe’s strategic autonomy in digital payments. The stablecoin will enable near-instant, low-cost payments and settlements with 24/7 access to efficient cross-border transactions, programmable payments, and improvements in supply chain management. According to Floris Lugt, Digital Assets Lead at ING and joint public representative of the initiative, “Digital payments are key for new euro-denominated payments and financial market infrastructure. They offer significant efficiency and transparency, thanks to blockchain technology’s programmability features and 24/7 instant cross-currency settlement”. Regulatory Framework The stablecoin will operate under the EU’s Markets in Crypto-Assets Regulation (MiCA), which has been in force since June 30, 2024. Under MiCA, stablecoins are classified as either e-money tokens (EMTs) or asset-referenced tokens (ARTs), with strict requirements including EU licensing, fully backed reserves, and detailed whitepapers. The consortium’s new entity will seek licensing and supervision from the Dutch Central Bank as an e-money institution. MiCA regulations cap payment transactions at €200 million per day and require issuers to maintain rigorous compliance standards. Launch Timeline and Market Context The MiCA-compliant euro stablecoin is expected to launch in the second half of 2026. This timeline positions it as an interim solution, launching at least three years before the European Central Bank’s digital euro, which won’t debut before mid-2029. Currently, US stablecoins dominate the international market, comprising approximately 99% of the total $292 billion market capitalization, while euro-pegged stablecoins represent only around €500 million ($587 million). The European initiative seeks to capture a larger share of this rapidly growing market. Connection to Tether’s Market Leadership This European banking initiative comes as stablecoin market leader Tether pursues a massive capital raise that could value the company at $500 billion. According to recent reports, Tether is seeking to raise between $15-20 billion for approximately 3% of the company, with Cantor Fitzgerald acting as lead adviser. Read our $500B Tether report here. Tether‘s USDT commands a market capitalization of $172 billion, making it the largest stablecoin globally. The company reported $4.9 billion in net profit in the second quarter of 2025 alone, primarily through interest income on reserves backing its tokens. This financial strength demonstrates the lucrative potential of the stablecoin market that European banks are now entering. Future Implications The consortium remains open to additional banks joining the initiative, and individual member banks will provide value-added services such as stablecoin wallets and custody solutions. A CEO for the new company is expected to be appointed pending regulatory approval. This initiative represents more than technological innovation—it embodies Europe’s strategic effort to establish financial sovereignty in the digital asset space while competing with established US players in the rapidly expanding stablecoin ecosystem. Share Information via Whistle42

Tokyo-listed Metaplanet just bought 5,419 BTC (~$632.5M)—its biggest deal ever—vaulting to #5 among public Bitcoin treasuries and edging past Bullish. It’s a bold signal: corporate balance sheets are turning into Bitcoin trackers. But compared with Strategy (ex-MicroStrategy), Metaplanet is still playing in a lower weight class (Source: coindesk.com). Key Facts New buy: Metaplanet acquired 5,419 BTC (~$632.5M), announced Monday. Total now ~25,555 BTC. Overtakes Bullish. Top 5 public holders (BTC): Strategy ~639,835 Marathon Digital 52,477 XXI 43,514 Bitcoin Standard Treasury Co. 30,021 Metaplanet 25,555(6) Bullish 24,300 (Source: bitcointreasuries.net). Strategy context: Name changed from MicroStrategy in Aug 2025; remains the dominant “Bitcoin Treasury Company” (Source: Strategy) Short Analysis Metaplanet’s move is not a hedge—it’s a transformation. Crossing into the Top-5 signals a strategic shift from traditional cash management toward BTC-centric corporate identity. Passing Bullish matters symbolically; it shows a non-U.S. issuer can scale into the front pack despite liquidity and regulatory frictions. Hypothesis: The “Bitcoin Treasury” model is converging toward a new asset-manager hybrid: issuers will finance BTC accrual via equity/convertible cycles, target premium-to-NAV narratives, and court index inclusion—while outsourcing custody/liquidity to prime brokers and ETFs. Expect name-brand treasuries (Japan/EU) to follow Metaplanet with staged buys, while U.S. miners and SPAC roll-ups chase Top-10 slots with deal-driven BTC jumps. Regulatory heat will push clearer disclosure, NAV, and dilution rails—and separate disciplined treasuries from momentum-chasers (Source: barrons.com). But Strategy is still the Everest. With ~640k BTC, Strategy’s balance sheet remains a leveraged, quasi-ETF on Bitcoin. Metaplanet’s 25.6k BTC is impressive yet dwarfed—a fraction of Strategy’s war chest—highlighting how far others must go to rival Saylor’s playbook (Source: barrons.com). Call for Information Have internal insights on corporate Bitcoin purchases, financing terms, or custody/risk controls at Metaplanet, Strategy, or other Top-10 holders? Confidential tips via Whistle42.com (PGP welcomed). Share Information via Whistle42

Executive Summary Tether Holdings SA, the world’s largest stablecoin issuer, is pursuing an unprecedented $15-20 billion capital raise at a $500 billion valuation—positioning itself among the world’s most valuable private companies alongside OpenAI and SpaceX. This ambitious fundraising represents far more than corporate expansion; it signals the maturation of stablecoins from cryptocurrency infrastructure into mainstream financial pillars, with profound implications for monetary policy, banking competition, and the ongoing “stablecoin hype” that some analysts warn could represent bubble territory. Key Financial Metrics Summary MetricCurrent StatusIndustry ContextStrategic ImplicationsProposed Valuation$500 billionRivals OpenAI, SpaceX40x increase from 2024 Cantor dealFundraise Target$15-20 billion3% equity stakeNo secondary sales, pure growth capitalUSDT Market Cap$172 billion56% of stablecoin marketDominant market positionQ2 2025 Profit$4.9 billion99% profit marginsSuperior to major banksReserve Base$162.5 billionExceeds liabilities by $5.4BStrongest balance sheet in cryptoAdvisory FirmCantor FitzgeraldWall Street validationPolitical connections via Howard Lutnick Tether’s $500B Valuation: Stablecoin Market Context and Growth Projections The Strategic Context: Stablecoin Market Transformation Market Size and Growth Projections The stablecoin sector has experienced explosive growth, expanding from approximately $200 billion at the start of 2025 to $280 billion as of September. Citi has revised its 2030 forecasts upward to $1.9 trillion in the base case and $4 trillion in the bull scenario, reflecting blockchain’s “ChatGPT moment” for institutional adoption. This growth trajectory represents a fundamental shift in how digital assets integrate with traditional finance. As Citi analysts note, stablecoins could support $100-200 trillion in annual transactions by 2030, comparable to traditional payment rails. Competitive Landscape Analysis Tether’s dominance becomes stark when viewed against competitors: Tether (USDT): $172 billion market cap, 56% market share Circle (USDC): $74 billion market cap, 25% market share Other issuers: Remaining 19% fragmented across multiple players Circle’s public valuation of approximately $30 billion makes Tether’s $500 billion target particularly audacious—representing a 16.7x premium over its closest competitor. Traditional Banking Enters the Stablecoin Arena Major Bank Initiatives The traditional banking sector is rapidly mobilizing around stablecoins, signaling institutional validation of the asset class: US Banking Consortium: JPMorgan Chase, Bank of America, Citigroup, and Wells Fargo are in preliminary discussions to launch a joint stablecoin initiative, contingent on the GENIUS Act providing regulatory clarity. European Banking Alliance: A nine-bank consortium, including ING, UniCredit, Banco Santander, and CaixaBank announced plans for a euro-denominated stablecoin launch in H2 2026, targeting the underserved European market where euro stablecoins represent less than 1% of total stablecoin circulation. Individual Bank Strategies: JPMorgan: CEO Jamie Dimon confirmed plans to “be involved in stablecoins,” building on their existing JPM Coin infrastructure that processes $2 billion daily Citigroup: CEO Jane Fraser announced evaluation of a “Citi stablecoin” alongside tokenized deposit initiatives Banking Circle: Already issued EURI, a MiCA-compliant stablecoin for B2B payments The Banking Advantage Traditional banks entering stablecoin issuance possess several competitive advantages: Regulatory Infrastructure: Existing compliance frameworks and supervisory relationships Customer Relationships: Established corporate and institutional client bases Capital Resources: Access to traditional funding markets and Federal Reserve facilities Trust Factor: FDIC backing and century-old brand recognition However, banks also face constraints that crypto-native issuers like Tether avoid: Regulatory Restrictions: Limited ability to invest reserves in higher-yield assets Legacy Systems: Integration challenges with existing banking infrastructure Compliance Costs: Higher operational overhead from traditional banking regulations Macroeconomic Implications and Systemic Risks The Interest Rate Dependency Model Tether’s extraordinary profitability stems from a simple but powerful model: collecting customer dollars and investing them in US Treasury bills. With $162.5 billion in reserves earning approximately 4-5% annually, Tether generates $6.5-8.1 billion in annual interest income with minimal operational costs. This model’s sensitivity to interest rate cycles creates both opportunity and risk: Rising Rates: Enhanced profitability (current beneficiary of 4.75% Fed rates) Falling Rates: Compressed margins (risk if rates return to zero-bound) Yield Curve Inversion: Potential liquidity management challenges “Too Big to Fail” Implications At $500 billion valuation and $172 billion in circulation, Tether approaches systemically important financial institution (SIFI) status. The company now holds Treasury bills comparable to some sovereign wealth funds, creating unprecedented monetary policy implications: US Treasury Demand: Stablecoin growth generates automatic demand for short-term government debt Liquidity Risk: Mass redemptions could force Treasury sales, impacting government borrowing costs Dollarization Effects: USDT adoption abroad strengthens dollar dominance globally The Stablecoin Hype: Bubble or Breakthrough? Bubble Warning Signals Several factors suggest caution about stablecoin market valuations: Speculative Excess: Reddit analysis warns of a “stablecoin trap” where Treasury backing creates “self-reinforcing cycles” that could destabilize both crypto and sovereign debt markets. Valuation Disconnects: Tether’s proposed 68x price-to-earnings ratio, while justified by growth prospects, exceeds most technology companies. Regulatory Dependency: The entire sector’s growth narrative depends on favorable regulatory outcomes, particularly the GENIUS Act passage in the US. Fundamental Strengths Conversely, structural factors support continued stablecoin expansion: Real Utility: Unlike speculative cryptocurrencies, stablecoins solve actual payment and settlement problems. Institutional Adoption: McKinsey reports stablecoins are becoming “mainstream infrastructure priority” with 49% of financial institutions already using them. Regulatory Clarity: MiCA in Europe and pending US legislation provide frameworks for compliant growth. Strategic Implications of Tether’s Fundraising Capital Deployment Strategy CEO Paolo Ardoino outlined expansion plans beyond stablecoins into: Artificial Intelligence: Competing with OpenAI in AI infrastructure Commodity Trading: Leveraging reserve management expertise Energy Sector: Bitcoin mining and renewable energy projects Communications: Potential telecommunications infrastructure Media Operations: Content and platform investments This diversification strategy reduces dependence on stablecoin revenues while leveraging Tether’s massive cash position for growth investments. Geopolitical Positioning Tether‘s relocation to El Salvador and partnerships with crypto-friendly jurisdictions position the company as a global financial infrastructure provider independent of any single regulatory regime. This geographic arbitrage provides operational flexibility while maintaining US dollar backing. Most Likely Scenarios Successful Fundraising (Probability: Moderate-High) If Tether closes at or near the $500 billion valuation: Market Validation: Legitimizes stablecoins as permanent financial infrastructure Competitive Pressure: Forces traditional banks to accelerate stablecoin initiatives Regulatory Attention: Increases government focus on systemically important crypto firms Innovation Acceleration: Provides capital for expansion beyond payment rails Valuation Compression (Probability: Moderate) Market conditions or investor skepticism could reduce final valuation to $200-300 billion: Still Transformational: Even at lower valuations, represents massive crypto industry milestone Precedent Setting: Establishes stablecoin issuers as legitimate fintech giants Banking Competition: Traditional bank stablecoin initiatives gain relative attractiveness Deal Failure (Probability: Low) Regulatory concerns or market conditions could derail the fundraising: Sector Cooling: Would suggest stablecoin growth has peaked Banking Advantage: Traditional bank initiatives would gain competitive positioning Regulatory Uncertainty: Could delay broader institutional crypto adoption Conclusion and Market Outlook Tether’s $500 billion valuation bid represents a watershed moment for stablecoins and crypto integration with traditional finance. The proposed fundraising occurs at the intersection of favorable regulatory developments, institutional adoption acceleration, and growing recognition of stablecoins’ utility in global payments infrastructure. While bubble concerns merit attention—particularly given the sector’s rapid growth and regulatory dependencies—the fundamental utility of stablecoins in solving real payment problems suggests sustainable demand beyond speculative cycles. The success or failure of this fundraising will establish important precedents for crypto company valuations, regulatory approaches, and the competitive dynamics between crypto-native and traditional financial institutions in the evolving digital asset ecosystem. Call for Insider Information FinTelegram seeks confidential information regarding Tether’s fundraising activities and the broader stablecoin sector through our secure whistleblower platform Whistle42.com. Share Informatin via Whistle42

