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

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

Several independent FinTelegram tests in different EU jurisdictions confirm that EU residents can fund, swap, and trade Perps on Hyperliquid without KYC, geo‑blocking, or deposit limits. Funds were deposited from cold wallets (Ledger), ETH was swapped to USDC on the spot market, and Perps were opened using USDC—all anonymously. Key findings (new evidence) EU onboarding with zero KYC: From different EU jurisdictions, testers connected wallets and used Hyperliquid’s interface without any identity checks, residency prompts, or geo‑blocks. Cold‑wallet funding: ETH was sent directly from Ledger (no MetaMask relay required) to a Hyperliquid deposit address; no onboarding or limits were encountered. Spot swap to USDC (sale of ETH): The deposited ETH → USDC conversion on Hyperliquid’s Spot market executed seamlessly, establishing USDC balances. Perps opened with USDC: With USDC as trading currency, perpetual futures (perps) were opened and managed without KYC. No deposit caps detected: Across both tests, no explicit deposit limits were shown or enforced. Interface behaviour unchanged: The prior flows we documented (wallet connect → ApproveAgent → accept terms) remain available to EU IPs. Why this matters (compliance lens) Perps = derivatives. In the EU, perpetual futures are MiFID II financial instruments when provided to EU clients. If a venue admits EU residents to perps, investment‑services authorisations are ordinarily required (venue/market‑maker side). Anonymity escalates risk. Absence of KYC/appropriateness and EU gating is inconsistent with MiFID II norms (client protections, market integrity, AML/CFT expectations via the authorised channel). Spot doesn’t sanitize perps. Even if spot crypto‑to‑crypto sits within MiCA/CASP concepts, listing/access to perps for EU clients triggers the MiFID II perimeter for the provider. Pattern now replicated. Two EU jurisdictions (Italy & Austria) produced the same result—strengthening the factual basis. What we observed on‑platform (concise) Deposit: ETH from Ledger into Hyperliquid deposit flow (no KYC). Spot: ETH sold for USDC on Hyperliquid Spot (trade executed). Perps: USDC used to open Perps (order ticket live; trades placed). Controls: No geo‑block, residency selection, KYC, or deposit caps encountered. Editorial analysis (strong view) Hyperliquid presents itself as a permissionless venue while functioning—de facto—for EU residents as a derivatives platform with no EU perimeter controls. In a post‑MiCA Europe increasingly aligning to MiFID II for derivatives, this posture looks less like innovation and more like a repeat of the “grow first, fix later” playbook we saw in earlier cycles. Scale doesn’t outrun jurisdiction. Updated right‑to‑reply (for Hyperliquid) Do you exclude EU/EEA/UK residents from Perps? If so, where are the effective controls (IP gating, residency attestation, KYC)? On what basis do you allow anonymous deposits/trading (including Ledger‑funded flows) for users connecting from EU IPs? Why does the Restricted Persons list in your Terms omit EU/EEA/UK while perps are available through your UI? Do you rely on reverse solicitation for EU users? If so, what evidence do you maintain, and how do you prevent indirect solicitation via affiliates/influencers? Have you engaged any EU NCA regarding your EU access posture for perpetual futures? Evidence pack (on file) Several test runs: different EU jurisdictions, different IP addresses Flow artifacts: wallet connect prompts, ApproveAgent signature, deposit confirmations, spot ETH→USDC fills, Perps order tickets/executions Hashing & timestamps: screenshots/recordings with SHA‑256 hashes; environment details (IP geolocation, time, network) Terms snapshot: current Terms of Use (showing US/Ontario/sanctions only; no EU exclusion) Risk signals for readers Regulatory: Potential exposure for unauthorised investment services if EU clients are admitted to perps. Operational: Possible sudden changes—account restrictions, position closure, or access blocks if/when enforcement tightens. Consumer: No MiFID II investor‑protection framework for these trades. Next steps (FinTelegram) Send right‑to‑reply with a 72‑hour response window; publish reply verbatim or note no comment. Continue access monitoring from multiple EU ISPs; log any control changes (geo‑fencing/KYC prompts). Prepare a short comparative matrix (Hyperliquid vs. EU‑authorised venues): KYC, onboarding, derivatives permissions, market surveillance. Share Information via Whistle42

New documents and emails allege that Martin Wittig—Kühne + Nagel board member and ex-Roland Berger boss—pocketed a hidden CHF 1.59 million commission from a Signa unit after introducing Klaus-Michael Kühne to René Benko in 2019. Kühne, who ultimately poured ~€500 million into Signa Prime, now says he was “betrayed”—by Benko and by his confidant—while writing off the investment amid Signa’s collapse and Benko’s pre-trial detention. Wittig says Kühne had not been informed and announced his immediate resignation from corporate mandates (Sources: News.at,spiegel.de). Key Points The “door-opener”: Emails show Wittig arranging the Benko–Kühne meeting in Feb 2019, praising Benko and flagging Hamburg real-estate angles (Source: News.at). Secret commission: A Swiss Signa entity formalized a consulting deal; mcw Management Services AG invoiced CHF 1.59m + VAT for mediating Kühne’s Signa Prime share purchase; two-thirds paid immediately, the rest due end-2020. Half-billion exposure: Kühne’s group invested ~€500m in Signa Prime and later sought to unwind after a dramatic break in Dec 2022; losses now in the hundreds of millions. “Ganove” moment: In May 2025, Kühne publicly blasted Benko as a “Ganove ersten Ranges” and admitted he hadn’t seen through the structure. Mandate fallout: Wittig expressed regret for not informing Kühne and resigned with immediate effect from roles at Kühne + Nagel (and Aenova) (Source: Inside Paradeplatz). Short Narrative If Signa was a machine, networking was its motor. In 2019, Wittig—ex-Roland Berger chief, Honorary German Consul in Switzerland, and a Kühne + Nagel director—opened the door to Klaus-Michael Kühne, Germany’s richest man. According to NEWS’s documents, the introduction was followed by a quiet consulting contract routed via a Swiss Signa subsidiary. The fee: CHF 1.59 million. Kühne then committed ~€500 million to Signa Prime—only to watch the empire unravel, Benko jailed, and the investment torched. Feeling double-crossed, Kühne turned on both Benko and his confidant. Wittig, acknowledging non-disclosure to Kühne, stepped down (Sources: News.at,spiegel.de). Compliance & Regulatory Angle (Why this matters) Undisclosed conflict risk: A sitting director at a major listed logistics firm receiving counterparty-side compensation related to his principal’s deal is a classic conflict-of-interest scenario with potential corporate-governance and fiduciary-duty implications (jurisdiction-specific). The lack of disclosure to the principal—as reported—magnifies risk (Source: News.at). Possible legal exposure (to be assessed): Depending on facts and venues (DE/CH/AT), investigators could examine breach of trust, commercial bribery/undue advantage in business transactions, or market-integrity issues. (No allegations of formal charges on these points at time of writing.) Asset-tracing vector: The commission trail (contract, invoices, UBS payments) is an evidence spine for transaction forensics across Swiss and Austrian entities if recovery claims are pursued. What’s New vs. Prior FinTelegram Coverage FinTelegram has chronicled Signa’s political and corporate enabling structures—from Austrian political facilitators to opaque foundation and network layers. The Wittig commission adds a clean, document-backed example of how introductions were monetized around Signa’s capital raises, strengthening our thesis that “network engineering” was as important as property economics in the Signa story. (See our earlier Benko/WEC/insider-network reports.) Actionable Insight (for investors, boards, prosecutors) Board-level review: Where a director intermediates major transactions, mandate ex-ante disclosure and third-party pay audit; require side-letter attestations that no third-party compensation exists. Forensics kit: Subpoena contract originals, invoice chains, bank credits (UBS), and email metadata (Feb 2019–Dec 2022). Match flows against Signa Prime allocations and Kühne Holding entries. Civil recovery options: Explore recission/claim avenues tied to non-disclosed inducements; map choice-of-law & venue (CH/AT/DE). Market hygiene: Listed-company policies should ban counterparty-paid “success fees” to sitting directors without full board disclosure and approval. Call for Information (Whistleblowers) Were you involved in Signa Prime placements, consulting contracts with Signa Financial Services AG or Swiss Signa units, or Kühne Holding deal teams from 2019–2022? Do you hold consulting agreements, invoice PDFs, payment advices, or email threads referencing Wittig, Benko, or intermediary fees? Contact FinTelegram / Whistle42 securely. (Presumption of innocence applies.) Share Information via Whistle42