The Shock Move In a dramatic escalation of the Signa collapse fallout, the insolvency administrator of Signa Prime Selection AG (SPS) has filed a €62.2 million recovery claim against Swiss private bank Julius Bär. According to Austrian reporting with alleged insider access, the claim accuses the bank of facilitation of last‑minute intra‑group fund transfers that unfairly favored SPS over other creditors. The Grievance The core allegation: in late 2022, during what the administrator deems an already insolvent phase, SPS and affiliated Signa entities routed €60 million via Julius Bär to Signa Zürich — only to have the same funds immediately returned to SPS. A 2021 credit facility of €200 million from Julius Bär to Signa Zürich is under scrutiny: though SPS was only a guarantor, the claim asserts that Julius Bär directed the loaned funds directly into SPS. The complaint accuses Julius Bär of “turn‑the‑hole‑open, close‑the‑hole” tactics — i.e. an ongoing shuffle of liquidity timed around key dates — allegedly to show robust assets under management at year‑end. It is alleged that the bank was fully aware of the financial distress within Signa and should have exercised higher due diligence. Bank’s Response Julius Bär has publicly declared that it “strongly rejects” the claims, calling them groundless and unfounded. Why It Matters This is likely to become one of the highest-profile clawback litigation battles in Europe tied to the Untersstructur of major real‑estate empire failures. A successful recovery could shift losses away from unsecured creditors. The case may draw legal and regulatory scrutiny over banks’ roles in complex intercompany financing chains during distress. Julius Bär’s global reputation could suffer if courts find it complicit in “gaming” balance‐sheet optics. Outlook & Risks The court will examine whether the fund flows were bona fide or structured to advantage SPS. Julius Bär will fight back aggressively — expect discovery battles, arguments over scienter and fairness. Even if Julius Bär prevails legally, reputational damage and regulatory inquiries are likely. A ruling in favor of SPS could embolden other recovery actions in the tangled Signa collapse. Share Information If you have any information about the Rene Benko case and his collapsed Signa Group, please share it with us via our whistleblower platform Whistle42. Share Information via Whistle42

Barclays Bank has entered the green investment spotlight by signing its first major carbon dioxide removal (CDR) agreement with UNDO (website), a climate tech innovator specializing in enhanced rock weathering (ERW). This UK-led deal sees UNDO tasked with permanently removing 6,538 tonnes of CO₂ through its ERW process on 10,000 acres of farmland in Ontario, Canada, marking the largest ERW contract of its kind for a British supplier to date. Details of the Barclays-UNDO Partnership Under the agreement, UNDO, an XPRIZE-winning company, will spread finely crushed silicate rocks across Canadian farmland, accelerating natural chemical weathering to capture and store atmospheric CO₂. The project features an innovative pre-financing structure and is part of Barclays’ multi-year net-zero plan targeting its most emission-intensive operations. Barclays has already slashed its Scope 1 and 2 emissions by 95% and is now augmenting its decarbonization strategy with high-integrity, permanent carbon removal. UNDO’s ERW technology not only addresses climate change but also delivers measurable benefits for soil health and crop yields, supporting agrarian communities while scaling up its global environmental impact. Context: Green Investment Trends in 2025 The Barclays-UNDO deal comes at a time when the green economy commands a global market capitalization of $7.9 trillion, accounting for 8.6% of listed equity markets as of Q1 2025. Institutional interest in durable carbon removal is intensifying, driven by long-term net-zero commitments, regulatory developments, and the pressing need for scalable climate solutions. Banks and asset managers are increasingly channeling capital into clean technologies, nature-based solutions, and innovative financial structures, with annual global investments in climate action projected to reach up to $275 trillion by 2050. Sector Implications This partnership signals the mainstreaming of permanent CDR within financial strategies and underscores the evolving role of banks in shaping the carbon market. Such landmark agreements not only help corporates achieve residual emissions targets but also catalyze the scale-up of promising green technologies, positioning the finance sector as a proactive force in climate transition. Share Information via Whistle42

FinTelegram is proud to present the latest installment in our Crypto Payment Processor Watch series with an in-depth analysis of PayOp and PayDo—two payment processors operating at the epicenter of the high-risk, high-revenue gambling sector. Read the PayOp/PayDo analysis here. About Crypto Payment Processor Watch The Crypto Payment Processor Watch series is dedicated to shining a light on the shadowy world of crypto and hybrid payment processors. In an industry plagued by regulatory loopholes and opaque corporate structures, we dissect the true compliance standards and business practices powering global financial flows—especially when legitimate licenses serve as a smokescreen for criminal activity. Our analytical approach combines investigative journalism, regulatory research, and data-driven scrutiny. The objective: to arm financial professionals, regulators, and the informed public with actionable intelligence on the payment gateways at the core of cyberfinance. The PayOp/PayDo Analysis Our latest report zeroes in on PayOp and PayDo, a partnership boasting FCA, FINTRAC, and MAS licenses, thousands of global merchants, and deep integration with offshore gambling networks. The analysis exposes how PayOp and PayDo systematically process payments for notorious unlicensed operators such as Gamdom, Rolletto, and RichKing Casino. Despite their regulatory credentials, both processors have repeatedly failed to enforce consumer protection standards, facilitate transactions with illegal casinos, and exploit cross-border regulatory blind spots—often to the detriment of vulnerable players and national compliance regimes. What emerges is a portrait of regulatory arbitrage in action. Behind glossy marketing and compliance badges, a sophisticated network effectively launders gambling revenues and enables operators barred by law from entire jurisdictions. The risks to investors, institutions, and consumers are real—and escalating. The full PayOp/PayDo report is now live, detailing the compliance failures, entity structures, whistleblower evidence, and imminent enforcement risks. Stay tuned as our Crypto Payment Processor Watch series continues to set new standards for industry transparency and accountability. Share Information via Whistle42

Crypto Payment Processor Watch Series Executive Summary PayOp and PayDo represent a concerning partnership in the high-risk payment processing sector, where legitimate regulatory licenses mask systematic facilitation of illegal gambling operations across multiple jurisdictions. Despite holding authorizations from respected regulators, including the UK’s FCA, Canada’s FINTRAC, and Singapore’s MAS, both entities have been implicated in processing payments for unlicensed casinos, circumventing consumer protection measures, and exploiting regulatory loopholes to enable prohibited gambling activities. Critical Investment Warning: FinTelegram’s investigations reveal that this partnership operates through a complex web of interconnected entities designed to obscure true ownership and enable regulatory arbitrage. The systematic processing of payments for operators like Gamdom, Rolletto, and RichKing Casino demonstrates willful disregard for compliance obligations despite formal regulatory oversight. Company Overview The PayOp/PayDo Alliance Structure The PayOp/PayDo partnership, announced in November 2021, creates a comprehensive payment processing ecosystem that spans multiple jurisdictions while targeting high-risk industries. This strategic alliance allows users to withdraw funds from PayOp accounts directly to PayDo wallets without delays or additional commissions, creating seamless payment flows that complicate regulatory oversight. Read our reports on PayOp and PayDo. PayOp Corporate Structure: Primary Entity: Transferop Payment Gateway Ltd (Canada, FINTRAC registered) Singapore Operations: FinTech Decision Pte Ltd (MAS regulated) Headquarters: Vancouver, Canada with operational presence in Ukraine Founded: 2016 Revenue: $17.6 million annually with 84 employees PayDo Corporate Structure: Primary Entity: Ecommerce Technologies Ltd (UK, FCA license 900916) Canadian Operations: PayDo Canada Ltd (FINTRAC registered) Post-Brexit Entity: PayDo EU Ltd (Malta operations) CEO: Serhii Zakharov (London-based) Revenue: £6.7 million (2024), Assets: £4.1 million Operational Integration and Market Position Both companies target identical high-risk industries including gambling, gaming, forex, and cryptocurrency operations across 170+ countries using 500+ payment methods and 100+ currencies. This comprehensive coverage enables them to serve clients that mainstream processors reject while maintaining the veneer of regulatory compliance. Key Business Metrics MetricValuePayOp Trading NamePayOpWebsitehttps://payop.comPayOp Legal EntityTransferop Payment Gateway Ltd / FinTech Decision Pte LtdPayOp Registration (Canada)FINTRAC Registered MSBPayOp Registration (Singapore)MAS Regulated (Singapore)PayOp Founded2016PayOp HeadquartersVancouver, Canada / Singapore / UkrainePayOp Revenue (Est.)$17.6 MillionPayOp Employees84 employeesPayDo Trading NamePayDoWebsitehttps://paydo.comPayDo Legal EntitiesEcommerce Technologies Ltd, PayDo Canada Ltd, PayDo EU LtdPayDo Registration (UK)FCA E-Money InstitutionPayDo Registration (Canada)FINTRAC Registered MSBPayDo Founded2016PayDo CEOSerhii ZakharovPayDo Revenue (2024)£6.7 MillionPayDo Assets (2024)£4.1 MillionCountries Coverage170+ countriesPayment Methods Supported500+ payment methodsCurrencies Supported100+ currenciesTarget IndustriesHigh-risk: Gambling, Gaming, Forex, CryptoPartnership (2021)Strategic Partnership (Nov 2021)Key Personnel (PayOp)Anastasia Semenkova (CEO), Denys MyloserdovKey Personnel (PayDo)Oleg Pikarevskyi, Matvii Mikhnevych, Ivan Pronchenkov, Serhii ZakharovFCA License Number900916Compliance RatingORANGE (PayRate42 downgrade) The impressive operational scale masks fundamental compliance failures that expose both companies to significant regulatory enforcement actions across multiple jurisdictions. Regulatory Framework and Compliance Failures Current Regulatory Status Despite maintaining authorizations from multiple respected regulators, both PayOp and PayDo have systematically violated their compliance obligations: PayOp Licenses: Canada: FINTRAC Money Services Business registration Singapore: MAS regulation through FinTech Decision Pte Ltd UK: Operations through Ecommerce Technologies Ltd partnership PayDo Licenses: UK: FCA E-Money Institution license 900916 Canada: FINTRAC MSB registration Malta: Post-Brexit EU operations through PayDo EU Ltd Systematic Compliance Violations IssueDescriptionImpactIllegal Gambling FacilitationProcessing payments for unlicensed online casinos across EUCriticalGamdom Casino IntegrationDeep partnership with Curacao-licensed Gamdom for EU playersCriticalRolletto Unauthorized TransactionsUnauthorized transactions to unlicensed Santeda International casinoHighFalse Merchant Category CodesUsing misleading MCCs to disguise gambling transactionsHighGamStop CircumventionHelping gambling addicts bypass UK self-exclusion schemesCriticalUK Gambling Act ViolationsCriminal offense under Section 33 – unlicensed gambling servicesCriticalTerms of Service ViolationsFailure to enforce prohibited gambling activities clausesMediumAML/KYC Compliance GapsInadequate Know Your Customer and Anti-Money Laundering controlsHighChargeback Processing IssuesComplex transaction structures complicate consumer protectionMediumRichKing Casino FacilitationPayment facilitation for illegal gambling site with CoinsPaidHighCustomer Fund Holding IssuesIssues with holdback deposits and payment provider problemsMediumRegulatory Loophole ExploitationUsing regulatory arbitrage between jurisdictionsHigh The most damaging violations involve systematic processing of payments for unlicensed gambling operators targeting jurisdictions where such activities are explicitly prohibited. The Gamdom Connection: A Case Study in Regulatory Evasion Offshore Casino Integration The partnership’s most significant compliance failure involves deep integration with Gamdom, a Curacao-licensed crypto casino operated by Smein Hosting. Despite lacking authorization within the European Economic Area, Gamdom actively targets EU players through PayOp and PayDo payment processing services. Read our Gamdom reports here. Transaction Structure: EU players purchase “Gamdom Coins” through PayOp/PayDo Payments are processed through Vilnius IT Solutions UAB in Lithuania Funds flow to Gamdom’s Curacao operations via Clear Junction LTD Complex structure designed to evade regulatory detection and chargeback protection Regulatory Violations: Facilitating unlicensed gambling in restricted jurisdictions Circumventing EU gambling regulations through transaction laundering Processing payments for activities prohibited under local laws Enabling vulnerable gamblers to bypass consumer protection measures Multiple Gambling Violations: A Pattern of Misconduct The Rolletto Scandal In May 2024, unauthorized transactions were discovered flowing from UK bank accounts (Monzo, HSBC, Barclays) through PayOp to Rolletto, an unlicensed casino operated by Santeda International. The transactions violated multiple regulatory frameworks: UK Gambling Act Section 33: Criminal offense for unlicensed gambling services False MCCs: Misleading merchant category codes to disguise gambling transactions GamStop Circumvention: Targeting self-excluded gambling addicts Banking Fraud: Misrepresenting transaction nature to bypass banking blocks RichKing Casino Warnings FinTelegram issued urgent warnings about RichKing Casino operations facilitated by PayOp, PayDo, and CoinsPaid. The warnings highlighted systematic processing of payments for operators lacking proper licensing and consumer protections. Corporate Structure and Beneficial Ownership Complex Ownership Networks EntityJurisdictionRoleStatusTransferop Payment Gateway LtdCanada (FINTRAC)PayOp Operating EntityActive MSBFinTech Decision Pte LtdSingapore (MAS)PayOp Singapore EntityMAS RegulatedEcommerce Technologies LtdUK (FCA)PayDo UK Operating EntityFCA Licensed (900916)PayDo Canada LtdCanada (FINTRAC)PayDo Canadian EntityFINTRAC RegisteredPayDo EU Ltd (Malta)Malta (Post-Brexit)PayDo European OperationsPost-Brexit OperationGamdom (Smein Hosting)CuracaoOffshore Crypto Casino ClientCompliance ViolationsRolletto (Santeda International)Gibraltar/CuracaoUnlicensed Casino ClientUnlicensed UK OperationsRichKing CasinoUnlicensedIllegal Gambling SiteFinTelegram Warning IssuedClear Junction LTDUK (FCA E-Money)Banking Partner for TransactionsFCA Regulated E-MoneyVilnius IT Solutions UABLithuaniaGamdom Payment ProcessingEU Payment Channel The PayOp/PayDo alliance operates through a complex network of entities across multiple jurisdictions, creating regulatory arbitrage opportunities and obscuring true beneficial ownership: Ukrainian Operational Control: Most operational staff located in Ukraine (Kyiv) Key personnel: Oleg Pikarevskyi, Matvii Mikhnevych, Ivan Pronchenkov Technical development and customer support centralized in Ukraine Regulatory Shell Structure: Canadian and UK entities provide regulatory legitimacy Singapore operations target Asian high-risk markets Malta entity enables post-Brexit EU operations Complex structure designed to exploit regulatory gaps Customer Complaints and Trustpilot Evidence Systematic Customer Abuse Trustpilot reviews reveal a pattern of systematic abuse of customers seeking refunds for illegal gambling transactions. In total, PayOp received 32% 1-star ratings: Customer Testimonials: “PayOp appears to be knowingly facilitating payments to unlicensed and illegal online gambling operators” “They allow illegal gambling companies such as Rolletto to process payments using PayOp” “By processing these transactions, PayOp actively supports and profits from illegal gambling operations” “Avoid PayOp at all costs if you value integrity and consumer protection” Operational Issues: Inability to pay back holdback deposits Payment provider problems affecting customer funds Repetitive verification processes designed to delay refunds Systematic refusal to reverse illegal gambling transactions Risk Assessment and Investment Implications Regulatory Enforcement Risk Both PayOp and PayDo face imminent regulatory enforcement across multiple jurisdictions: UK Enforcement Risk: FCA investigation of Ecommerce Technologies Ltd license 900916 Potential criminal charges under UK Gambling Act Section 33 Financial Ombudsman Service complaints escalation Canadian Enforcement Risk: FINTRAC review of MSB registrations for both entities AML/KYC compliance failures across multiple jurisdictions Potential criminal money laundering charges EU Enforcement Risk: Malta regulatory review of PayDo EU operations Lithuanian investigation of Vilnius IT Solutions UAB Multi-jurisdictional coordination on gambling violations Operational Sustainability The business model depends entirely on relationships that violate regulatory frameworks: 80%+ of business derived from high-risk gambling operations Systematic violation of terms of service across both platforms Complex transaction structures designed to evade detection Multiple security and operational issues affecting customer funds Reputational Contamination Association with PayOp/PayDo creates cascading risks: Banking partners face AML compliance contamination Legitimate merchants risk regulatory scrutiny Professional service providers face liability exposure Regulatory authorities question oversight effectiveness Whistleblower Testimonies and Inside Information Customer Protection Failures Multiple whistleblowers and customers have provided evidence of systematic failures: Gambling Addiction Exploitation: Active targeting of GamStop-registered individuals Refusal to process refunds for vulnerable gamblers Complex transaction structures preventing consumer protection Systematic circumvention of banking blocks on gambling Operational Deficiencies: Inability to maintain adequate reserves for customer funds Payment provider relationship problems affecting operations Repetitive compliance processes designed to frustrate customers Systematic avoidance of regulatory reporting obligations Partnership Strategy and Market Manipulation Strategic Alliance Benefits The PayOp/PayDo partnership creates specific advantages for high-risk processing: Regulatory Arbitrage: Multiple licenses across different jurisdictions Complex entity structures obscure true operations Cross-border payment flows complicate enforcement Strategic use of partnership agreements to avoid direct liability Market Coverage: Combined coverage of 170+ countries through single integration 500+ payment methods reduce detection by specific processors Multiple currency support enables global gambling operations Technical integrations with high-risk industry platforms Industry Impact and Regulatory Response PayRate42 Downgrade Both PayOp and PayDo have been downgraded to ORANGE compliance status by PayRate42, the leading payment processor rating authority, specifically due to their involvement with unlicensed gambling operations. Downgrade Factors: Systematic processing of payments for unlicensed gambling Failure to enforce terms of service prohibitions Complex transaction structures designed to evade detection Multiple customer complaints regarding illegal gambling facilitation Regulatory Environment Evolution The PayOp/PayDo case demonstrates critical gaps in cross-border payment regulation: Multiple regulators supervising the same operational network Lack of coordination between FCA, FINTRAC, and MAS oversight Complex corporate structures exploiting regulatory arbitrage Need for enhanced beneficial ownership transparency requirements Investment Recommendation Risk Rating: CRITICAL – AVOID PayOp and PayDo present unacceptable investment risks that disqualify both entities from legitimate business consideration: Primary Disqualifying Factors: Systematic Regulatory Violations: Willful processing of payments for unlicensed gambling Criminal Enterprise Facilitation: Active support for operators violating criminal law Consumer Protection Failures: Exploitation of vulnerable gambling addicts Complex Evasion Structures: Corporate architecture designed to avoid accountability Multiple Jurisdiction Exposure: Enforcement risk across UK, Canada, EU, and Singapore Operational Instability: Customer fund holding issues and payment provider problems Required Actions for Investment Consideration Both entities would require comprehensive remediation before investment consideration: Immediate Requirements: Cessation of all gambling-related payment processing Comprehensive audit of all merchant relationships Implementation of robust transaction monitoring systems Proactive cooperation with all regulatory authorities Transparent beneficial ownership disclosure across all entities Long-term Requirements: Independent compliance monitoring for minimum 24 months Regulatory approval for all new high-risk merchant relationships Quarterly reporting to all supervisory authorities Customer fund segregation and protection mechanisms Professional liability insurance for compliance failures Whistleblower Call to Action The PayOp/PayDo investigation demonstrates the critical importance of insider information in exposing payment processor misconduct. Current and former employees, merchants, and customers with knowledge of violations are encouraged to provide confidential information. Specific Information Sought: Internal communications regarding gambling compliance policies Merchant onboarding procedures for high-risk clients Financial records showing transaction flows to unlicensed operators Evidence of regulatory reporting failures or omissions Documentation of customer complaint handling procedures Secure Reporting: Information can be safely submitted through FinTelegram’s secure whistleblower platform:  Share Information via Whistle42 Conclusion The PayOp/PayDo alliance represents a sophisticated regulatory evasion scheme that exploits legitimate licensing frameworks to facilitate illegal gambling operations across multiple jurisdictions. While both entities maintain authorizations from respected regulators, their systematic violations demonstrate that regulatory licensing alone cannot ensure compliance integrity. Key Findings: Strategic partnership designed to exploit regulatory arbitrage Systematic processing of payments for unlicensed gambling operations Complex corporate structures obscuring beneficial ownership and accountability Multiple customer protection failures affecting vulnerable gambling addicts Operational instability threatening customer fund security Investment Verdict: Both PayOp and PayDo are unsuitable for investment or business partnership until comprehensive remediation addresses systematic compliance failures and regulatory violations. The case highlights critical weaknesses in cross-border payment regulation and demonstrates the need for enhanced coordination between supervisory authorities to prevent legitimate licensing from being exploited for illegal activities. This analysis is based on regulatory filings, customer complaints, investigative reports, and publicly available information. The serious nature of the compliance violations requires independent legal and regulatory review before engaging with either entity.