Vienna, September 5, 2025 — Austria’s anti-corruption prosecutors (WKStA) have filed the first criminal charges in the sprawling LNR affair: real-estate developer Lukas Neugebauer is indicted for fraudulent bankruptcy (betrügerische Krida, §156 StGB) over luxury spending after his personal insolvency began. The case—modest in sum but maximal in signal—lands amid the wreckage of Austria’s real-estate bubble and two marquee collapses: René Benko’s Signa empire and the fresh insolvency of Klemens Hallmann, long styled a “billionaire” investor. The Charge: Luxuries While Insolvent According to the WKStA press release, prosecutors allege that in October–December 2024—after his private bankruptcy opened—Neugebauer spent ~€145,000 on luxury travel, high-end shopping and nightlife, thereby diminishing creditor recovery. The indictment was lodged with the Vienna Regional Criminal Court. Total claims in his personal case now stand around €147.35 million, Austrian media report. Maximum penalty: up to five years’ imprisonment. Neugebauer denies wrongdoing. Why this matters: This is the first formal criminal step in the LNR complex. Investigations reportedly still span about ten natural persons and entities on broader suspicions, including fraud and breach of trust. The new filing shows prosecutors are now moving from investigation to litigation. Austria’s “Over-Financing” Era Comes Due From roughly 2015–2022, Austria was ground zero for leveraged real-estate plays: ECB policy rates near zero, a flood of bank credit, and a double-digit overvaluation signal from the Austrian central bank (OeNB). When the ECB hiked ~450 bps from mid-2022, financing costs surged, deals froze and valuations cracked—exactly the risk path the IMF had warned about (Sources: European Central Bank+1,OeNBIMF). Price dynamics: After years of sharp gains, Austrian residential prices fell in 2023–24; 2024 ended roughly flat to slightly down, confirming a turn in the cycle (Sources: STATISTIK AUSTRIA,globalpropertyguide.com). Policy admonition: IMF 2025 urges Austria to lock in stricter borrower-based rules as permanent tools to counter lax underwriting—the very fuel of “over-financing” (Sources: IMF). FinCrime angle: In such liquidity waves, “chain transactions” (rapid resales at step-up prices inside tight networks) and “over-financing” (high LTVs against optimistic valuations) create fertile ground for bank-fraud typologies—precisely the patterns Austrian media and investigators have long associated with Neugebauer’s LNR network and peers. The WKStA’s new case signals a broader shift from supervisory reports to criminal accountability. Benchmarks: Benko and Hallmann René Benko / Signa Group Status: Benko faces criminal proceedings tied to the Signa collapse. Austrian courts ordered pre-trial detention earlier this year; among the reasons cited: risk of reoffending and high criminal energy. Political ties: Former Chancellor Alfred Gusenbauer served as supervisory board chairman of Signa Prime and Signa Development and sat on Signa’s advisory structures. He has since stepped back; recent reports say Benko described Gusenbauer as “deeply involved” in restructuring phases—allegations disputed in public debate. Ex-Chancellor Sebastian Kurz maintained close relations with Benko (documented contacts, events, and discussions reported in Austria’s press). These ties are politically sensitive but not, per se, crimes (Sources: Reuters,SWI swissinfo.ch,News.at,n-tv.de). Read our reports on Rene Benko here. Klemens Hallmann Status: In August 2025, Hallmann entered insolvency proceedings (sanierungsverfahren mit Eigenverwaltung) in Vienna—creditor claims around €95 million; his holding says group entities are unaffected. The move followed stress at affiliates including SÜBA AG (insolvent in April, later a 20% plan) (Sources: ksv.at,trend.at,AKV EUROPA). Comparative enforcement: Benko: Custodial measures based on flight/collusion/reoffending risk and the case’s systemic gravity. Neugebauer: Indicted but not remanded; no court has publicly imposed custody to date. Prosecutors began with a targeted Krida count focused on post-insolvency dissipation—potentially the fastest-proving slice of a larger financial-crime mosaic. Read our reports on Neugebauer here. What the Neugebauer Indictment Signals to Banks Austria’s lenders are again in the spotlight. The IMF has urged tighter underwriting and vigilant supervision as the boom-era residue works through balance sheets. If the LNR file ultimately broadens into over-financing and chain-transaction counts, banks could face uncomfortable questions: Why were valuation jumps funded so readily? Were red flags (related-party flips, thin equity, inflated “comps”) ignored? Today’s Krida charge sets a precedent: post-insolvency spending is low-hanging fruit; the next layer could be financing conduct around the bubble’s peak. Key Facts at a Glance Defendant: Lukas Neugebauer, real-estate developer (LNR group). Charge: Betrügerische Krida (§156 StGB) — post-insolvency dissipation (~€145k). Claims in personal insolvency: ~€147.35 million (media). Custody: None reported for Neugebauer; Benko remains the benchmark case for remand severity in Austria’s real-estate bust. Macro backdrop: ECB hikes ~450 bps since 2022; Austria’s housing prices stalled/declined in 2023–24 after years of rapid gains. IMF urges permanent borrower-based rules (Sources: European Central Bank,STATISTIK AUSTRIA,IMF). Parallel collapse: Klemens Hallmann entered insolvency in Aug-2025; ~€95m in claims, 102 creditors (Sources: ksv.attrend.at). FinCrime Observer View Signal > size. €145k of Krida-spending is small in a sea of nine-digit claims—but it’s prosecutable now and cracks open court scrutiny of LNR cashflows. Expect further filings if evidence on over-financing, sham flips, or asset shifting matures. Austria as a case study. Nowhere in Europe did low-rate fuel, bank enthusiasm, and political proximity to developers combine so potently as in Austria’s pre-2022 cycle. The Benko remand set a tone; the Neugebauer indictment should keep momentum from stalling. Compliance takeaway. Banks and funds with historical Austrian exposure should re-review 2019–2022 vintages for chain-sale uplift, insider counterparties, and thin-equity financings. Align with IMF guidance on borrower-based limits and enhance related-party analytics (Sources: IMF). Sources & Further Reading WKStA press release (Sept 5, 2025) — Indictment of real-estate entrepreneur for fraudulent bankruptcy in LNR case. ORF Wien — WKStA indicts Neugebauer for “betrügerische Krida”; luxury spending after insolvency. OeNB / Statistik Austria — Property price indices; overvaluation and 2023–24 correction. OeNBSTATISTIK AUSTRIA ECB — Hike cycle since 2022 (~450 bps). European Central Bank IMF 2025 Article IV (Austria) — Make mortgage underwriting limits permanent; tighten supervision. IMF Benko pre-trial detention — Austrian court grounds include risk of reoffending and high criminal energy. Gusenbauer roles at Signa; debate on involvement — Reuters; subsequent reporting. Reuters Hallmann insolvency — KSV1870 / AKV Europa; trend; Puls24. ksv.atAKV EUROPAtrend.atpuls24.at Call for Information FinTelegram is turning the Neugebauer/LNR case international to keep sunlight on Austria’s post-bubble clean-up. If you have documents, term sheets, valuation reports, lender memos, or correspondence related to over-financing, chain transactions, or asset transfers in the LNR orbit—or in connected networks (Signa, Hallmann)—contact us securely. Your information can help determine whether Austria is finally ending an era of impunity in real-estate finance. Share Information via Whistle42

Perpetual futures (perps) on DEXs may be branded as “permissionless,” but in the EU they don’t live outside the law. When derivatives are offered to EU clients, they generally fall under MiFID II—licences, conduct rules, surveillance, the lot [2]. In our latest field test from Italy, we connected a wallet to Hyperliquid, accepted its terms, and reached Spot and Perps—with no EU geo-gate, no residency question, and no KYC (see case study details below). Hyperliquid’s own Terms (26 Jan 2025) restrict the U.S., Ontario, and sanctioned regions—but not the EU [8]. That is not a theoretical nuance; it’s a live compliance risk given how EU regulators view crypto-derivatives [2][5]. Executive summary Derivatives in the EU: Crypto perps are generally treated as MiFID II financial instruments when provided to EU clients; if a venue or its market makers address or onboard EU users, MiFID II investment-services authorisations (or an authorised distribution route) are expected [2]. MiCA vs. MiFID II: MiCA covers crypto-assets that are not financial instruments (e.g., many utility/program tokens that avoid backing/pegs/dividends) [1]. But derivatives on such tokens push the activity into MiFID II for the provider serving EU clients [2][4]. NCA posture: Multiple European regulators have stated that cash-settled crypto derivatives require authorisation, and have warned that reverse solicitation is narrow and not a backdoor into the EU [5][3]. Our Hyperliquid test: From an EU IP (Italy), we connected a wallet, signed “ApproveAgent,” saw the Deposit modal for Spot & Perps, and accepted the Terms—all without EU-specific controls; Hyperliquid’s Terms omit EU/EEA/UK from the “Restricted Persons” definition and shift legality to users [8]. This pattern elevates MiFID II exposure if EU clients are being admitted and serviced [2][5]. The legal split (plain English) MiCA (token/program side): If a token avoids pegs, backing, and dividends, it can remain a crypto-asset other than ART/EMT; issuers/CASPs then fall under MiCA rather than MiFID II [1]. MiFID II (derivative side): A perpetual future (even on a crypto index) is typically a derivative and thus a financial instrument; firms serving EU clients must hold the relevant authorisations and meet conduct/market-abuse duties [2]. Interpretation: It’s not the “decentralised front-end” label that decides the perimeter; it’s the provision of an investment service to EU users [2]. What NCAs actually look for Authorisation trigger: Are EU clients being addressed, onboarded, or serviced in derivatives? If yes, the activity is MiFID II in-scope [2][5]. Reverse solicitation (RS): RS is strict and narrow; any EU-facing promotion (ads, affiliates, influencers, local-language funnels) or a pattern of EU client business undermines it. Firms must keep evidence that each EU relationship was exclusively client-initiated [3]. Interpretation: “We don’t market to the EU” is not persuasive if EU users can seamlessly trade perps via the official interface [3]. Case study: Hyperliquid (as tested by FinTelegram) Observed behaviour from Italy (EU): Wallet connect to app.hyperliquid.xyz with MetaMask → “ApproveAgent” signature (standard trading-agent approval). Deposit modal for ETH showing Spot and Perps functionality available. Terms acceptance signature → no residency question, no EU geo-gate, no KYC before perps features became accessible.(We have preserved screenshots and hashes on file.) Terms highlights (26 Jan 2025): §1.5 “Restricted Persons”: U.S., Ontario, and sanctioned jurisdictions only—no EU/EEA/UK restriction [8]. §1.6: Shifts responsibility to the user to ensure compliance with local leveraged/derivative rules [8]. §3.1.5: Bans circumvention (VPN/proxy), but this is a weak control where EU access is not explicitly restricted [8]. §5 Programs: Promotions could constitute solicitation if available to EU users [8][3]. Interpretation: For the EU perimeter, this combination—frictionless access to perps for EU users, no explicit EU exclusion in the Terms, and responsibility shifted to users—is exactly the pattern European supervisors scrutinise [2][3][5]. A tougher question for a market leader Hyperliquid positions itself as a premier perps venue. With that status comes responsibility. Our test suggests EU users can reach perps without EU-specific controls, and the Terms omit EU/EEA/UK from the restricted list [8]. How is that compatible with the MiFID II framework that other players—centralised and decentralised—are now building toward [2][5]? This posture is uncomfortably reminiscent of Binance’s early “grow first, fix later” era: global scaling with ambiguous perimeter controls, followed by a multi-year regulatory reckoning. The lesson from that period is clear: scale doesn’t outrun jurisdiction. Compliance analysis (our view) If a venue admits EU users to perps without EU authorisation (or a compliant EU distribution route), an NCA could deem this unauthorised investment services [2][5]. Hyperliquid’s Terms and our EU access test together heighten this risk [8]. Only a competent authority can determine a breach; however, the fact pattern is consistent with MiFID II-in-scope activity [2][5]. Enforcement vectors & user risk Regulatory tools: warnings, domain measures, orders to block access, actions against EU-facing promotions; cross-border coordination via ESMA [3][5]. User impact: abrupt off-boarding, position restrictions, or loss of EU recourse (no MiFID II investor-protection regime) [2]. Market integrity: authorised venues run surveillance/halts; permissionless UIs rarely meet that standard [2]. Recommendations For venues/market makers Add EEA/UK to Restricted Persons; enforce IP geofencing, residency attestations, and KYC for derivatives modules [2][3]. Insert a Marketing & Solicitation clause: no perps solicitation in EEA/UK; restrict Programs by geography [3]. Keep logs and audits; implement an incident playbook for regulator queries. For token issuers/projects Keep the token and index/oracle MiCA-safe (no pegs/backing/dividends; methodology-first comms) [1]. License Index IP only to venues that geofence the EU or hold MiFID II/UK permissions; include audit & takedown rights [2][3]. For investigators/editors Preserve screenshots/videos and hashes; archive Terms/Privacy/Programs and capture network logs. Offer a right-to-reply (EU exclusion controls? reliance on EU permissions? RS records?) [3]. Conclusion “Permissionless” is not permission-free in Europe. MiCA can cover your utility token if you avoid pegs, backing, and dividends [1]; the moment you provide EU clients with a perpetual future, you’re in MiFID II [2]. That moves obligations to the venue and its market makers: licensing, client protections, market integrity. Our test shows that a market leader—Hyperliquid—appears to allow EU access to perps without EU-specific controls, while its Terms omit EU restrictions and push legality onto users [8]. That is not sustainable in a post-MiCA, MiFID-aware Europe. The industry has a choice: professionalise distribution or invite another Binance-style reckoning. Sources & References [1] Regulation (EU) 2023/1114 (MiCA) — Markets in Crypto-assets; establishes EU framework for crypto-assets that are not financial instruments and for tokens other than ART/EMT (scope/exclusions).[2] Directive 2014/65/EU (MiFID II) — esp. Annex I, Section C on financial instruments (derivatives); triggers authorisation, conduct, and market-abuse regimes when provided to EU clients.[3] ESMA — Final Report: Guidelines on Reverse Solicitation under MiCA (Dec 2024) — clarifies RS is strict and narrow; direct/indirect marketing into the EU defeats it; record-keeping expectations.[4] ESMA — Final Report: Guidelines on conditions/criteria for the qualification of crypto-assets as financial instruments (Dec 2024) — “classification by substance”; if a token is a financial instrument, MiFID II applies, not MiCA.[5] AMF (France), Analysis of the legal qualification of cryptocurrency derivatives (Mar 2018) — early NCA view that crypto-derivatives are financial instruments; authorisation/advertising limits apply.[6] AMF — MiCA explainer (Nov 2024) — reiterates that crypto-assets qualifying as financial instruments are outside MiCA and within existing regimes (MiFID II).[7] BaFin (Germany), MiCAR/MiFID materials (overview pages) — confirms case-by-case classification; tokens can be financial instruments under national/MiFID II rules.[8] Hyperliquid — Terms of Use (Last updated 26 Jan 2025) — §1.5 (Restricted Persons: US/Ontario/sanctioned—no EU); §1.6 (user responsible for local derivative laws); §3.1.5 (VPN/proxy ban); §5 (Programs). Note: We have preserved the Hyperliquid Terms text provided to FinTelegram, plus screenshots and SHA-256 hashes from the Italy-based access test (on file). Share Information via Whistle42