The US bitcoin mining CleanSpark has secured a $100 million Bitcoin-backed credit facility from Coinbase Prime—leveraging its crypto reserves to fuel aggressive expansion without shareholder dilution. The deal marks a maturing moment for crypto-backed structured finance and signals growing institutional confidence in Bitcoin as collateral. Key Facts CleanSpark expanded its credit line with Coinbase Prime, securing an additional $100 million, fully backed by Bitcoin collateral. The deal allows non-dilutive financing, preserving shareholder equity while unlocking liquidity. Funds will support capital expenditures, including Bitcoin mining expansion, energy portfolio growth, and HPC (high-performance computing) development. CleanSpark reportedly holds ~13,000 BTC, part of which is pledged under the loan terms. The financing is structured to retain upside exposure to Bitcoin while tapping institutional-grade lending via Coinbase Prime. CleanSpark’s stock jumped on the news, reflecting positive market sentiment toward non-dilutive capital strategies. This move follows earlier similar credit strategies by CleanSpark and other miners using BTC reserves to secure fiat liquidity. Short Analysis CleanSpark’s Coinbase credit deal is emblematic of the crypto sector’s evolving capital stack. By securing fiat financing against Bitcoin holdings, CleanSpark bridges Web3 asset management with institutional-grade capital markets. This playbook—crypto-collateralized credit—offers miners a way to scale without equity dilution or asset sales. However, the strategy is not without risk. Bitcoin’s price volatility exposes CleanSpark to margin calls and forced liquidation if markets turn sharply. Coinbase’s role as both custodian and lender also concentrates counterparty risk. If crypto prices collapse, or Coinbase adjusts collateral thresholds, CleanSpark’s balance sheet could face stress. Still, the deal signals growing confidence in regulated, crypto-backed lending infrastructure. Expect more such hybrid structures as BTC becomes an accepted corporate reserve asset and credit instrument. Call for Information Do you have insights into crypto-backed lending practices, hidden risks in miner financing, or Coinbase Prime’s institutional lending terms? We invite insiders, affected parties, and whistleblowers to submit information securely and anonymously via Whistle42.com. Share Information via Whistle42

The U.S. SEC has dropped the hammer on Retail Ecommerce Ventures’ ex‑leadership, alleging a $112 million Ponzi‑like fundraising machine wrapped in a “brand revival” fairy tale. Promising investors 25% annual returns while using fresh money to plug holes, the scheme allegedly siphoned millions for personal spend and left iconic names like RadioShack and Pier 1 as mere props. This case is a stark warning: glossy turnaround narratives don’t excuse opaque cash flows, guaranteed yields, or executive self‑dealing—expect bans, disgorgement, and a wider compliance chill across private offerings. Key facts The U.S. Securities and Exchange Commission filed suit in a Florida federal court against three former executives of Retail Ecommerce Ventures (REV) (Source: wsj.com). The SEC alleges they raised approximately USD 112 million through securities offerings that functioned as a Ponzi‑type scheme, promising investors a 25% annual return on their capital (Source: law360.com). REV had acquired distressed retail brands (notably RadioShack, Pier 1 Imports, Dressbarn, Modell’s, Stein Mart) with the pitch of revitalizing them as profitable, e‑commerce centric businesses (Source: bloomberg.com). According to the complaint, none of the acquired brands generated the profits claimed. REV allegedly funded payout obligations using new investor capital, merchant cash advances, outside loans, or investor funds — classic red flags in a Ponzi structure (Source: wsj.com). The SEC also accuses the defendants of misappropriating about USD 16 million to finance personal expenses (Source: wsj.com). The complaint seeks civil penalties, disgorgement of ill‑gotten gains, and permanent bans on serving as public company officers or directors. law360.com+2wsj.com+2 REV suffered liquidity pressures, with secured creditors foreclosing in 2023. The company was dissolved; its assets were shifted to a successor entity, Omni Retail Enterprises (Source: wsj.com). What makes this case hard‑hitting (and instructive) 1. Ponzi characteristics in a corporate acquisitions vehicle It’s unusual to see an acquisition vehicle positioned publicly as a growth strategy be accused of operating as a Ponzi-like fraud. The classic Ponzi blueprint is borrowing from new investors to pay old ones. But here, the vehicle was cloaked as a “turnaround e‑commerce platform,” with brand acquisitions as cover. That gives this case both novelty and strategic relevance to enforcement actors. 2. Use of narrative, marketing and storytelling REV heavily marketed its vision. In investor presentations and promotional videos, it portrayed its acquired brands as “on fire,” generating robust cash flow — all to sustain investor confidence and drive further fund inflows. That narrative component is critical: when fraud hides behind plausible business narratives, it complicates detection and gives fraudsters more room to argue they believed in their own model (a classic defense). 3. The warning signs: red flags that should have registered Promise of high, guaranteed returns — 25% per annum is extraordinary in any legitimate retail turnaround play. Opaque use of capital — shifting funds via merchant advances or new investor funds, with little transparency. Aggressive recruitment of new capital — necessary in any Ponzi scheme to sustain payouts. Weak or non‑existent profitability in the underlying businesses — a fatal flaw in the business justification. Asset transfers to successor entities / winding down before enforcement — classic play to complicate recovery. These are textbook indicators, yet they were masked by the veneer of “brand revival.” That is precisely what the SEC seized on. 4. The enforcement signal This filing sends multiple signals: The SEC remains aggressive about fraud in retail, brand investments, and private offerings even outside financial sector. The agency is demonstrating that “buy and build” stories, especially in distressed retail, will not get a free pass. By targeting senior executives for personal liability (misappropriation, officer‑director bans), the SEC stresses individual accountability. Risks, uncertainties, and defense angles Good faith argument: The defendants may argue that they genuinely believed in their turnaround strategy, that market conditions deteriorated (especially given ongoing retail headwinds), and that capital shortfalls drove desperate measures later. Causation / investor reliance: They might challenge whether investors relied solely on misrepresentations, or should have done more due diligence on underlying brands. Recovery challenges: Since REV was foreclosed and reconstituted as a successor, tracing and clawing back funds may run into hurdles, particularly across entities and jurisdictions. Parallel criminal exposure: This is a civil SEC action, but misappropriation allegations may invite criminal inquiries, especially if fraud is proven. Broader implications & watchpoints for markets and compliance Investor appetite for “brand play” stories: This case may chill the surge of private deals predicated on reviving dormant consumer brands via e‑commerce — high-risk narratives may now attract greater scrutiny. Private capital and retail revival funds: Lending or investing into funds promising large returns to revive retail brands might face tougher diligence standards from institutional investors. Heightened due diligence regimes: Investors, analysts, and compliance teams must probe not just the pitch but the cash flows, funding sources, and sustainability of model assumptions. Civil enforcement pressure: Expect the SEC to deploy more “less orthodox” fraud claims — blending acquisition business models with classical fraud facts. Share Information via Whistle42

A FinTelegram Special Report Buongiorno! While you enjoy your morning espresso at your favorite bar, the financial world is witnessing a seismic shift that will fundamentally transform how securities are traded, settled, and owned. Nasdaq’s groundbreaking September 2025 proposal to the SEC represents far more than a technological upgrade—it signals the inevitable tokenization of the entire financial system. The Nasdaq Watershed Moment On September 8, 2025, Nasdaq filed a historic proposal (SR-NASDAQ-2025-072) with the Securities and Exchange Commission that could forever change the architecture of capital markets. The initiative seeks to enable trading of tokenized equity securities and exchange-traded products (ETPs) alongside their traditional counterparts on the same order book, utilizing blockchain technology for settlement while maintaining existing regulatory protections. Revolutionary Framework: Under Nasdaq’s proposal, investors can choose to settle trades in either traditional or tokenized form on a trade-by-trade basis. Tokenized securities must be fungible with traditional shares, carry identical CUSIP numbers, and provide shareholders with the same rights and privileges. The Depository Trust Corporation (DTC) will handle conversion to token form, enabling T+1 settlement through blockchain infrastructure. This represents the first serious attempt by a major U.S. exchange to integrate blockchain-based settlement into the national market system—a development that validates FinTelegram’s long-standing position that tokenization is the inevitable future of finance. The Current Regulatory Stranglehold Gary Gensler’s War on Innovation The path to Nasdaq’s breakthrough has been littered with regulatory obstacles, particularly under SEC Chair Gary Gensler‘s aggressive enforcement regime. Gensler has consistently maintained that “the vast majority” of crypto tokens are securities under the Howey Test, creating a hostile environment for blockchain innovation. The Coinbase Crucible: The SEC’s enforcement actions against Coinbase perfectly illustrate the regulatory dysfunction that has stifled security token adoption. In June 2023, Gensler’s SEC sued Coinbase for operating as an unregistered securities exchange, specifically identifying 13 tokens worth $37 billion as securities. The case was ultimately dismissed in 2025 under the Trump administration, but the damage to innovation was severe. Challenge CategoryDescriptionImpact LevelSEC Enforcement – CoinbaseSEC sued Coinbase for operating unregistered securities exchangeCriticalSecurity Token ClassificationMost crypto tokens classified as securities under Howey TestCriticalExchange Listing RestrictionsMajor exchanges refuse to list security tokens due to regulatory riskHighRegulatory UncertaintyLack of clear regulatory framework across jurisdictionsHighCompliance CostsHigh compliance costs for security token issuancesMediumCross-Border IssuesDifferent regulatory approaches across countriesHighKYC/AML RequirementsStringent identity verification and anti-money laundering rulesMediumHowey Test ApplicationSupreme Court test determines if token is investment contractCriticalGary Gensler Position“Vast majority” of crypto tokens are securities – GenslerCriticalDelisting Risks25% of listed tokens face delisting across major exchangesHighLiquidity ConstraintsLimited secondary market liquidity for security tokensHighInfrastructure RequirementsNeed for specialized custody and trading infrastructureMedium security_token_challenges.csv Generated File The Exchange Listing Desert The regulatory uncertainty has created a barren landscape for security token trading. Major cryptocurrency exchanges have systematically refused to list security tokens, fearing regulatory retaliation. This has created a vicious cycle: without liquid trading venues, security tokens cannot achieve market acceptance, while exchanges avoid listing assets that regulators might classify as securities. Delisting Epidemic: Analysis of major exchanges from 2023-2024 reveals that 25% of listed tokens faced delisting, with many removals driven by regulatory concerns rather than project failures. This systematic purge has decimated the security token ecosystem, forcing legitimate projects into regulatory limbo. The Tokenization Market Explosion Despite regulatory headwinds, the tokenization market has experienced explosive growth that demonstrates pent-up demand for blockchain-based securities: Market SegmentMarket Value (USD)CAGR/Growth RateTime PeriodGlobal Security Token Market (2024)$1.91 billion27.3%2024Global Security Token Market (2033)$17.44 billion27.3%2024-2033Security Token Offering (STO) Market (2025)$6.66 billion19%2025Security Token Offering (STO) Market (2034)$31.87 billion19%2025-2034Tokenized Securities Market (2023)$2.3 billion16.1%2023Tokenized Securities Market (2032)$8.9 billion16.1%2023-2032Real-World Asset (RWA) Tokenization (2025)$24 billion380% over 3 yearsCurrentRWA Tokenization Projection (2034)$30 trillionProjected growth2025-2034Asset Tokenization Market (2024)$865.54 billion43.36%2024Asset Tokenization Market (2029)$5,254.63 billion43.36%2024-2029Tokenized Money Market/Treasury Funds (2025)$7.4 billion80% YTD growth2025Private Credit RWA Share58% of RWA marketMarket leader2025US Treasuries RWA Share34% of RWA marketSecondary segment2025 Unstoppable Growth Trajectory The numbers tell an extraordinary story of market evolution despite regulatory hostility: Real-World Asset Tokenization: The RWA market reached $24 billion in 2025, growing 380% over three years. Private credit dominates with 58% market share, while U.S. Treasuries account for 34%. Institutional Validation: BlackRock’s BUIDL fund manages $2.9 billion in tokenized U.S. Treasuries, making it the largest tokenized asset fund globally. Franklin Templeton’s BENJI follows with $776 million, while VanEck has introduced VBILL for cross-blockchain Treasury access. Exponential Projections: Conservative estimates project the tokenization market reaching $2-4 trillion by 2030, while optimistic forecasts suggest $30 trillion by 2034. McKinsey, BCG, and Standard Chartered all predict multi-trillion-dollar markets within the decade. The Transformative Power of Tokenization Benefit CategoryTraditional Finance ChallengeTokenization SolutionFractional OwnershipHigh minimum investments exclude retail investorsAssets can be divided into affordable fractionsEnhanced LiquidityIlliquid assets like real estate hard to tradeBlockchain enables continuous tradingLower Transaction CostsMultiple intermediaries increase feesSmart contracts reduce intermediary fees24/7 Trading CapabilityLimited to market hours onlyBlockchain operates continuouslyFaster SettlementT+1 or T+2 settlement cyclesNear-instant settlement on blockchainGlobal Market AccessGeographic and regulatory barriersGlobal access through blockchain networksProgrammable ComplianceManual compliance processesSmart contracts automate complianceTransparency & AuditabilityLimited transparency in ownership recordsAll transactions recorded on blockchainReduced IntermediariesMultiple intermediaries requiredDirect peer-to-peer transactionsAutomated ProcessesManual back-office operationsSmart contracts automate processesPortfolio DiversificationHigh capital requirements for asset classesAccess to previously unavailable asset classesDemocratized AccessExclusive access to institutional investorsLower barriers enable broader participation Democratizing Finance Through Technology Tokenization addresses fundamental inefficiencies that have plagued traditional finance for centuries: Fractional Ownership Revolution: Real estate, fine art, and other high-value assets can be divided into affordable fractions, enabling retail investors to access previously exclusive markets. Liquidity Liberation: Traditionally illiquid assets become continuously tradable on blockchain networks, creating new pools of capital and investment opportunities. Settlement Speed: Near-instant settlement eliminates counterparty risk and frees capital from multi-day clearing cycles, dramatically improving capital efficiency. Global Access: Blockchain networks transcend geographic boundaries, enabling truly global capital markets without traditional intermediaries. The Regulatory Renaissance Under Trump The regulatory environment has transformed dramatically since the Trump administration’s return to power. The dismissal of the Coinbase case and the SEC’s new rulemaking agenda indicate a fundamental shift toward blockchain innovation. Bipartisan Support: The recent passage of the GENIUS Act by the Senate establishes the first federal framework for digital assets that Wall Street has long awaited. This legislation provides regulatory clarity that has been missing for years. Industry Validation: Major financial institutions including JPMorgan, Goldman Sachs, and BNY Mellon are actively tokenizing money-market funds and other financial instruments, demonstrating institutional confidence in the regulatory direction. Nasdaq’s Strategic Masterstroke Why Nasdaq Will Succeed Where Others Failed Nasdaq’s approach differs fundamentally from previous tokenization attempts: Regulatory Compliance: By working within existing securities law and utilizing DTC infrastructure, Nasdaq avoids the regulatory pitfalls that doomed earlier security token initiatives. Market Integration: Trading tokenized and traditional securities on the same order book eliminates liquidity fragmentation while maintaining familiar market structure. Infrastructure Leverage: Utilizing existing Nasdaq systems and DTC clearing infrastructure minimizes implementation complexity while maximizing regulatory acceptance. Timing Advantage: The proposal arrives at the perfect regulatory moment, with a crypto-friendly administration and growing institutional demand for blockchain solutions. The Coming Tokenization Tsunami Phase One: Liquid Securities (2026-2027) Nasdaq plans to launch tokenized securities trading once DTC’s blockchain infrastructure is operational, likely by Q3 2026. Initial focus will target liquid ETFs and large-cap stocks to establish market confidence. Phase Two: Expansion Across Asset Classes (2027-2029) Success with liquid securities will drive expansion into fixed income, commodities, and alternative assets. The tokenized market could reach $235 billion by 2029 according to Calastone projections. Phase Three: Global Market Transformation (2030+) By 2030, tokenization will fundamentally transform capital markets architecture, enabling 24/7 global trading, programmable compliance, and frictionless cross-border investment. The Inevitable Future: Total Financial System Tokenization FinTelegram’s analysis indicates that tokenization represents an unstoppable technological evolution, not merely a financial innovation. The combination of regulatory clarity, institutional adoption, and technological maturity creates an environment where tokenization will become the dominant model for securities trading. Network Effects: As more assets become tokenized, network effects will accelerate adoption. Investors will demand tokenized versions of traditional securities to access 24/7 trading and instant settlement capabilities. Competitive Pressure: Exchanges that fail to offer tokenization services will face competitive disadvantage as trading migrates to blockchain-based platforms offering superior efficiency and global access. Regulatory Evolution: Regulators worldwide are recognizing that tokenization enhances rather than threatens market integrity through improved transparency, automated compliance, and reduced systemic risk. Investment Implications and Strategic Positioning Winners in the Tokenization Revolution Infrastructure Providers: Companies providing blockchain infrastructure, custody services, and compliance technology will capture enormous value as tokenization scales. Early Adopters: Financial institutions and exchanges that embrace tokenization early will gain competitive advantages in efficiency, global reach, and customer service. Technology Enablers: Firms developing smart contract platforms, cross-chain interoperability, and regulatory technology will benefit from explosive demand growth. Risks for Traditional Players Incumbent Exchanges: Exchanges that resist tokenization face disintermediation as trading volume migrates to blockchain-based platforms offering superior functionality. Traditional Custodians: Custodial services that cannot adapt to digital asset requirements risk losing market share to blockchain-native providers. Legacy Infrastructure: Companies dependent on outdated clearing and settlement infrastructure face obsolescence as tokenized markets mature. FinTelegram’s Tokenization Thesis Based on our comprehensive analysis, FinTelegram maintains that tokenization represents the most significant transformation of financial markets since the introduction of electronic trading. The convergence of regulatory clarity, institutional adoption, and technological maturity has created conditions for explosive growth. Key Predictions: 2026: Nasdaq successfully launches tokenized securities trading, becoming the first major U.S. exchange to offer blockchain settlement 2027: Other major exchanges follow Nasdaq’s lead, creating competitive tokenization offerings 2028: Tokenized markets reach $100+ billion in total value locked, demonstrating mainstream adoption 2030: Tokenization becomes the preferred method for new security issuances, representing majority market share for liquid assets 2035: Traditional securities trading becomes legacy technology, with tokenized markets dominating global finance The Cyberfinance Revolution is Unstoppable The Nasdaq proposal represents a pivotal moment in financial history—the formal recognition by traditional capital markets that blockchain technology is not a threat to be contained, but an evolution to be embraced. The regulatory barriers that once seemed insurmountable are crumbling under the weight of technological inevitability and institutional demand. The message is clear: Financial institutions, investors, and regulators must prepare for a tokenized future. Those who embrace this transformation will thrive in the new cyberfinance ecosystem, while those who resist risk obsolescence. The tokenization revolution has begun. The only question remaining is how quickly traditional finance will adapt to this new reality. Share Information via Whistle42 FinTelegram remains at the forefront of cyberfinance analysis, tracking the transformation of global financial systems through blockchain technology. As tokenization reshapes capital markets, we continue providing critical insights for investors, institutions, and regulators navigating this historic transition. Position: The future of finance is tokenized. The Nasdaq proposal proves this future has arrived.