FinTelegram’s investor briefing finds Brex, the Peter Thiel-backed fintech, at a critical juncture: poised for IPO, surging with European expansion, and executing a disciplined path to profitability, making it far more than a typical Silicon Valley growth story. Strategic Positioning Brex, specializing in corporate credit cards and spend management, is now licensed to operate across the EU, removing prior barriers and eyeing the UK next. This direct access opens a market that could add up to $5 billion in annual revenue opportunities, further elevating Brex’s global footprint and reinforcing its role as a fintech disruptor. While EU banking and bill pay are not immediately available, the company’s expansion enables European startups—often underserved by traditional banks—to adopt Brex’s products at scale, differentiating its value proposition as fintech incumbents remain regionally siloed. Financial Highlights Brex is targeting $500 million in annual net revenue for 2025, with a stated goal to reach positive cash flow by year-end: both are prerequisites the company’s leadership insists must be met before an IPO is launched. The transformation is especially notable given Brex’s rocky 2023, when layoffs and high cash burn rates put future prospects in doubt. Since then, cost management initiatives and product innovation—including AI-powered spend solutions and quarterly feature releases—have reversed cash burn by nearly 70%, while enterprise business grew over 90% in 2024. Competitive Landscape Brex’s maturation comes amid fierce competition. U.S. rivals Ramp and Mercury have set aggressive funding and valuation records, while Brex, after its $12.3 billion Series D-2 round in 2022, pivoted to debt facilities to finance its growth rather than further diluting equity. The company stands out for its ability to attract top-tier enterprise clients (Robinhood, Anthropic, Arm) and 150+ publicly traded customers. For investors, this signals enduring market demand, vital as fintech valuations recalibrate post-2022. IPO Outlook FinTelegram notes Brex’s leadership is methodical: the IPO timeline is contingent on sustained profitability and revenue goals, likely in late 2025 or early 2026. Unlike peers rushing to capitalize on favorable market windows, Brex seeks to demonstrate stable, recurring profitability—a stance that should command investor respect and higher multiples. Investment Opinion From FinTelegram’s vantage point, Brex’s prudent cash management, unique global access, and enterprise client traction suggest it’s on track to be one of the most compelling fintech IPOs in recent years. Risks remain: ongoing execution in new markets, integration of additional financial products, and macroeconomic volatility. Yet, the combination of operational discipline and high-reward expansion makes Brex’s upcoming IPO likely worth close attention for growth-oriented investors. Summary Table Aspect2025 Targets / StatusEU Market AccessLicensed, all 30 countries; UK in pipeline Revenue Goal$500M net revenue Profitability TargetCash-flow positive by year-end Recent Financing$260M debt, $12.3B Series D-2 (2022) Product InnovationAI spend management, quarterly feature releases Enterprise Growth>90% in 2024, 150+ listed firms on platform IPO TimelineEarliest late 2025/early 2026, post-profitability Brex stands ready to transform the fintech public market narrative, not just with hype—but with substance and strategic edge. Share Information via Whistle42.

This piece of investor education is part of our FinTelegram DeFi Series. Hyperliquid has consolidated a commanding lead in decentralized perpetuals with record revenues and market share, while newcomer Lighter is courting traders with a zk-rollup CLOB, zero-fee retail, and an HLP-style liquidity vault. Is this the next serious challenger—or just incentive-driven beta hype? (Sources: Yahoo Finanzen,The Block,Hyperliquid Docs,Lighter Docs) Key points Hyperliquid = current market leader: August revenue ~$106–110M; ~70–80% share of DeFi perps volume depending on methodology; multi-trillion cumulative perp volume (Sources: Yahoo Finanzen,The Block,defillama.com). HYPE & HLP flywheel: Token airdrop + community-owned HLP market-making vault underpin depth, uptime, and CEX-like execution (Sources: Blockchain News,Hyperliquid Docs). Lighter’s pitch: zk-rollup with verifiable matching/liquidations, CLOB UX, zero fees for retail, and an LLP market-making vault (Hyperliquid-like). Still in/just leaving closed beta (Sources: Lighter Docs,Benzinga). Early metrics & caveats: ~56k users, ~$300–340M TVL; eye-catching daily volumes but an unusually high volume/open-interest ratio signals heavy incentives or wash-trading risk during beta (Source: Benzinga) Market snapshot (as of 5 Sep 2025) Hyperliquid: 30-day perp volume ~$387B; OI ~$11.9B; cumulative perp volume >$2.5T. Market cap (HYPE) ~$12B (FDV ~ $45B) (Sources: defillama.com). Revenue momentum: August revenue reported ~$106M and higher; multiple outlets note leadership in DeFi perps share (Sources: Yahoo Finanzen,thecurrencyanalytics.com). Lighter: Private beta began Jan; public rollout this month; ~56k users, TVL ~$340M (per DefiLlama references), points program live (Sources: Benzinga,Lighter Docs). Why Hyperliquid leads Depth + reliability: Community-owned HLP vault market-makes and backstops liquidations; onchain governance routes fees to HLP and an assistance fund—no “insider fee siphon.” This has produced tight spreads and resilience under stress (Sources: Hyperliquid Docs,Medium). Tokenization loop: The HYPE airdrop (late-2024/early-2025 seasons) catalyzed growth; the platform has sustained activity beyond airdrop euphoria—rare in DeFi (Sources: Blockchain News,airdrops.io). Scale effects: Leadership compounds liquidity: better fills beget more traders, reinforcing market share. Recent data shows Hyperliquid chipping away even at Binance’s derivatives dominance (ratios are creeping up) (Source: The Block). What Lighter is doing differently zk-CLOB verification: Lighter says it zk-proves the full trade-execution path (not just end balances), aiming for CEX-grade performance with onchain verifiability (Source: Benzinga). Retail zero-fee: Aggressive go-to-market—fee-free retail trading plus a points program that also controls how much capital users can allocate to the LLP vault (Sources: Lighter Docs,Airdroplet.com). LLP as margin (planned): Post-beta, Lighter plans to let traders use LLP deposits as margin, simultaneously earning yield and trading—functionality most perp DEXs (including Hyperliquid) don’t offer natively today (Sources: Benzinga). The red flags & reality checks Incentive distortion: Analysts flagged Lighter’s volume/open-interest ratio (e.g., ~27 vs. HL ~0.76), a classic marker of incentive-amplified churn. Numbers often reset once points end or fees normalize. (Source cites K33 commentary.) Beta ≠ battle-tested: Closed-beta stats can mask slippage/outage behavior in true stress events. Hyperliquid’s edge in “extreme piles” scenarios is a frequent trader refrain. VC vs. community: Lighter touts a16z/Lightspeed backing; that can speed product, but token design, unlocks, and fee routing will determine if liquidity is durable or mercenary. Regulatory & risk angle (FinTelegram lens) Perps are derivatives: In the EU, CASP/MiCA perimeter is tightening around leveraged crypto derivatives; DEXs operating via smart contracts still face on-ramps/off-ramps and market-making scrutiny, especially where retail access, leverage, and promotional incentives intersect. (We’ll continue monitoring ESMA guidance changes as they roll through 2025–26.) (General context; watch for enforcement rather than headline bans.) Market integrity: Points/airdrop seasons can inflate “headline volumes.” For investor-protection narratives, OI, depth on non-majors, realized fees, and slippage under volatility are better quality signals than raw daily volume. Our take Base case: Hyperliquid stays #1 near term; its HLP + execution reliability + already-won network effects keep it the default venue for serious perp flow. Challenger case: Lighter could carve out a 10–20% niche if it ships LLP-as-margin, keeps zero-fee retail (or smart fee routing), and proves zk-CLOB advantages in live volatility. But beta-era metrics likely compress post-incentives. Actionable signals to track (dashboard checklist) Hyperliquid: HLP APY/net PnL trend; outage/latency incidents; per-pair depth on mid/long-tail assets. Lighter: Transition from beta → public; persistent OI/volume normalization; LLP utilization caps tied to points; execution quality in volatile windows. Cross-venue: Share vs. Binance perps over time; revenue persistence after incentives. Share Information via Whistle42