Crypto Payment Processor Watch Series Executive Summary CoinsPaid represents one of the most concerning cases in the crypto payment processing sector, where significant market presence masks extensive compliance violations and potential criminal activity. Operating as the self-proclaimed “#1 crypto payment gateway for iGaming,” the Estonia-licensed company processes over €3 billion annually while allegedly facilitating money laundering, illegal gambling, and sanctions evasion across multiple jurisdictions. Critical Investment Warning: FinTelegram’s comprehensive investigations reveal systematic financial misconduct, including potential insolvency, shadow ownership by sanctioned entities, and active intimidation of whistleblowers. The company’s deep integration with unlicensed gambling operations and alleged document forgery create unacceptable regulatory and reputational risks. Company Overview Corporate Structure and Shadow Leadership CoinsPaid operates through Dream Finance OÜ, Dream Finance UAB, and Dream Finance US LLC. Until recently, Dream Finance S.A. in El Salvador was also listed as the operator; however, this entity has since been removed from the website. The company maintains a complex multinational structure that obscures actual ownership and control. Official Leadership: CEO: Max Krupyshev (Ukraine) – Public face and crypto influencer Beneficial Owner: Alexander Horst Riedinger (Austria) – Alleged frontman Shadow Control: Ivan Montik (Belarus) – Co-founder of SoftSwiss and alleged true controller Key Concern: Multiple sources indicate Riedinger serves as a front for Belarusian interests, with Ivan Montik wielding actual control over operations. This shadow ownership structure enables sanctions evasion and regulatory manipulation. Business Model and Market Dominance CoinsPaid operates multiple brands including CoinsPaid.com, CryptoProcessing.com, and the secretly integrated AlphaPo, creating a dominant position in high-risk payment processing. The company claims to handle 8% of global on-chain Bitcoin flows and processes over 8 million monthly transactions for 500+ gambling operators. Operational Scale: €3 billion processed in Q4 2022 500+ iGaming operators served 150+ countries supported 100+ employees across multiple jurisdictions Key Business Metrics MetricValueTrading NamesCoinsPaid, CryptoProcessing, AlphaPoFounded2018HeadquartersTallinn, EstoniaLegal Entitieshttps://fintelegram.com/tag/dream-financeDream Finance OÜ, Dream Finance UAB, Dream Finance US LLC, Dream Finance S.A. CEOMax Krupyshev (Ukraine)Beneficial Owner (UBO)Alexander Horst Riedinger (Austria)Key FiguresIvan Montik, Pavel Kashuba, Frédéric HubinTotal Processing Volume (Q4 2022)€3 BillionMonthly Transaction Volume8+ Million TransactionsMerchant Accounts500+ OperatorsCountries Supported150+Cryptocurrencies Supported20+Fiat Currencies40+Employees100+License – EstoniaFIU Estonia CASP LicenseLicense NumberFVT000166Business ModelCrypto Payment Gateway & ExchangeTarget IndustriesiGaming, Online Gambling, High-RiskMajor Security Incidents$37.3M Hack (July 2023), $7.5M Hack (2024)Former Brand NamesAlphaPo (integrated operations)Related EntitiesSoftSwiss, Merkeleon GmbHGlobal Bitcoin Flow Share8% of Global On-Chain Bitcoin Flows (allegedly) The impressive growth metrics mask fundamental compliance failures and potential insolvency issues that threaten the company’s operational viability. Regulatory Framework and License Status Current Authorization CoinsPaid holds an Estonian CASP license (FVT000166) from the Financial Intelligence Unit FIU), renewed in September 2023 after 15 months of regulatory scrutiny. The company invested €5 million in share capital to meet Estonia’s stringent requirements, positioning itself as a compliant operator in the European market. Regulatory Claims: Estonia FIU licensed under new CAMA framework Regular third-party security and compliance audits AML/KYC compliance systems Preparation for EU MiCAR implementation Critical Compliance Failures Despite regulatory licensing, FinTelegram investigations reveal systematic violations that contradict the company’s compliance narrative: IssueDescriptionImpactMoney Laundering OperationsLaundering hundreds of millions of euros annually through cryptoCriticalIllegal Gambling FacilitationProcessing payments for unlicensed gambling operators globallyCriticalFinancial Insolvency/Negative EquityOperating with negative equity despite €37M+ in lossesHighBelarusian Shadow ControlAustrian UBO Riedinger fronting for Belarusian interestsCriticalSoftSwiss Casino IntegrationDeep integration with unlicensed SoftSwiss casino platformsHighAlphaPo Hidden IntegrationSecret operational merger with AlphaPo payment processorHighRegulatory EvasionExploiting regulatory loopholes across multiple jurisdictionsHighDocument Forgery AllegationsAlleged forged signatures in Cyprus court documentsCriticalWhistleblower IntimidationSystematic campaign against former director Frédéric HubinMediumTax Fraud AllegationsNon-compliance with local tax regulations across EUHighSanctions EvasionFacilitating payments in sanctioned countries (Russia/Belarus)CriticalCorporate Structure ManipulationUsing shell companies to obscure true ownership structureHigh The most damaging revelations involve CoinsPaid’s secret operational merger with AlphaPo, creating a single entity that processes payments for unlicensed gambling operations while maintaining separate public identities to deceive regulators. Financial Misconduct and Insolvency Concerns Security Breaches and Financial Losses CoinsPaid has suffered multiple devastating security incidents: July 2023: $37.3 million theft attributed to Lazarus Group (Source: CoinsPaid) 2024: Additional $7.5 million breach Total Losses: Over $44 million in confirmed thefts Insolvency Indicators: Whistleblower reports suggest the company operates with negative equity, continuing operations despite being technically bankrupt. The discrepancies between publicly reported and actual losses raise serious questions about financial transparency. Money Laundering Operations Former director Frédéric Hubin and other whistleblowers allege CoinsPaid launders hundreds of millions of euros annually through cryptocurrency transactions. The operation allegedly involves: Network of Belarusian expatriates across European countries Processing payments for offshore and illegal gambling platforms Systematic evasion of AML/KYC requirements Tax fraud across multiple jurisdictions The SoftSwiss Connection Unlicensed Gambling Ecosystem CoinsPaid‘s most significant compliance failure involves its deep integration with SoftSwiss, a Belarus-founded iGaming platform operator. This relationship enables unlicensed gambling operations across regulated European markets through brands including: Rabidi Dama Hollycorn N1 Interactive Regulatory Violations: These platforms operate without proper licenses in regulated markets, with CoinsPaid providing the payment infrastructure that enables continued operations despite regulatory warnings. Download our report on Rabidi, Softswiss and CoinsPaid here. Sanctions Evasion Concerns The Belarus connection raises serious sanctions compliance issues, particularly given: Ivan Montik‘s role as SoftSwiss founder and CoinsPaid co-founder Operations in sanctioned countries including Russia and Belarus Use of Austrian fronting to obscure Belarusian control Processing payments for platforms serving sanctioned jurisdictions Whistleblower Intimidation and Document Forgery The Frédéric Hubin Case Former CoinsPaid director Frédéric Hubin‘s explosive allegations have triggered a systematic intimidation campaign. Hubin claims: CoinsPaid operates with negative equity Systematic money laundering operations Belarusian shadow control of operations Processing payments for illegal SoftSwiss casinos Corporate Retaliation: CoinsPaid has pursued legal action against Hubin in Belgian courts, obtaining a judgment for €80,700 while dismissing his substantive allegations about company misconduct. Document Forgery Allegations Most concerning are allegations that CoinsPaid participated in document forgery for Cyprus court proceedings. FinTelegram reports that CoinsPaid co-signed documents with Payabl (another high-risk processor) containing allegedly forged signatures in an attempt to obtain injunctions against investigative reporting. Risk Assessment and Investment Implications Regulatory Enforcement Risk CoinsPaid faces potential enforcement actions across multiple jurisdictions: European Union: MiCAR implementation increases scrutiny of CASP operations, particularly those serving unlicensed gamblingEstonia: Regulatory review of license renewal given mounting compliance concernsAustria: Investigation of Alexander Riedinger’s fronting activitiesMultiple Jurisdictions: AML/sanctions investigations related to Belarusian connections Operational Sustainability The company’s business model depends on relationships that violate regulatory frameworks: Over 70% of business derived from gambling operations Many clients operate without proper licenses Shadow ownership structure enables regulatory evasion Multiple security breaches demonstrate operational vulnerabilities Reputational Contamination Association with CoinsPaid creates cascading reputational risks: Regulatory scrutiny for partner institutions Sanctions compliance concerns for financial counterparties AML violations for correspondent banking relationships Professional liability for service providers Market Position and Competitive Analysis Industry Leadership Claims CoinsPaid claims market leadership in crypto iGaming payments, processing €3 billion annually with 500+ operator clients. However, this dominance relies on serving unlicensed operators that compliant processors avoid. Competitive Vulnerabilities: Business model depends on regulatory arbitrage Client base consists primarily of high-risk operators Shadow ownership creates sanctions compliance issues Multiple security breaches demonstrate operational weakness Fee Structure and Business Economics CoinsPaid offers competitive processing fees below 1% with no monthly charges or rolling reserves. However, the low-cost model depends on: Inadequate compliance investment Regulatory arbitrage through Estonian licensing Serving clients other processors reject Investment Recommendation Risk Rating: CRITICAL – AVOID CoinsPaid presents unacceptable risks that disqualify it from any legitimate investment consideration: Primary Disqualifying Factors: Criminal Enterprise Allegations: Systematic money laundering and sanctions evasion Financial Insolvency: Operating with negative equity following major losses Shadow Ownership: Belarusian control through Austrian fronting arrangement Document Forgery: Alleged participation in legal document manipulation Whistleblower Intimidation: Systematic campaign against former executives Regulatory Violations: Enabling unlicensed gambling across regulated markets Enforcement Prediction Given the severity and scope of violations, CoinsPaid faces imminent regulatory action: License revocation in Estonia likely within 12 months Criminal investigations probable in multiple jurisdictions Civil forfeiture actions targeting laundered proceeds Sanctions designation possible for shadow controllers Industry Impact and Systemic Risk Contagion Concerns CoinsPaid’s operations create systemic risks for the cryptocurrency ecosystem: Undermines regulatory confidence in licensed operators Creates compliance contamination for partner institutions Demonstrates inadequacy of current licensing frameworks Validates regulatory concerns about crypto payment processors Regulatory Response The CoinsPaid case will likely accelerate regulatory tightening: Enhanced beneficial ownership disclosure requirements Stricter AML/KYC enforcement for crypto processors Increased sanctions compliance scrutiny Coordinated international enforcement actions Whistleblower Call to Action The CoinsPaid investigation demonstrates the critical importance of insider information in exposing financial crime. Current and former employees, business partners, and clients with knowledge of CoinsPaid‘s operations are encouraged to provide confidential information through FinTelegram’s secure whistleblower platform. Specific Information Sought: Financial records demonstrating insolvency or losses Documentation of money laundering operations Evidence of sanctions evasion activities Communications regarding document forgery Internal records of shadow ownership arrangements Secure Reporting: Whistleblowers can safely submit information regarding CoinsPaid and related entities through Whistle42’s secure platform: https://whistle42.com Conclusion CoinsPaid represents a textbook case of how cryptocurrency payment processors can exploit regulatory gaps to facilitate criminal activity while maintaining a veneer of compliance. The company’s Estonian license and professional marketing mask an operation allegedly controlled by sanctioned interests, designed to launder money and evade international sanctions. Investment Verdict: CoinsPaid is unsuitable for any legitimate investment or business relationship. The combination of criminal enterprise allegations, financial insolvency, shadow ownership, and active enforcement risks creates unacceptable exposure for any associated party. The case serves as a critical warning about the cryptocurrency payment sector’s vulnerabilities and the need for enhanced regulatory oversight. Investors, financial institutions, and service providers must implement rigorous due diligence procedures to avoid contamination from operations like CoinsPaid. Final Assessment: CoinsPaid should be treated as a high-risk criminal enterprise masquerading as a legitimate financial services provider. Any association with the company or its principals creates immediate legal, regulatory, and reputational jeopardy. Share Information via Whistle42 This investor briefing is based on investigative reports, regulatory filings, and publicly available information. The serious nature of the allegations requires independent verification through appropriate legal and regulatory channels.