What Are Crypto Perpetual Contracts (“Perps”)? Crypto perps (short for Perpetual Futures) are a type of derivative (financial instrument) that lets traders speculate on the price of an underlying asset (such as Bitcoin, Ethereum, or other cryptocurrencies) without ever owning the asset itself. Unlike traditional futures contracts, which always have a set expiry date, perps are open-ended—they can be held indefinitely, provided margin requirements are met (Sources: Coinbase, Kraken, Gemini) How Do Perps Work? When trading a perp, there are always two sides: The long (betting on the price going up) The short (betting on the price going down) The position size is usually much larger than your actual collateral, thanks to leverage. If the price moves in your favor, the profit can be significant—but losses can be equally large if the market turns against you. Funding Rate To keep the price of perps close to the real spot price, the market uses a mechanism called the funding rate: If the perp trades above the spot price, long traders pay shorts. If it trades below the spot, shorts pay longs. These payments typically happen every few hours and incentivize traders to keep the perp price close to the spot price. Where Can You Trade Perps? (CEXs vs DEXs) Centralized Exchanges (CEXs) Perps were first launched on centralized platforms like BitMEX, Binance, Bybit, Kraken, and Coinbase. CEXs are custodial: funds stay on the exchange while open positions are managed. Usually provide deep liquidity, fast matching, multiple assets, and regulated environments (but may require KYC). Decentralized Exchanges (DEXs) Decentralized perpetual DEXs such as dYdX, GMX, and Drift enable traders to: Trade perps fully non-custodially: funds remain in the trader’s wallet; all trades are executed by smart contracts. Enjoy permissionless access and greater privacy, but may experience less liquidity and higher on-chain costs. Leverage: Power and Peril Leverage means controlling a position worth more than your deposited margin. For example, with $20,000 and 10x leverage, you can open a $200,000 position. For every 1% the market moves against you, you lose 10% of your margin. A 10% adverse move will fully liquidate your position. Initial margin: Capital required to open a position. Maintenance margin: Minimum remaining capital needed to keep the position open; if breached, the contract is liquidated automatically. Why Trade Perps?—Use Cases Speculation: Take leveraged bets on price movements, both up and down, without holding the actual asset. Hedging: Protect other crypto investments from adverse price moves with offsetting perp positions. Arbitrage: Buy on the spot market, sell on perps, or vice versa, to profit from price discrepancies. Risks and Opportunities Risks Leverage Risk: Amplifies both gains and losses—liquidation risk is very real. Funding Costs: Holding positions over time can generate significant costs through the funding rate. Counterparty/Smart Contract Risk: On CEXs, you trust the exchange; on DEXs, bugs or exploits in the smart contract could cause loss of funds. Volatility: Sudden price moves can trigger margin calls and liquidations, often more quickly than traders expect. Opportunities Capital Efficiency: Small collateral enables access to large positions and strategies unavailable with spot-only trading. Sophisticated Strategies: Perps let users go short, hedge, and construct complex risk/reward structures impossible with simple spot trading. 24/7 Liquidity: Both CEX and major DEX perp markets run around the clock. Final Thoughts Crypto perps are a cutting-edge financial tool, fusing the efficiency of futures with the 24/7 nature of crypto markets. Their combination of leverage, liquidity, and flexibility make them powerful—but risk management is crucial. Spot traders who want to expand into perps should start small, use strict position sizing, and have a clear plan for handling margin calls and volatility. Whether you choose a CEX for its liquidity and ease or a DEX for control and transparency, understanding the mechanics—including funding rates and margin requirements—is key to success. Leverage and the chance for outsized returns draw many traders to perps, but the risks are equally outsized. Approach with caution, discipline, and a continuous focus on education. Share Information via Whistle42

Elon Musk has once again stirred the demographic pot, this time weighing in on Europe’s ongoing birth rate collapse. In response to a growing online discussion about the cultural and geopolitical consequences of Europe’s aging population, Musk posted a stark three-word comment: “It’s just math.” The implications are existential — not just for Europe’s pension systems, but for its cultural continuity, global influence, and survival as a civilizational force. Key Points: Europe’s birth rates have dropped far below replacement levels across nearly all countries. Musk reiterates his long-standing view: population collapse, not overpopulation, is the real threat. Grok, Musk’s AI chatbot, warns that Europe faces a “demographic time bomb” and could see massive economic contraction and cultural disintegration if trends continue. Fertility rates in countries like Italy, Spain, and Germany are nearing 1.2 births per woman — far below the replacement threshold of 2.1. Europe’s migration policies have filled labor gaps but sparked identity and integration debates. Short Narrative: Elon Musk‘s minimalist “It’s just math” statement may be the most damning critique yet of Europe’s demographic drift. The math is indeed brutal: shrinking native populations, soaring pension burdens, and an increasingly elderly workforce that cannot sustain the continent’s economic and social models. Musk’s broader point is clear — a civilization that stops reproducing signs its own death warrant. Extended Analysis: For decades, European policymakers have treated fertility decline as a soft issue — a cultural trend, not an emergency. But declining birth rates are now colliding with economic stagnation, a shrinking labor force, and social unrest. The replacement strategy — mass immigration — has triggered political polarization and failed to solve long-term systemic gaps. Meanwhile, Elon Musk has emerged as an unlikely demographic hawk. He’s consistently warned that the real threat to humanity isn’t climate change or AI — but civilizational suicide by infertility. His AI assistant Grok chimed in with chilling clarity: “Without policies to encourage family growth, Europe could become a museum of its former self.” Actionable Insight: Demography is destiny — and Europe’s future hinges on reversing its birthrate spiral. Investors, policymakers, and social architects should track countries that enact serious pronatalist reforms, such as Hungary and Poland. If Europe cannot solve the birth rate equation, expect escalating social, economic, and political instability across the continent. Call for Information: Do you have insights into how low birth rates are reshaping European institutions, economies, or cultures? Contact us securely via Whistle42.com. Confidentiality guaranteed. Share Information via Whistle42

Irish comedy writer Graham Linehan was detained at Heathrow by five armed Metropolitan Police officers on Mon, 1 Sept, questioned over three April X-posts about transgender issues, taken to hospital for high blood pressure, then released on police bail. The Met says the arrest was on suspicion of inciting violence under public‑order law; Commissioner Sir Mark Rowley now publicly urges lawmakers to clarify speech laws so police aren’t “policing toxic culture wars.” (Source: The Guardian+1,Reuters). What happened Arrest optics: Aviation unit officers (routinely armed at airports) intercepted Linehan as he arrived from the U.S.; firearms were not drawn, per the Met. The force confirmed the arrest time, flight context, and bail status (Source: The Guardian) Posts at issue: One cited post urged bystanders to “punch [a trans‑identified male] … in the balls” if present in a women‑only space—language Rowley said can meet the threshold for a public‑order offence involving a protected group (Source: The Guardian) Charging status: No charge at this stage; the Met says it is in contact with the Crown Prosecution Service (CPS) (Source: The Guardian) Linehan’s account: He calls the UK a “police state,” says he’ll sue for wrongful arrest with support from the Free Speech Union, and published his narrative on Substack (Source: The Guardian,grahamlinehan.substack.com). Why it matters (beyond one arrest) Law vs. policing reality: Rowley says officers had reasonable grounds under current statutes but shouldn’t be adjudicating cultural speech disputes; he’s proposing tougher triage so only cases with clear risk of harm proceed, and he’s asked government to clarify the law “within weeks.” This is a rare, public push from the UK’s top cop to narrow the funnel of online‑speech enforcement (Source: The Guardian). Transatlantic blowback: Nigel Farage used the arrest in sworn testimony before the U.S. House Judiciary Committee, casting Britain as an exporter of speech restrictions—fuel for an escalating international narrative that UK law overreaches online (Sources: Financial Times,PBS,The Irish Times). Chilling‑effect risk: The image of five armed officers greeting a returning passenger for tweets is already viral shorthand for perceived state heavy‑handedness—raising legal risk for UK agencies and reputational risk for UK policy. Legal context (quick read) Suspected offence: The Met cites incitement to violence tied to public‑order law. UK speech crimes span the Public Order Act (threats, incitement), Malicious Communications/Communications Act offences, and new Online Safety Act duties; lines between offensive speech, threats, and incitement are contested and evolving (Sources: Reuters,The Guardian). Process note: Arrest + bail ≠ charge. CPS must assess evidence + public‑interest tests before any prosecution. In parallel, Rowley’s call suggests near‑term policy tightening to deprioritise borderline “toxic culture‑war” reports Risk & impact radar For UK policing: Elevated judicial‑review / civil‑claim exposure (wrongful arrest, proportionality, Article 10 ECHR) if the case collapses; operational guidance likely to be rewritten. For policymakers: The incident becomes Exhibit A in a broader critique of the Online Safety Act and UK speech law coherence—now under international scrutiny. For platforms/creators: Expect more forum shopping (publish outside UK, moderation friction), rising legal‑advice overhead for creators, and a stronger free‑speech litigation bar. For civil society: Both gender‑critical and trans‑rights groups will mobilise; watch for test cases seeking to harden the line between hateful/inciting speech vs. offensive opinion. Our take (provocative, but grounded) Arresting a public figure at a jet bridge with five armed officers for three contentious posts is a policing choice with predictable optics. Even if the legal threshold for “incitement” is arguable, the state must weigh necessity and proportionality—especially given the guaranteed chilling effect and the near‑certain political weaponisation. Rowley’s unusual public plea effectively concedes the system is over‑inclusive and miscalibrated for online speech. If CPS declines to charge—or a court trims the case—expect rapid policy retrenchment and a fresh round of legislative fixes. Open questions Will CPS charge or quietly NFA (no further action)? 2) What bail conditions apply? 3) How will any new Met triage policy be worded and measured? 4) Will Parliament table an urgent clarification of public‑order/communications offences in online contexts? Call for information Were you an eyewitness at Heathrow’s arrivals gate, or do you have the custody record / bail paperwork or internal guidance cited for airport arrests of online‑speech Share Information via Whistle42

Wiener Privatbank (WPB) is a small but interesting bank with deep connections in the Eastern European markets. However, the publicly listed bank has been in rough water over the last couple of years. In their press releases announcing their H1 2025 results, WPB claims “slight upward trends” in the Austrian real‐estate market—more buyer interest and higher offer prices—helped by rate cuts and the expiry of Austria’s KIM mortgage limits. But hard data still show elevated insolvencies, weak transaction volumes vs. 2021, and only patchy green shoots (permits ticking up, a better hotel sub-market). Investors should treat WPB’s tone as aspirational, not confirmed macro recovery—and demand granular exposure and loss-given-default (LGD) disclosures (Sources: pressetext.com, STATISTIK AUSTRIA, practiceguides.chambers.com). Read our WPB Investor Briefing for H1 2025 here. Key Points What WPB said (Sept 3, 2025): “Der … Immobilienmarkt verzeichnet derzeit leichte Aufwärtstrends. Sowohl das Kaufinteresse als auch die Angebotspreise haben zugenommen,” supported by rate cuts and the expiry of KIM lending caps (Source: pressetext.com). Macro cross-check: Bankruptcies rose ~7% YoY in H1-2025 (services, retail, construction hit), inconsistent with a broad-based upswing narrative (Source: STATISTIK AUSTRIA). Green shoots (but narrow): Building permits rose from Q4-2024 to Q1-2025; hotel transactions +13% YoY in H1-2025 (~€215m), helped by tourism and a few large deals. These do not equal a residential/commercial recovery (Sources: Trading EconomicsChristie & Co). KIM expiry (June 30, 2025) could ease mortgage frictions, but the FMA’s new guidance urges prudence, not a lending free-for-all. Transmission into volumes/prices takes time (Sources: FMA Österreich+1). Sentiment vs. fundamentals: Local reports flag fragile improvement and only a slow upswing in Vienna housing; national transaction volumes remain far below the 2021 boom (Sources: Leadersnet,practiceguides.chambers.com). Short Narrative — Why the “recovery” claim feels early Yes, rates are lower and KIM is gone. But distress is still washing through developers. The collapse of Signa continues to radiate; Rene Benko faces criminal proceedings. Lukas Neugebauer’s LNR entities are in insolvency. In August, Klemens Hallmann filed for personal bankruptcy (his holding reportedly not affected). A market claiming “recovery” while its most prominent names implode is not a recovery; it is a bottom-formation at best—with dispersion across segments and heavy reliance on selective buyers (Sources: Reuters, Financial Times, vindobona.org+1). Data Check — What actually points up (and what does not) UP (tentatively): Permits ticked up into Q1-2025 (from Q4-2024) (Sources: Trading Economics) Hotel investment improved in H1-2025 (+13% YoY), led by a few chunky deals (e.g., Vienna Marriott) (Sources: Christie & Co). OeNB notes signs that permits and lending survey data are beginning to turn, after a ~20% real drop in residential construction investment (2023–2024) (Sources: Österreichische Nationalbank). NOT YET: Bankruptcies remain elevated (+7% YoY H1-2025), with construction among the worst hit (Sources: STATISTIK AUSTRIA). Nationwide transactions remain muted versus 2021 (-44% vs boom year); price indices show mixed/flat moves, not a decisive rebound (Sources:practiceguides.chambers.com, FRED). WPB Exposure — where investors need clarity WPB runs a three-lane property franchise: Project finance for developers (secured, selective—largest risk vector). Distribution of Vorsorgewohnungen (investment apartments) and brokerage (Sources: Deutsch+1). Proprietary/platform issuance like the 5.5% “Wiener Stadthäuser One Immobilien GmbH” 2024–2031 notes (issuer docs show a WPB-centred platform; investors should examine refinancing, sales velocity, and conflicts) (Sources: Deutsch). Ask WPB to disclose (H2-2025): Sector/borrower concentration in project finance, LTV bands, and stage-2/3 migration since YE-2024. LGD assumptions under stressed exit prices; refinancing cliffs for issuer/SPV platforms (e.g., Stadthäuser) (Sources: Deutsch). Distribution pipeline conversion rates (reservation→closing) post-KIM, and any inventory risk. Analyst Take — How to read the press release WPB’s message of a “slight” recovery is not baseless—there are early signals (permits, KIM expiry, hotel deals). But the weight of macro evidence still argues caution, not confirmation. For equity holders, the direction of provisions in H2 and the pace of closings in distribution will decide whether FY-2025 turns the corner. Until then, we classify WPB’s “recovery” as “work in progress” rather than “in the bag.” What to Watch Quarterly NPL/provision prints and any ad-hoc disclosures on developer exposures. Vienna housing: transaction counts, discount rates, and developer insolvency flow. Issuer/SPV updates (coupon coverage, sales progress, refinancing) for Wiener Stadthäuser and peers. Call for Information (Whistle42) Are you involved in WPB-financed projects or WPB-distributed investment apartments? Do you hold term sheets, loan tapes, valuation reports, sales ledgers, or board materials? Share safely via Whistle42. Share Information via Whistle42