Executive Summary Swapped.com represents a concerning case study in the crypto payment processing sector, highlighting the challenges of regulatory compliance in an evolving digital asset landscape. While the Denmark-based company has achieved notable growth with 1.5 million users across 150+ countries, recent investigations reveal significant compliance failures that pose substantial regulatory and reputational risks to the organization and its stakeholders. Key Investment Concerns: FinTelegram’s comprehensive investigation has uncovered deep operational ties with unlicensed gambling platforms, particularly Gamdom, despite explicit regulatory prohibitions. These relationships expose Swapped to multi-jurisdictional enforcement actions and contradict the company’s stated compliance framework. Read our reports on Gamdom here. Company Overview Corporate Structure and Leadership Swapped ApS, incorporated in Denmark under registration number 42865397, operates from dual headquarters in Aarhus, Denmark and St. Julians, Malta. The company was founded in 2021 by Thomas Franklin (CEO) and Jonathan Bau (CTO/CMO), who previously operated under the name Bitinvestor before rebranding. Thomas Franklin brings compliance expertise from his previous role as Money Laundering Reporting Officer, while Jonathan Bau contributes technical leadership with full-stack development and cybersecurity experience in cryptocurrency applications since 2017. The company successfully acquired US-based Kado Software in April 2025 to expand its North American operations. Business Model and Market Position Swapped operates as a cryptocurrency on-ramp/off-ramp payment processor, facilitating conversions between traditional fiat currencies and digital assets. The platform supports over 30 cryptocurrencies and 25+ fiat currencies through 40+ payment methods, targeting both retail consumers and merchant integration services. Market Context: The global crypto payment gateway market is experiencing rapid expansion, valued at $1.68 billion in 2025 and projected to reach $6.03 billion by 2035 at a 13.6% CAGR. However, the sector faces increasing regulatory scrutiny, particularly in the EU under the new MiCAR framework. Key Business Metrics MetricValueCompany NameSwapped.comFounded2021HeadquartersAarhus C, Denmark / St. Julians, MaltaLegal EntitySwapped ApSRegistration Number42865397CEO/Co-FounderThomas FranklinCTO/Co-FounderJonathan BauTotal Users1.5+ MillionCountries Supported150+Payment Methods40+Cryptocurrencies Supported30+Fiat Currencies25+Employees11-50Funding StageSeries ARegulatory Status – DenmarkDFSA Registered CASP under MiCARRegulatory Status – CanadaFINTRAC Registered MSBRegulatory Status – AustraliaASIC RegisteredKey Acquisition – 2025Kado Software (April 2025)Former NameBitinvestorLEI Code894500H8YU01P0Q0ST42Business ModelCrypto On-ramp/Off-ramp Payment Processor The company’s growth trajectory shows strong user acquisition, reaching 1.5 million users since its 2021 launch. However, this growth has occurred alongside significant compliance deficiencies that threaten sustainable operations. Regulatory Framework and Compliance Status Current Regulatory Authorizations Swapped maintains several regulatory registrations that position it within legitimate financial services frameworks: Denmark: Registered as a Crypto-Asset Service Provider (CASP) under MiCAR with the Danish Financial Supervisory Authority (DFSA) Canada: Registered Money Services Business (MSB) with FINTRAC Australia: Registered with ASIC for operations through a branch entity These registrations provide EU passporting rights under MiCAR, theoretically enabling compliant operations across European markets. Critical Compliance Failures Despite regulatory registrations, FinTelegram’s investigation reveals systemic compliance violations that undermine the company’s operational legitimacy: IssueDescriptionImpactGamdom IntegrationDeep integration with unlicensed crypto casinoHighIllegal Gambling FacilitationEnabling gambling in restricted EU jurisdictionsCriticalSpanish DGOJ SanctionsConnected to €5M fine against Gamdom operatorHighGerman GlüStV 2021 ViolationsFacilitating offshore gambling prohibited in GermanyHighUK/Italy Regulatory ViolationsSupporting restricted gambling activitiesHighTerms of Service EnforcementFailure to enforce prohibited activities clausesMediumMerchant MonitoringInadequate merchant onboarding and monitoringMediumAML/KYC Compliance GapsInsufficient compliance culture and oversightHigh The most significant concern involves Swapped‘s deep integration with Gamdom, an unlicensed crypto casino operating from Curaçao. This relationship violates multiple regulatory frameworks: Spanish DGOJ: Gamdom‘s operator Smein Hosting faces €5 million in fines for unlicensed activity German GlüStV 2021: Facilitates prohibited offshore gambling targeting German residents UK Gambling Commission: Enables unlicensed gambling activities in restricted markets Risk Assessment and Regulatory Exposure Multi-Jurisdictional Enforcement Risk Swapped‘s compliance failures expose the company to enforcement actions across multiple jurisdictions. The integration with unlicensed gambling platforms creates liability under various regulatory frameworks: AML/KYC Deficiencies: Despite claiming robust compliance procedures, the company’s merchant onboarding processes appear inadequate to prevent prohibited use cases. The Terms of Service explicitly prohibit unlawful gambling activities, yet enforcement mechanisms are demonstrably ineffective. Regulatory Contradiction: The company’s DFSA registration under MiCAR requires strict compliance with EU anti-money laundering directives, yet operational evidence suggests systematic violations of these requirements. Reputational and Operational Risks The public exposure of compliance failures creates cascading risks: Regulatory Action: Potential license revocation or suspension across multiple jurisdictions Banking Relationships: Financial institutions may terminate services due to reputational concerns Merchant Partners: Legitimate businesses may discontinue relationships to avoid compliance contamination User Base: Reputation damage may accelerate user attrition in competitive markets Market Position and Competitive Landscape Industry Context The crypto payment processing sector operates in an increasingly regulated environment. Market leaders maintain strict compliance standards to preserve regulatory relationships: Fee Comparison: Traditional payment processors charge 2.5-3.5% transaction fees. Swapped’s competitive positioning relies on transparency and low fees, with spreads varying by payment method. Regulatory Compliance: Legitimate players invest heavily in compliance infrastructure. Swapped’s failures suggest inadequate investment in regulatory compliance systems relative to business growth. Competitive Vulnerabilities Swapped’s compliance issues create significant competitive disadvantages: Regulatory Uncertainty: Compliance failures may restrict expansion into regulated markets Partnership Limitations: Legitimate financial institutions may avoid integration due to regulatory concerns Operational Constraints: Enforcement actions could disrupt core business operations Financial Analysis Revenue Model Assessment Swapped generates revenue through transaction spreads and fees across its payment processing services. The company’s 1.5 million user base represents significant transaction volume potential, but compliance violations threaten sustainable revenue generation. Growth Sustainability: The acquisition of Kado Software demonstrates expansion ambitions, but regulatory exposure may constrain sustainable growth opportunities. Cost Structure: Compliance failures suggest inadequate investment in regulatory infrastructure, potentially creating future remediation costs and regulatory penalties. Investment Recommendation Risk Rating: HIGH Swapped presents an unacceptable risk profile for institutional investment consideration: Systemic Compliance Failures: Deep integration with unlicensed gambling operations violates core regulatory requirements Multi-Jurisdictional Exposure: Potential enforcement actions across EU, UK, and other regulated markets Management Credibility: Leadership’s compliance background makes violations particularly concerning Operational Sustainability: Business model relies on relationships prohibited by regulatory framework Recommendation: AVOID – The company’s compliance violations create unacceptable regulatory and reputational risks that outweigh potential financial returns. Required Remediation Actions For Swapped to become investment-worthy, comprehensive remediation would require: Immediate Cessation: Terminate all relationships with unlicensed gambling platforms Compliance Overhaul: Implement robust merchant monitoring and KYC/AML procedures Regulatory Engagement: Proactive cooperation with supervisory authorities Management Accountability: Clear acknowledgment of failures and remediation commitment Third-Party Audit: Independent compliance assessment and ongoing monitoring Whistleblower Call to Action FinTelegram continues investigating compliance violations in the crypto payment processing sector. Industry insiders with relevant information about Swapped, Gamdom, or similar regulatory violations are encouraged to provide confidential information through the secure Whistle42 platform. Contact Information: Whistleblowers can safely submit information regarding financial crime and regulatory violations through Whistle42’s secure platform: https://whistle42.com Conclusion Swapped.com exemplifies the risks inherent in cryptocurrency payment processors that prioritize growth over compliance. While the company has achieved notable user acquisition and maintains legitimate regulatory registrations, systematic compliance failures create unacceptable investment risks. The case serves as a critical reminder that regulatory compliance cannot be treated as an afterthought in the evolving cryptocurrency sector. Investors must demand demonstrable compliance frameworks that match the regulatory complexity of digital asset businesses. Investment Verdict: The combination of systemic compliance failures, multi-jurisdictional regulatory exposure, and management credibility concerns makes Swapped unsuitable for investment consideration until comprehensive remediation is completed and independently verified. Share Information via Whistle42 This investor briefing is based on publicly available information and investigative reports. Investors should conduct independent due diligence and consult with qualified legal and financial advisors before making investment decisions.