Executive Summary Wiener Privatbank’s H1-2025 release (3 Sept 2025) signals stability and improving trendlines after a difficult 2024: CET1 26.51% (↑ from 22.46% YE-2024), AUM ~€1.433bn (flat), LCR ~1,480%, sharply lower risk costs (€0.68m vs. €7.36m), and a much better EPS (-€0.13) despite a moderately negative IFRS group result. Management guides to a “clear improvement vs. 2024,” aided by a tentative upturn in Austrian real estate and expansion in CEE/CIS private banking (Source: Pressetext). Shareholder Structure Shareholder structure (04 Aug 2025): K5 Beteiligungs 16.61%; Kerbler Holding 7.39%; Alpha Fund AD (Bulgaria) 9.55%; Shanfari Investment 9.90%; Bohemia Faktoring 9.90%; Aventure Capital 8.64%; Ficron Finance 7.06%; RONDA INVEST P2B 5.79%; Deal Services 5.24%; Free float 16.53%. Trading is in the standard market auction (12:30–13:30) with 5,004,645 shares outstanding (Source: Deutsch). Alpha Bulgaria link: The Bulgarian Alpha Fund AD (presented by the group as ~9.9%) disclosed 9.55% in WPB (via capital increase in 2024; controllers include CREDITBOX SMLTD and Alpha Bulgaria AD). This sits just below the 10% “qualifying holding” threshold—worth monitoring from a control/governance standpoint (Sources: mainsights.ioDeutschalpha). Read our report on Alpha Bulgaria here. Role of Günter Kerbler: Long-time Austrian investor Günter Kerbler serves as Vice-Chair of the Supervisory Board; his holding company also owns 7.39% of WPB. Board composition changed on 27 Jun 2025 (two resignations; Jay Johnston and Christian Briker appointed as alternates), with re-constitution of chair/vice-chair noted thereafter (Sources: Deutsch+1,Pressetext). Opportunities Capital & Liquidity Strength: CET1 at 26.51% and LCR ~1,480% provide notable buffers to pursue selective growth in project finance/Lombard lending and support client confidence (Source: Pressetext) Earnings Trajectory: Risk costs normalised (€0.68m vs. €7.36m H1-2024) and EPS improved to -€0.13; management expects a “clear improvement” in FY-2025 vs. FY-2024. Market Setup: The Austrian real-estate backdrop shows early signs of recovery; easing rates and KIM relaxation could bolster deal flow and fee income. Niche Positioning: Only listed Austrian private bank with a focus on KMU capital-market services (listings, paying-agent work), selective real-estate/project finance, and CEE/CIS private banking—a differentiated franchise in a consolidating market. Risks Profitability still fragile: IFRS group result remains moderately negative in H1-2025 (market effects), so the earnings recovery is not yet “sealed.” Shareholder mosaic: Multiple blocs at 5–10% (incl. Alpha Fund AD at 9.55%) can complicate governance, especially if strategies diverge; near-10% stakes merit continuous fit-and-proper/ownership scrutiny (Source: Deutschmainsights.io). Regulatory/compliance optics around Alpha Bulgaria: Public materials indicate Alpha Bulgaria/Alpha Fund mechanics through CREDITBOX and offshore activity; perception risk if external controversies arise. (Investors should track disclosures and regulator notices.) (Source: mainsights.io,alpha). Liquidity risk in the stock: Auction window 12:30–13:30 and small free float (~16.5%) can amplify volatility and widen spreads—position sizing matters (Source: Deutsch). Governance continuity: Supervisory Board changes (27 Jun 2025); execution of strategy depends on stable oversight and alignment among key blocs (Source: Pressetext). Market Impact & Read-Across Credit quality & capital markets: If Austrian real estate continues to thaw and rates ease, WPB’s niche in selective project finance and KMU ECM/DCM can re-accelerate fee/interest income; conversely, a macro relapse would keep returns sub-par. Ownership dynamics: Any movement by sub-10% blocs (↑/↓) could shift the power map; watch filings and the extraordinary/annual meetings calendar for signals. Regulatory & Governance Context Supervisory leadership: Vice-Chair Günter Kerbler (also a 7.39% holder) provides continuity and local market reach; board re-constitution in June suggests active stewardship. Deutsch+1Pressetext Ownership disclosures: Company maintains an updated shareholder list (as of 04 Aug 2025); investors should monitor §135 BörseG notices and MAR PDMR dealings. Deutsch+1 Investment View (analyst’s take) Rating: Hold / Speculative (micro-cap financial).Thesis: The balance-sheet quality is strong (CET1/LCR), operational KPIs are moving the right way, and the franchise has distinct niches. However, earnings are not yet decisively positive, the shareholder base is complex, and trading liquidity is thin. For risk-tolerant investors comfortable with Austria/CEE private-banking exposure and patient liquidity management, WPB could be worth a watchlist position ahead of FY-2025 print. For conservative portfolios, wait for a clean return to sustained profitability (and clarity around shareholder dynamics) before building a position. Key Data (H1-2025) CET1: 26.51% (vs. 22.46% YE-2024) AUM: €1.433bn (stable) Risk costs: €0.68m (vs. €7.36m H1-2024) LCR: ~1,480% EPS: -€0.13 (improved YoY) BS total: €310.64m; Equity: €32.44m (excl. minorities) Outlook: “Clear improvement vs. 2024,” still a challenging year. Shareholder Map (04 Aug 2025) K5 Beteiligungs 16.61%; Kerbler Holding 7.39%; Alpha Fund AD 9.55% (linked to Alpha Bulgaria/CREDITBOX); Shanfari Investment 9.90%; Bohemia Faktoring 9.90%; Aventure Capital 8.64%; Ficron Finance 7.06%; RONDA INVEST P2B 5.79%; Deal Services 5.24%; Free float 16.53% (Source: Deutschmainsights.io). Actionable Takeaways Monitor filings around any threshold moves by Alpha Fund AD or other 5–10% blocs (could signal strategic shifts). Track FY-2025 guidance delivery and sustainability of lower risk costs into H2. Liquidity discipline: Use limit orders; assume low depth during the one-hour auction window. Governance watch: Follow Supervisory Board composition and AGM/EGM outcomes post-June changes. Share Information via Whistle42

The European Public Prosecutor’s Office (EPPO) says Greece’s agricultural-payments agency OPEKEPE sat at the center of an organised fraud system siphoning EU farm subsidies via false pasture claims, fictitious herds, and misuse of public/monastic land. On Friday, 27 June 2025, Migration Minister Makis Voridis (agriculture minister during part of the period) and three deputy ministers resigned, alongside a senior secretary general. Brussels has already docked Greece’s CAP funds (~€392m cut) and EPPO has forwarded materials to Parliament that could trigger immunity votes. Despite the magnitude, coverage outside Greece remains muted (Sources: eppo.europa.eu+1,AP News,euractiv.com). Key Points EPPO’s thesis: An organised fraud scheme around OPEKEPE enabled non-eligible beneficiaries to claim CAP money using false land/stock declarations (incl. public & monastic land) (Sources: eppo.europa.eu,IBNA) Political fallout: On 27 Jun 2025 Voridis resigned; three deputy ministers and a secretary general also stepped down the same day. Thanos Plevris was later sworn in as migration minister. (Sources:ekathimerini.com,euronewsAP News). Financial hit: The Commission imposed a ~€392m reduction/penalty in CAP funding; investigators detail €22m+ already tied to fraudulent claims, with probes ongoing for 2016–2024 (Sources: Reuters+1). Systemic fix promised: Athens plans to overhaul/shift OPEKEPE functions and tighten controls; Parliament eyeing inquiry powers (Sources: Reuters). What’s New (Timeline) 20 May 2025: EPPO publicly describes an organised CAP fraud/corruption probe focused on OPEKEPE (Sources: eppo.europa.eu). 19 Jun 2025: EPPO submits information to the Hellenic Parliament (potential immunity issues) (Sources: eppo.europa.eu). 27 Jun 2025: Resignations: Voridis + multiple deputies/officials. ekathimerini.comeuronews July–Aug 2025: Raids widen; further lines of inquiry opened; Greek media coverage dominates (Sources: Reuters,subscriber.politicopro.com,GreekReporter.com). Modus Operandi (as alleged) False pastureland & fictitious herds: Beneficiaries declared land they didn’t own/lease (including public & monastic land) and inflated livestock numbers to unlock CAP payments (Sources: IBNAt,ovima.com). Weak controls at the paying agency: OPEKEPE processes used to pass ineligible claims; EPPO flagged lack of sincere cooperation during parts of the probe (Sources: tovima.com). Exposure & Risk Map Budget risk: EU financial interests harmed; clawbacks and future CAP cuts likely until compliance proven (Sources: Reuters). Political risk: Potential immunity votes in Parliament; further resignations cannot be ruled out (Sources: AP News). Operational risk: Expect process migration from OPEKEPE to other state authorities and external audits/consultants to harden controls (GIS/LPIS, beneficiary vetting) (Sources: Reuters+1). Red Flags For Investigators & Journalists Clusters of claims on public/monastic land or abrupt spikes in eligible hectares. Recycling of pasture declarations across multiple “farmers” using identical parcels. (Sources: eppo.europa.eu) Local intermediaries (filers/consultants) repeatedly appearing across suspect files. (Inference based on EPPO patterns; confirm with case files.) (Sources: eppo.europa.eu) What to Watch Next Parliamentary action on any EPPO requests to lift immunity. Commission’s follow-up on additional financial corrections or safeguarding measures for future CAP cycles. Beneficiary lists & recovery notices—who ultimately repays what and when. FinTelegram Take Greece’s scandal isn’t a handful of bad actors—it reads like systemic control failure at the paying-agency layer, with political accountability now in play. The scale (years, nationwide, nine-figure budget impact) and EPPO’s language (“organised fraud system”) elevate this beyond routine CAP irregularities. European coverage remains surprisingly low-signal given the sums involved—precisely why it belongs on Leak Watch. Call for Information (Whistle42) Were you involved with OPEKEPE processing, local claim preparation, GIS/LPIS mapping, or recovery actions between 2016–2024? Do you hold documents, parcel maps, beneficiary files, consultancy invoices, or internal emails? Share safely via Whistle42. Anonymity protected. Share Information via Whistle42

Date: September 2, 2025 Executive Summary Alpha Bulgaria AD (“Alpha Bulgaria”, ALFB) is a Sofia-based public investment company listed on the Bulgarian Stock Exchange. The group positions itself as a fast-growing holding with a rapidly upsized share capital and a portfolio that includes the alternative investment fund Alpha Fund AD, a sub-10% exposure to Wiener Privatbank SE (Vienna), and an $8 million offshore investment in Canal Bank SA, Panama. Public filings confirm the Wiener Privatbank stake is held via Alpha Fund AD, which Alpha Bulgaria indirectly controls through CREDITBOX SMLTD. These mechanics, and the group’s offshore forays (e.g., Canal Bank, Panama), place Alpha Bulgaria in a higher-than-average compliance-risk bracket that investors should monitor closely (Source: pressetext.com). Company Snapshot (ALFB) Listing / Ticker: Bulgarian Stock Exchange (BSE), ALFB. BSE issuer page lists the company website and contacts (Source: bse-sofia.bg). Market capitalisation: Company website states BGN ~56.4m (marketing claim). Third-party market page shows last quoted BGN ~156.7m (price BGN 6.00; shares ~26.12m) as of July 24, 2025. The large gap suggests either site lag or high price volatility—investors should verify with current BSE data (Source: alphaStockAnalysis). Share capital: BGN 26.12m; the site also claims growth from BGN 1.18m to BGN 26.12m over ~2 years, consistent with prior warrant-driven capital increases reported in Bulgarian media (Source: alphaSeeNews). Business focus (self-described): Multi-sector investment (real estate, energy, tech, etc.) (Source: FT Markets). Strategic Holdings & Transactions Alpha Fund AD (AIF) – positioned as a subsidiary/vehicle of Alpha Bulgaria; the site says it’s managed by “Salomon Mayer 1772 AD,” and claims a ~9.9% stake in Wiener Privatbank SE (marketing copy). Regulatory filing shows 9.55% held by Alpha Fund AD after shares were transferred from Alpha Bulgaria to Alpha Fund via a capital increase; control chain disclosed as Alpha Bulgaria → CREDITBOX SMLTD → Alpha Fund AD. This is the authoritative source for the stake and chain of control (Source: alphapressetext.com). Wiener Privatbank SE (Vienna) – Austria’s listed private bank. Alpha’s 9.55% sits just below the EU’s 10% “qualifying holding” threshold that triggers enhanced regulatory scrutiny; this pattern is highlighted in FinTelegram’s reporting (Source: pressetext.com,fintelegram.com). Capital programme – Alpha Bulgaria’s rapid upsizing is documented in SeeNews (warrants framework) and echoed on the corporate website (Source: SeeNewsalpha). Alpha Fund and Alpha Bulgaria in the Wiener Privatbank Panama exposure via Canal Bank (unconfirmed): According to an Alpha Fund AD board resolution dated April 1, 2025, the fund authorized the subscription of 11,428,571 ordinary shares at USD 0.70 (USD 8 million total) in Canal Bank S.A., Panama, to be executed via the Bulgarian intermediary Faktori AD and paid into the bank’s subscription account. This would give Alpha Fund two apparent banking exposures: (1) a confirmed 9.55% position in Wiener Privatbank SE (Vienna), and (2) an unconfirmed offshore position in Canal Bank, Panama. We could not locate a matching public filing or issuer confirmation for the Canal Bank transaction; investors should treat it as whistleblower-sourced/pending verification and request documentary evidence (subscription agreement, payment confirmations, broker contract, and share allocation). Given Panama’s heightened AML sensitivity, this exposure—if completed—would materially elevate Alpha Fund’s jurisdictional risk profile. (Source: Deutschboerse-frankfurt.de). Read our report on the Canal Bank transaction here. Governance & Key Figures Stoyan Staykov – widely cited in investigative reporting as the central deal architect/beneficial controller behind Alpha Bulgaria’s network (Bulgaria/Vienna). Coverage points to patterns such as sub-10% positions, nominee layers, and cross-border flows. Treat these as allegations, not adjudicated facts; still, they are material to investor risk (Source: fintelegram.com). Rumen Nanov – Executive Director at Alpha Fund AD who signed the USD 8m Panama Canal Bank S.A. subscription (board resolution referenced by whistleblowers; broker of record Faktori AD—a licensed investment intermediary in Sofia) (Source: Factori+1). CREDITBOX SMLTD – intermediary company in the control chain disclosed in Vienna’s official stake notification (Source: pressetext.com). Faktori AD – Bulgarian investment intermediary named in Alpha Fund executions; presence and licensing publicly advertised (Source: Factori+1). Network Map — Entities & Roles (Summary Table) NameJurisdictionRole/FunctionLinkage/NotesAlpha Bulgaria AD (ALFB)BulgariaListed holding / issuerControls CREDITBOX SMLTD which controls Alpha Fund AD (per Vienna filing). Website markets rapid capital growth. (Source: pressetext.com,alpha)Alpha Fund ADBulgariaAlternative investment vehicleHolds 9.55% of Wiener Privatbank SE; execution conduit for several investments (Source: pressetext.com).CREDITBOX SMLTD(Disclosed in filing)Intermediate controllerChain of control: Alpha Bulgaria → CREDITBOX SMLTD → Alpha Fund AD (Source: pressetext.com).Wiener Privatbank SE (WPB)AustriaListed private bankAlpha exposure at 9.55%; sub-10% threshold avoids “qualifying holding” regime (Source: pressetext.com,fintelegram.com).Faktori ADBulgariaInvestment intermediaryBroker referenced in Alpha Fund transactions; active licensed intermediary (Source: Factori+1).Canal Bank S.A.PanamaOffshore bank (target of Alpha Fund subscription)USD 8m share subscription; offshore exposure—AML sensitivity. (Transaction context from whistleblower docs; investors should request official filings.)Stoyan StaykovBG/ATAlleged ultimate controller / strategistReported orchestrator of network; allegations of AML-risk patterns and regulatory arbitrage via sub-10% stakes (Source: fintelegram.com).Rumen NanovBulgariaExecutive Director, Alpha Fund ADAuthorized signer for Panama transaction; operational lead for AIF moves. (Per internal docs; cross-check advisable.)BGA Management GmbHAustriaVienna node (reported)Mentioned in FinTelegram network analysis as part of the wider Alpha web (Source: fintelegram.com). Risk Assessment (Investor Lens) Control & Transparency Risk – Formal filings in Vienna reveal a multi-entity control chain (Alpha Bulgaria → Creditbox → Alpha Fund). Beneficial ownership clarity and fit-and-proper transparency are key diligence items; sub-10% positioning merits regulatory attention if influence exceeds disclosed levels. Jurisdictional/AML Risk – Offshore banking exposure (e.g., Panama) plus high-velocity capital movements increase AML monitoring needs. Ensure counterparties (banks, brokers) and source of funds are independently validated. Disclosure vs. Marketing – Market-cap figures published on the Alpha site diverge from third-party quotes; investors should anchor to BSE or official disclosures and request timely IR updates. Concentration & Reputation Risk – The Wiener Privatbank stake is material to Alpha Fund’s profile; any Austrian supervisory actions or reputational hits could reverberate into ALFB’s valuation. FinTelegram highlights Vienna’s historical soft spots in AML enforcement—independent risk review advised. What To Watch (Actionable) Fresh BSE filings: confirm current shares outstanding, warrant exercises, and market-cap (Source: bse-sofia.bg). Vienna disclosures: monitor §135 BörseG stake changes at Wiener Privatbank (thresholds, control chain amendments). (Source: pressetext.com). AIF activity: request Alpha Fund AD’s AIFM documentation (who exactly is the licensed manager; reconcile with “Salomon Mayer 1772 AD” branding on site) (Source: alpha). Broker relationships: verify Faktori AD’s role, KYC/AML procedures, and any outsourcing arrangements (Source: Factori). Offshore flows: obtain bank confirmations for the Panama subscription and ensure source-of-funds documentation. Sources & Notes Corporate site & IR: Alpha Bulgaria website; Investors Center pages (marketing claims: market cap, capital growth, subsidiaries) (Source: alpha+2alpha+2). Listing & quotes: BSE issuer page (contacts), StockAnalysis snapshot (last available pricing/market cap); FT company page overview (Source: bse-sofia.bg,StockAnalysis,FT Markets). Regulatory filing (Austria): Pressetext §135 BörseG disclosure—9.55% stake in Wiener Privatbank SE held by Alpha Fund AD, control via CREDITBOX SMLTD. Authoritative for structure (Source: pressetext.com). Context / Investigative reporting: FinTelegram reporting on Staykov, Alpha network, and sub-10% patterns; recap on Wiener Privatbank shareholder structure. Treat as journalistic sources indicating risk signals (Source: fintelegram.com+1). Intermediary confirmation: Faktori AD public website (contact, history) (Source: Factori+1). Verdict (Initial) Alpha Bulgaria/Alpha Fund present opportunity-with-risk: a fast-scaling listed vehicle using warrant-fuelled capital programmes and strategic financial stakes (notably in Vienna). However, ownership clarity, AIF governance, and offshore exposure require enhanced diligence. For institutional investors, any position should be contingent on: independent BO verification across the chain (Alpha Bulgaria → Creditbox → Alpha Fund); confirmations on AIFM licensing and policy; documented source-of-funds for offshore investments; monitoring for regulatory developments at Wiener Privatbank. Call for Information If you have primary documents (AIFM mandate, custodian confirmations, subscription receipts, shareholder agreements) relating to Alpha Bulgaria, Alpha Fund AD, CREDITBOX SMLTD, Faktori AD, or the Wiener Privatbank stake, please reach us confidentially via Whistle42. Your evidence helps us keep markets clean. Share Information via Whistle42