Executive Summary Despite announcing strategic investments from industry giants Tether (December 2024) and Kraken (July 2025), StablR‘s stablecoin issuance has not only failed to grow but has actually declined during Q3 2025 – the same quarter Kraken announced its investment. This counterintuitive outcome reveals critical structural challenges facing small stablecoin issuers and provides a template for analyzing similar operations across the sector. Our quantitative analysis reveals that StablR requires €24 million in reserves at current ECB rates merely to achieve operational breakeven, while maintaining only €22 million. More concerning, the company’s reserves and token circulation decreased following major partnership announcements, suggesting fundamental business model dysfunction. Key Financial Metrics Summary MetricQ2 2025Sept 2025ChangeBreakeven RequiredEUR Reserves€13.2M€11.0M-16.7%€24.0MEURR Issued€12.8M€11.0M-14.1%€24.0MUSD Reserves~€11.0M€11.0MFlat€24.0MTotal Reserves€24.2M€22.0M-9.1%€48.0MEst. Annual Revenue€715K€715KFlat€780K+Operating Deficit€65K€65KUnsustainableBreak-even StablR Business Model Viability Analysis: Current Position vs Growth Scenarios Scenario Analysis: The Path to Viability Scenario 1: Conservative Growth (€50M Reserves) Likelihood: Moderate | Timeline: 12-24 months This scenario assumes StablR achieves modest market penetration and captures a small portion of EU stablecoin demand: Required Growth: 2.3x current reserves Profitability: €220K-€2.2M annually depending on interest rates Key Dependencies: Successful Turkey market expansion, improved exchange adoption Risk Factors: Competition from Circle’s EURC, regulatory headwinds from Payvision connections Scenario 2: Moderate Growth (€150M Reserves) Likelihood: Low | Timeline: 2-3 years This requires StablR to become a significant player in European stablecoin markets: Required Growth: 6.8x current reserves Profitability: €2.2M-€8.2M annually Key Dependencies: Major institutional adoption, successful cross-border payment partnerships Risk Factors: Established competitor dominance, management reputation issues Scenario 3: Aggressive Growth (€500M Reserves) Likelihood: Very Low | Timeline: 3-5 years This would position StablR as a major European stablecoin issuer: Required Growth: 22.7x current reserves Profitability: €9.2M-€29.2M annually Key Dependencies: Market disruption, regulatory preference for EU-based issuers Risk Factors: Winner-take-all market dynamics, technical/operational scaling challenges The Investment Paradox: Analyzing the Kraken-Tether Disconnect The Announcement vs. Reality Gap StablR‘s July 2025 announcement of Kraken‘s strategic investment emphasized remarkable growth metrics: “€3 billion in transaction volume” in H1 2025 “50+ major exchange listings” “150 trading pairs supported” “Rapidly expanded” since launching six months prior However, the proof-of-reserves data tells a starkly different story. Rather than growth acceleration following Kraken’s investment, Q3 2025 witnessed: 16.7% decline in EUR reserves 14.1% reduction in EURR token circulation 9.1% decrease in total reserves Possible Explanations for the Paradox Strategic Investments Were Overstated: The partnerships may involve technical collaboration, small equity stakes, or future commitments rather than immediate capital injection for growth. Market Rejection Despite Partnerships: Even with major backing, StablR may face adoption barriers due to management reputation (Payvision connections), competitive disadvantages, or product-market fit issues. Deliberate Reserve Management: The company may be intentionally managing reserves down while building alternative revenue streams or preparing for regulatory changes. Hidden Operational Issues: Undisclosed technical problems, compliance challenges, or internal management conflicts may be impeding growth despite external support. Broader Implications for Small Stablecoin Issuers The Structural Challenge Framework Our analysis establishes a framework for evaluating small stablecoin issuer viability: Critical Success Factors: Scale Threshold: Minimum €25-50M reserves for operational sustainability Interest Rate Sensitivity: 2-3x revenue impact across normal rate cycles Partnership Effectiveness: Strategic relationships must translate to measurable adoption Regulatory Positioning: MiCA compliance provides differentiation but increases costs Red Flag Indicators: Stagnant or declining reserves post-investment announcements High transaction volume claims without corresponding reserve growth Management connections to previous financial scandals Lack of transparent guidance or growth projections The Stablecoin Bubble Risk Assessment The disconnect between StablR’s partnership announcements and actual business performance reflects broader concerns about a potential stablecoin sector bubble: Valuation Inflation: Strategic investment announcements may create artificial market confidence Competition Compression: Winner-take-all dynamics favor established issuers with massive scale advantages Regulatory Arbitrage Limitations: MiCA compliance alone insufficient for competitive differentiation Interest Rate Dependency: Sector profitability tied to monetary policy cycles beyond issuer control Most Likely Scenario: Managed Decline or Acquisition Hypothesis: StablR will either voluntarily wind down operations within 12-18 months or be acquired by a larger player seeking EU regulatory infrastructure. Supporting Evidence: Mathematical impossibility of sustainable operations at current scale Declining reserves despite major partnership announcements Management reputational risks creating ongoing regulatory scrutiny Established competitors (Circle, Tether) with insurmountable scale advantages Alternative Outcomes: Pivot to B2B Services: Focus on payment processing, treasury management for crypto businesses Regulatory Asset Sale: License and infrastructure acquisition by major financial institution Merge with Competitor: Consolidation with another small EU stablecoin issuer Regulatory and Systemic Risk Implications The StablR case demonstrates why regulators consider stablecoins systemically important. Small issuers operating at sub-scale levels pose multiple risks: Consumer Protection: Token holders face potential total loss if the issuer becomes insolvent Market Integrity: Misleading growth narratives may distort market expectations Regulatory Credibility: EMI license failures could undermine MiCA framework legitimacy Financial Stability: Concentrated failure risk if multiple small issuers face similar challenges Call for Insider Information FinTelegram urgently seeks insider information regarding StablR’s operations through our secure whistleblower platform Whistle42.com. Priority Intelligence Requirements: Financial Performance: Internal P&L statements, cash flow projections, actual operational costs Partnership Details: True nature and terms of Tether/Kraken investments and ongoing relationships Strategic Planning: Management discussions regarding business model sustainability and exit strategies Operational Issues: Technical problems, compliance challenges, or regulatory correspondence Turkey Operations: Specific details of Turkish market strategy and performance metrics Reserve Management: Investment strategies, yield optimization, and custodial arrangements Protected Disclosures: Information regarding potential investor fraud, misleading public statements, regulatory violations, or connections to previous financial crimes will be handled with strict confidentiality protections. Submit Confidentially: Visit Whistle42.com to securely provide information that protects the public interest and ensures market integrity in the evolving stablecoin sector. 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By FinTelegram Editorial Desk Europe built instant, low‑cost payment rails—and accidentally created a paradise for cyber‑fraud. That’s the core message in a new academic paper by Elfriede Sixt, Chairwoman of EFRI and partner in the C42 project, who lays out a data‑driven indictment of today’s liability rules and a blueprint to fix them. Drawing on 1,750 victim cases across 20 countries (losses: €62.5m), Sixt shows how “authorised” push payments induced by deception remain largely unreimbursed, while even clearly unauthorised cases are inconsistently handled across Member States. The result is a double protection gap that erodes trust and rewards bad actors embedded in Europe’s payment stack. European Payment Rails What Sixt finds Europe’s “payment paradox.” Regulators modernised the rails (SEPA Instant & the 2024 Instant Payments Regulation), but consumer protection hasn’t kept pace. APP (authorised push‑payment) fraud shifted losses onto consumers, and redress is fragmented and slow. European Payment Rails Evidence at scale. EFRI’s dataset documents pig‑butchering/investment scams where most funds move via “authorised” transfers or CNP card payments; victims encounter denial, delay, and blame when they seek refunds. Psychological harm and trust loss are widespread, with 39% closing long‑standing bank relationships after the experience. European Payment Rails Gatekeeping failures in the rails. The same small circle of PSPs/acquirers/EMIs and certain banks repeatedly appear at the monetisation layer, onboarding high‑risk merchants, mis‑coding MCCs, and letting mule stacks run. This is contingent, not inevitable—many institutions don’t show these patterns, which supports shifting default liability to the actors best placed to prevent abuse. European Payment Rails Named case studies. Payvision (ING): processed high‑risk “investment” flows, including networks tied to Gal Barak/Uwe Lenhoff; internal figures attribute ~€154m CNP volume to the “Wolf of Sofia” group alone. European Payment Rails Wirecard: operated as a global fraud enabler before its collapse, legitimising illicit flows via acquiring units and subsidiaries. European Payment Rails Københavns Andelskasse (DK): pass‑through hub for scam proceeds; later fined DKK 794m for AML failures. European Payment Rails ADR that doesn’t redress. FIN‑NET and national ombuds schemes are obscure, uneven, and rarely binding; in EFRI’s cohort, no meaningful relief came through ADR. European Payment Rails Download the Research Paper here. What Sixt demands Sixt argues for outcome‑based reimbursement for all fraud‑induced payments—treat consent obtained through deception as no consent—and then align liability with functional control in the scam chain. Her blueprint includes: Reimbursement anchor at the payer’s ASPSP, with calibrated recourse down‑chain (beneficiary PSPs, acquirers, platforms, telcos). European Payment Rails Redefine “consent.” Fraud‑induced authorisations become unauthorised in law, triggering immediate refund rules. European Payment Rails FIN‑NET 2.0 (binding EU‑level ADR) with deadlines, presumptions, and disclosure so victims aren’t re‑victimised. European Payment Rails EU Fraud Data Framework to close opacity gaps and surface cross‑institutional risk signals (mules, layering, MCC camouflage). European Payment Rails Technology duties for PSPs and platforms: name/IBAN checks (CoP/VoP), real‑time analytics, kill‑switches, cross‑sector intel sharing. European Payment Rails The legislative moment: PSR Article 59 is not enough Europe’s Payment Services Regulation (PSR) is the vehicle to fix the gap. Parliament’s 2024 stance broadened coverage and explored shared, cross‑sector liability (PSPs, ECSPs, platforms). But the Council’s 18 June 2025 “General Approach” retreats to a narrow trigger—refunds only if the fraudster impersonated the consumer’s PSP (“bank spoofing”)—with a 15‑business‑day refund clock. That leaves most induced‑consent scams (fake tax, police, brand, marketplace) out of scope and keeps platforms/telcos largely off the hook. Sixt’s view: two PSR landings are realistic, but only the broader reimbursement model aligns incentives across the scam chain and restores trust. Otherwise, Europe cements an equilibrium that rewards institutions and harms consumers. European Payment Rails Why this matters now for cyberfinance: illegal casinos & crypto The paper’s lens on MLaaS (Money‑Laundering‑as‑a‑Service) explains why illegal online casinos and unlicensed crypto platforms keep thriving: they rely on regulated on/off‑ramps—acquirers, PSPs, EMIs, beneficiary banks, and exchanges—to collect, layer, and cash‑out at scale. Where onboarding/monitoring is weak (or willfully blind), these actors become financial crime enablers. Tightening KYCC/EDD, MCC governance, inbound risk‑scoring, mule controls, and beneficiary‑side holds/recalls is essential—and must be backed by default liability so the least‑cost avoiders actually invest in prevention. European Payment Rails Crypto‑native rails don’t sit outside this: scam funds frequently bridge to EMIs/banks for monetisation. Without outcome‑based reimbursement and binding ADR, victims of crypto‑themed pig‑butchering and casino funnels will keep absorbing losses while intermediaries capture fees.

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

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

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