On April 1, 2025, Alpha Fund AD – a Bulgarian investment vehicle linked to controversial figure Stoyan Staykov – approved an $8 million capital injection into Canal Bank S.A. in Panama. At first glance, the deal appears routine. But a deeper look reveals hallmarks of a capital-shifting operation typical of transnational money laundering. The deal, signed by Alpha Fund’s executive Rumen Nanov and executed via Sofia-based Faktori AD, raises serious red flags. Key Points: Alpha Fund AD committed $8 million to Canal Bank S.A. in Panama via 11,428,571 shares at $0.70 each. The intermediary, Faktori AD, is seen as a likely strawman entity for fund transfers. Stoyan Staykov, alleged beneficial owner, is under scrutiny in Austria, Bulgaria, and other jurisdictions for involvement in fraudulent investment structures. The transaction features common laundering indicators: offshore bank, low-priced shares, rapid approval, and minimal oversight. Potential violations include money laundering (§165 StGB Austria), fraud (§147), and organized crime (§278). Cross-border nature may trigger interest from the European Public Prosecutor’s Office (EPPO). Read our reports about Stoyan Staykov here. Short Narrative: In a resolution dated April 1, 2025, Alpha Fund AD, a subsidiary of Alpha Bulgaria (website), greenlit a major offshore investment – the purchase of over 11 million shares in Canal Bank S.A., a small Panamanian institution long associated with opaque financial flows. The total value: $8 million. The justification cited was typical investment-speak – foreign diversification, portfolio exposure. However, when viewed through the lens of the Staykov network, the transaction fits a disturbing pattern of strategic fund relocation, not legitimate asset management. Read the Wiener Privatbankannouncement here. Alpha Fund AD is a closed-end investment fund focused on diversified financial investments. The fund operates under the management of Salomon Mayer 1772 AD, registered with the Bulgarian Financial Supervisory Commission. According to documents and insider reports obtained by FinTelegram, the transaction was pushed through with remarkable speed following a notice dated March 7. The intermediary, Faktori AD, has repeatedly surfaced in other suspicious transfers. And behind it all, Stoyan Staykov – a name that has become synonymous with financial opacity. Extended Analysis: Who is Stoyan Staykov? Staykov is known across Eastern Europe as the man behind a string of questionable investment schemes. In Bulgaria, Austria, and Germany, victims accuse him of orchestrating pyramid-style operations through various shell companies. One of the most high-profile complaints came from his alleged brother, who claims to have lost €1.8 million. Another Austrian victim, a Notary, reportedly remains unpaid for services totaling €100,000. In 2023, Regent Capital AD, another Staykov-linked vehicle, was involved in a litigation case alleging fraudulent misrepresentation and default. Regulators in Austria and Bulgaria have been quietly monitoring Staykov’s operations, though no formal charges have yet been brought. Why Panama? Why Canal Bank? Canal Bank S.A., although officially licensed, has a low public profile and minimal due diligence footprint. Panama remains a high-risk jurisdiction for financial secrecy. The combination of low-priced shares and obscure ownership structures raises immediate concerns. In similar historic cases, such setups were used to inject untraceable capital, clean up dirty funds, or artificially prop up balance sheets. The Role of Faktori AD: Nominally a licensed Bulgarian broker, Faktori AD appears to act more like a facilitator than a compliance gateway. According to internal sources, Faktori has been used multiple times by the same circle of actors to shuttle money between Eastern Europe and offshore zones – notably Panama, Belize, and the UAE. Actionable Insight: This is not just a story about one shady investment decision. It’s a case study in how opaque European fund vehicles operate within a global shadow finance system. Regulators, especially Austria’s Financial Market Authority (FMA) and Bulgaria’s FSC, should prioritize investigations into Alpha Fund AD, Faktori AD, and their connections to the Staykov network. The EPPO should also consider opening a cross-border investigation, given the trans-European footprint and possible misuse of investor capital. The Alpha Fund Board Resolution (April 1, 2025) Bulgarian (Original)English (Official/Forensic Translation)АЛТЕРНАТИВЕН ИНВЕСТИЦИОНЕН ФОНД АЛФА ФОНД АД: Решение за участие в увеличение на капитала на Canal Bank, S.A. (Панама)Alternative Investment Fund “Alpha Fund” AD: Resolution on Participation in Capital Increase of Canal Bank, S.A. (Panama)Съветът на директорите на Дъщерното Дружество АИФ „Алфа Фонд“ АД проведе заседание на 01.04.2025 г. и, след обсъждане на инвестиционните параметри и стратегическата целесъобразност, единодушно одобри участие на Фонда в увеличение на издадения капитал на Canal Bank, S.A., обявено със Съобщение № CB-CAP-2025-03/07 от 07.03.2025 г.The Board of Directors of the subsidiary AIF “Alpha Fund” AD held a meeting on April 1, 2025, and, after discussing the investment parameters and strategic feasibility, unanimously approved the Fund’s participation in the capital increase of Canal Bank, S.A., as announced in Notice No. CB-CAP-2025-03/07 dated March 7, 2025.Решено е да бъдат записани 11 428 571 броя обикновени акции при емисионна цена USD 0,70 на обща стойност USD 8 000 000.It was resolved to subscribe for 11,428,571 ordinary shares at an issue price of USD 0.70, for a total value of USD 8,000,000.Изпълнителният директор Румен Нанов е упълномощен да разпореди извършване на сделката чрез ИП „Фактори“ АД и плащане по абонаментната сметка на Canal Bank, S.A.Executive Director Rumen Nanov was authorized to execute the transaction via the investment intermediary Faktori AD, and to arrange payment into the subscription account of Canal Bank, S.A.Очакван ефект: разширяване на чуждестранната експозиция на портфейла и диверсификация по география и банков сегмент, при стриктно следване на лимитите и вътрешните политики за риск на Фонда.Expected effect: Expansion of the Fund’s foreign portfolio exposure and diversification by geography and banking segment, in strict compliance with the Fund’s internal risk limits and policies. Call for Information: If you have worked with, invested in, or were approached by Alpha Fund AD, Faktori AD, Canal Bank S.A., or Stoyan Staykov, we urge you to contact us in confidence via the Whistle42 platform. Your information can help uncover the full structure behind these suspicious transactions. Share Information via Whistle42

Meta:Date: 2025‑08‑30 CET • Risk:   Medium • Confidence:  High • Sector: Real Estate / Insolvency • Entities: René Benko, Signa Group, Karl‑Heinz Götze, Kreditschutzverband 1870 • Jurisdictions: Austria, Europe What happened Creditors have now lodged €27.6 billion in claims against the collapsed Signa real estate group, Austria’s largest insolvency to date, according to Karl‑Heinz Götze of the Kreditschutzverband von 1870. However, only €9.5 billion has been recognized by administrators so far—the rest remains contested. (Sources: ground.news)At the same time, Austrian prosecutors have charged Signa’s founder, René Benko, with insolvency fraud, accusing him of concealing assets—luxury items, property, and shell transactions—to dodge creditor payouts. Criminal investigations span multiple countries. (Sources: ft.com, reuters.com) Why it matters The claim volume is staggering—far exceeding any previous European insolvency case by a wide margin. Asset concealment allegations strike at the heart of trust in elite-managed property empires. Cross-border investigations including Italy, Germany, and Liechtenstein signal this won’t be resolved quietly. Our opinion This is a textbook collapse of celebrity-chairmanship run amok. Benko built an empire glittering with landmarks—but now we see he overstayed the PR show with trickery behind the scenes. If Signa’s reckoning doesn’t result in asset recovery and institutional reform, this will be legacy litigation—not justice. A real estate titan needs effective transparency, not labyrinthine trust structures. Read our reports on Rene Benko here. Signals to watch (7–30 days) Legal confirmation of the final recognized liability and distribution plan. Asset recovery tracks—Will major trophy properties be liquidated or preserved? Further indictment announcements or regime shifts in Austrian creditor protection law. Sources Ground.News: Claims of €27.6 billion filed; €9.5 billion recognized. (turn0search0) Reuters: Fraud charges brought against Benko for manipulating assets in insolvency. (turn0search1) Financial Times: Criminal complaint details asset hiding and embezzlement allegations. (turn0news20) FinTelegram reports here and here. Call for information — Got internal asset lists, creditor schedules, or court filings from the Signa case? Pass them anonymously via Whistle42. Share Information via Whistle42

Standfirst: Saudi Arabia’s football push has outgrown the “buy the stars” phase. If the Saudi Pro League (SPL) wants to be more than a public‑relations spectacle, sustainability—not spectacle—must be the core product. Key points Cristiano Ronaldo’s renewal through 2027 keeps the SPL’s global magnet in place, while U.S. investor Harburg Group taking control of Al‑Kholood signals a turn toward privatization and foreign capital (Source: The Guardian) The SPL says it’s shifting from spend-first to governance-first: new financial regulations, a league‑run Financial Oversight body (moved from the Ministry of Sport), and roster/youth rules aimed at cost control and talent pipelines (Sources: Reutersspa.gov.saargaam.comSaudi Professional League Association). The 2023 privatisation program put 75% of the “big four” under PIF and opened the door to private owners—vital for long‑term incentives but risky if broadcast and matchday economics lag (Source: Al Jazeera) What just happened (and why it matters) Ronaldo stays; investors arrive. Ronaldo’s extension with Al‑Nassr locks in the league’s most bankable global name for two more seasons. At the same time, Al‑Kholood’s takeover by U.S.‑based Harburg Group is a proof‑of‑concept for foreign ownership beyond the PIF‑backed giants. The message is clear: star power for attention, private capital for durability. From free‑spending to rule‑setting. The SPL’s CEO advertised new financial regulations, reduced squad sizes, youth quotas, and a Financial Oversight Committee to tame wage inflation and force development pathways. The Ministry of Sport’s formal transfer of oversight to the SPL is the institutional anchor this model needed. If enforced, this changes the conversation from “sportswashing” to “can the unit economics work?” The playbook: from sportswashing to sustainability Sportswashing buys headlines fast; sustainability earns audiences slowly. To cross that bridge, three systems have to work: Incentives & ownershipPrivatization aligns club owners with profitability and compliance—if oversight is real and predictable. PIF control of the big four created stability; outside owners diversify risk and ideas. The Harburg deal is an early test: can a smaller‑market club (Al‑Kholood) build brand and cash flow without state oxygen? Cost discipline & developmentSquad caps, foreign‑player limits, and U‑21 quotas are only as good as their enforcement. If they bite, they compress wage bills and push academies to matter. If they’re porous, the league reverts to checkbook football and short half‑lives. Revenues beyond the TreasuryBroadcast distribution has widened (the SPL touts carriage in 180+ countries), but the question is price, not reach. Until media rights, sponsorships, and matchday income cover a meaningful slice of costs, sustainability is a press release. Our opinion (FinTelegram) The SPL is doing the right things on paper—moving oversight in‑house, tightening rosters, and inviting foreign owners. But the league’s credibility will be earned only when rules constrain the stars, not bend to them. We want to see a season where a glamorous transfer is blocked on compliance grounds, or where a youth‑minute rule costs a big club points. Until then, the gravity of state money outweighs market discipline. This is not an indictment; it’s a challenge. If Saudi Arabia wants a durable, globally respected league, publish the enforcement data (wage‑to‑revenue ratios, academy graduation rates, fine totals) and lock it into the calendar. Sustainability is a scoreboard. Put it on the scoreboard. What would convince us the model is real Transparent enforcement: Quarterly reports from the Oversight Committee—violations, fines, transfer restrictions applied. Youth outcomes: Year‑on‑year increase in U‑21 minutes and domestic transfers without net wage growth. Owner diversification: At least 3–5 non‑PIF majority owners operating under the same audit regime as the giants. Rights economics: A step‑up in international media fees (not just coverage), disclosed by territory. Risks we’re watching Subsidy dependence: If PIF backstops remain implicit, private owners won’t innovate; they’ll arbitrage. Rule capture: Waivers for star signings gut the reforms. (If caps flex for news cycles, costs return.) Audience plateau: Global carriage without sticky local audiences leaves sponsorship soft and stadiums half‑full. Signals to watch (next 6–12 months) Enforcement firsts: A blocked transfer, points deductions, or fines for financial breaches. Hard cap behavior: Evidence that squad‑size/foreign‑player limits drive exits instead of exceptions (Source: Saudi Professional League Association). Deal flow beyond big four: Additional mid‑table privatizations or foreign takeovers following Al‑Kholood (Source: The Guardian). Rights revenue, not just reach: Disclosed uplifts or multi‑year guarantees from key territories (Source: Reuters). Sources The Guardian: “US money comes to Saudi Pro League as Ronaldo commits for two more years.” (Aug 28, 2025) — Ronaldo extension; Harburg/Al‑Kholood; privatization context. The Guardian Reuters: “New financial regulations will ensure sustainability in Saudi Pro League, says CEO.” (Aug 28, 2025) — new financial rules; oversight; youth/squad measures; global carriage claim. Reuters Saudi Press Agency / Ministry of Sport: transfer of financial oversight to the SPL. (July 2025). spa.gov.samos.gov.sa Al Jazeera: 2023 privatization drive; PIF takes 75% of four major clubs. (June 5, 2023). Al Jazeera SPL official site: foreign‑player registration context. Saudi Professional League Association Call for information — Have financial docs, oversight memos, or media rights details? Share securely via Whistle42. Share Information via Whistle42

Meta:Date: 2025‑08‑30 CET • Risk: Medium • Confidence: Medium • Sector: Sports / Geopolitics • Entities: Cristiano Ronaldo, Saudi Pro League (SPL), Harburg Group, Al‑Kholood • Jurisdictions: Saudi Arabia, US, Global What happened Cristiano Ronaldo, now 40, extended his Al‑Nassr contract through mid‑2027—committing to Saudi’s top flight until age 42. Simultaneously, the SPL is pushing to up its game internationally: the American Harburg Group invested in newly promoted club Al‑Kholood, reflecting a pivot to privatization and governance reforms. Why it matters Ronaldo’s long‑term stay doubles as a market anchor and global media magnet. U.S. investment signals a new governance order—not just megastar splurges. Reform measures (youth quotas, oversight, smaller squads) suggest the league knows sustainable cachet will last longer than headlines. Our opinion This isn’t mere sportswashing—it’s a carefully choreographed soft‑power play. Saudi is locking in long‑run visibility (via Ronaldo) while patching structural cracks with privatization and regulation. Still, a league built on spectacle should show what it does next when the football circus fades. Signals to watch (7–30 days) Al‑Kholood’s debut season performance and brand development. U.S. investor moves in other SPL clubs. Squad age data and youth compliance across the league. Sources Guardian: “US money comes to Saudi Pro League as Ronaldo commits for two more years” The Guardian Reuters: “New financial regulations will ensure sustainability in Saudi Pro League, says CEO” Reuters Guardian: Ronaldo contract extension to 2027 noted The Guardian+2Wikipedia+2 Others: The Washington Post+12The Guardian+12The Guardian+12The Guardian+1 Related on FinTelegram “Sportswashing vs. sustainability: Laying the groundwork for a real Saudi league” Call for information — Leaked contracts or PIF board memos? Share via Whistle42. Share Information via Whistle42

In Austria, one fallen real-estate mogul sits in pre-trial detention; another tours Vienna in a yellow Lamborghini. René Benko has been behind bars since January 2025 as courts repeatedly upheld custody over collusion and recidivism risks. Lukas Neugebauer, by contrast, continues to operate through a maze of entities tied to his LNR Group—despite a swelling insolvency crater, an evidentiary trail of suspect transactions, and criminal investigations already on file. The question practically asks itself: why are Austrian authorities not acting with the same urgency in the Neugebauer case? (Sources: Reuters+3Reuters+3Reuters+3,Bloomberg.com,ft.com) Who is Lukas Neugebauer? Lukas Neugebauer is an Austrian real-estate operator who built the LNR Group into a sprawling web of project companies across Vienna before a wave of insolvencies engulfed the network in 2024–2025. Investigative files and creditor records tie LNR entities to high-profile addresses and redevelopment sites—Apollogasse 8, Zollergasse 31, Amerlingstraße 7, Rennweg 72–74, among others—while prosecutors probe alleged bank-fraud patterns, sham purchase contracts, and treuhand payouts without adequate collateral. Neugebauer’s inner circle features fixer-type associates such as Markus Pospichal and newly installed frontmen like Johann Vakovics (linked to a chain of “Blackstone” SPVs and Mandos GmbH at Vienna’s Palais Festetics), with lawyer Gerald Göllner—a longtime confidant—now suspended amid criminal-procedure headwinds. Neugebauer’s Lambhorgini Urus parking before his Vienna office on Aug 29, 205 Despite the insolvency crater and mounting evidence of last-minute asset transfers, Neugebauer has continued to project normalcy—whistleblowers describe him circulating between LNR locations in foreign-plated luxury cars—underscoring the central question of this series: why hasn’t Austria applied the same restraint and urgency here as in the country’s other marquee real-estate case? What we know about LNR’s playbook (from files and fresh whistleblowers) Our reporting partner, the German-language investigative outlet Wiener Zocker, has tracked the Neugebauer/LNR case for years with extensive support from whistleblowers and insiders, uncovering a repeatable pattern of suspect transactions, proxy-controlled SPVs, and last-minute asset moves. The most material findings are summarized below: Follow the Lukas Neugebauer case here on Wiener Zocker: Bank fraud pattern (investigative files): Search-warrant materials outline alleged “sham” purchase contracts, bank misrepresentations, and treuhand (escrow) disbursements without required safeguards—across multiple LNR projects, including Apollogasse 8. Estimated damages in the tens of millions are tabulated for Neugebauer and associates. The “last-minute” Apollogasse 8 transfer: Hours before the 5 Aug 2025 insolvency of Zinshaus APGA 8 Projekt GmbH, the property was sold to Blackstone Four GmbH under a contract that pays no cash into the estate—price “settled” solely by taking over liabilities. Insolvency contacts told tenants they’d “never seen a case this bad.” Who’s steering Blackstone Four: Our Vienna reporting has mapped the Palais Festetics (Berggasse 16) cluster and a rapid reshuffle placing Johann Vakovics—a recent retiree from the hospitality trade—as managing director across Blackstone One–Five and Mandos GmbH (100% Vakovics), entities linked by address and people to the LNR network. (See our separate profile.) Vehicles & optics: Multiple whistleblowers report Neugebauer’s luxury cars—including a yellow Lamborghini Urus—parked at LNR’s Viennese HQ and driven on German (Nuremberg) plates sourced via Auto Zitzmann, a luxury dealer/leaser in Nuremberg. If these vehicles are systematically used in Austria, domestic registration is generally required after one month for residents. (Sources: Auto Zitzmann,home.mobile.de,instagram.com). Read our report on Rene Benko here. Why the contrast with Benko matters Benko standard: Courts cited risk of collusion and reoffending to keep Benko in custody, with extensions reaffirmed in late January and April 2025; prosecutors have since advanced charging decisions. The burden is not on “final proof,” but on credible risks and ongoing investigative needs (Sources: Reuters+2Reuters+2,ft.com). Neugebauer reality: Investigative materials already describe scheme mechanics (sham buyers, escrow misuse, cash-pooling) and enumerate project-by-project exposures—Apollogasse 8, Zollergasse 31, Amerlingstraße 7, Rennweg 72–74, among others. Yet post-insolvency asset transfers (e.g., Apollogasse 8) have still proceeded in the open. Why no comparable restraint? The car-plate angle (not the biggest issue, but telling) Austria’s KFG §82(8) presumes foreign-plated cars used by Austrian residents have a “permanent location” in Austria; use on foreign plates is typically limited to one month from first entry—after which local registration is required. Official portals reiterate the rule; the Finance Ministry also flags tax implications for improper use. If LNR vehicles are operated long-term on DE plates, that’s at least a regulatory breach—and a useful test of whether basic enforcement is happening at all. (Sources: jusline.at,oesterreich.gv.at,bmf.gv.at,wko.at) A sharper question for Austrian authorities Benko remains detained due to acute risks acknowledged by courts. Neugebauer’s network, by contrast, displays an active transaction pattern in the midst of insolvency chaos—precisely the scenario where collusion and reoffending risks usually trigger swift constraints. Add that Neugebauer’s longtime lawyer-confidant Gerald Göllner appears prominently in the investigative files (and has faced professional repercussions), and the asymmetry becomes starker. So what explains the inertia—capacity, priorities, or influence? What would “normal” enforcement look like here? Immediate defensive steps in Apollogasse 8: Injunctions and avoidance (Anfechtung) actions where the estate receives no cash and transfers occur hours before insolvency. Scrutiny of treuhand files, bank releases, valuation basis, and ultimate beneficial owners in the Blackstone/Mandos chain. Basic traffic & tax enforcement: Quiet checks on vehicle registration and use at LNR sites—the rule is simple, the test uncomplicated. jusline.atoesterreich.gv.at Protective measures: If patterns mirror those alleged in the files (sham transactions, circular funding, cash-pooling), restraining orders and custodial measures should at least be on the table, applying the same yardstick used for Benko. Open leads we’re pursuing The Apollogasse 8 contract: Signed Aug 4, 2025 in Ebreichsdorf; “price” netted solely via assumption of liabilities; not yet recorded in the land register at the time sources wrote to us. We’ve published the contract for scrutiny. If you spot red flags, tell us. Blackstone/Mandos structure: Directors, beneficial owners, treasury flows, and any overlaps with LNR treasury or service providers. Vehicles & leases: Contracts, garaging, insurance, and use patterns of DE-plated cars at LNR sites; links to Auto Zitzmann leasing arrangements (Sources: Auto Zitzmann). Call for documents & witnesses Have WB extracts, treuhand agreements, bank releases, valuation reports, emails, vehicle papers, or tenant notices touching LNR / Blackstone Four / Mandos / Palais Festetics or Apollogasse 8? Share Information via Whistle42 Editorial note: Allegations against Neugebauer, Pospichal, Vakovics, and Göllner are grounded in official investigative records and first-hand documents shared with us; all parties are presumed innocent unless proven otherwise. We will publish clarifications and responses in full. Why are Austrian authorities not applying the Benko yardstick here? We ask the question—and we’ll keep asking it—until we see an answer backed by action.