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to state", "period": "Stated in a white paper dated 27 June 2024", "status": "reported", "direction": "directed", "role_group": "ownership", "temporal_status": "unknown", "claim_ids": [ "c-own-white-paper", "c-own-divisio-fees" ], "kind": "owns" }, { "id": "r-sobkow-board-bbte", "from": "sobkow", "to": "bbte", "role": "Management board member and chief executive", "period": "Until spring 2020", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-mgmt-board-2019-2020", "c-own-sobkow-luxbay-2020" ], "kind": "directs" }, { "id": "r-suszek-board-bbte", "from": "suszek", "to": "bbte", "role": "Management board member; chairman from spring 2020", "period": "By February 2020 until at least 24 September 2021", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-mgmt-board-2019-2020", "c-ast-reserves-2020" ], "kind": "directs" }, { "id": "r-sendecki-board-bbte", "from": "sendecki", "to": "bbte", "role": "Management board member; later also director of risk and compliance", "period": "By February 2020 (the 2021 report gives June 2021) until 28 August 2026", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-mgmt-board-2019-2020", "c-mgmt-board-2021", "c-mgmt-board-2023", "c-mgmt-krs-branch-board", "c-mgmt-restructuring-2025", "c-mgmt-board-may-2026", "c-mgmt-sendecki-resignation", "c-mgmt-register-changes" ], "kind": "directs" }, { "id": "r-kral-board-bbte", "from": "kral", "to": "bbte", "role": "Management board member and chief executive, able to represent the company alone", "period": "From November 2021 (register: 8 November 2021)", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-mgmt-board-2021", "c-mgmt-register-card-2026", "c-mgmt-representation", "c-mgmt-board-2023", "c-mgmt-krs-branch-board", "c-mgmt-restructuring-2025", "c-mgmt-board-may-2026" ], "kind": "directs" }, { "id": "r-buhler-board-bbte", "from": "buhler", "to": "bbte", "role": "Management board member", "period": "10 December 2023 to March 2025", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-mgmt-board-2023", "c-mgmt-krs-branch-board", "c-mgmt-restructuring-2025", "c-mgmt-buhler-capacity" ], "kind": "directs" }, { "id": "r-buhler-supervisory-bbte", "from": "buhler", "to": "bbte", "role": "Supervisory board member", "period": "March 2025 to April 2026", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-mgmt-restructuring-2025", "c-mgmt-supervisory-resignations", "c-own-single-beneficiary", "c-pay-buhler-seba", "c-mgmt-buhler-capacity" ], "kind": "directs" }, { "id": "r-dzaniasvili-supervisory-bbte", "from": "dzaniasvili", "to": "bbte", "role": "Supervisory board member", "period": "March 2025 to April 2026", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-mgmt-restructuring-2025", "c-mgmt-supervisory-resignations", "c-own-single-beneficiary" ], "kind": "directs" }, { "id": "r-chiellini-supervisory-bbte", "from": "chiellini", "to": "bbte", "role": "Supervisory board member", "period": "From March 2025; end not recorded", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-mgmt-restructuring-2025", "c-own-single-beneficiary" ], "kind": "directs" }, { "id": "r-tugo-supervisory-bbte", "from": "tugo", "to": "bbte", "role": "Chair of the supervisory board", "period": "Until April 2026", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-mgmt-supervisory-resignations" ], "kind": "directs" }, { "id": "r-jurik-mlro-bbte", "from": "jurik", "to": "bbte", "role": "Money laundering reporting officer, approved by the Financial Intelligence Unit", "period": "From 2023", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-mgmt-mlro-2023" ], "kind": "employs" }, { "id": "r-lentsius-trustee-bbte", "from": "lentsius", "to": "bbte", "role": "Trustee in bankruptcy, earlier interim administrator", "period": "Interim administrator from 27 July 2026; trustee from 27–28 August 2026", "status": "documented", "direction": "directed", "role_group": "legal", "temporal_status": "current", "claim_ids": [ "c-mgmt-register-card-2026", "c-crisis-trustee", "c-crisis-bankruptcy-notice", "c-crisis-disposal-ban", "c-crisis-first-meeting", "c-crisis-estate-figures" ], "kind": "legal" }, { "id": "r-przybylowski-committee-bbte", "from": "przybylowski", "to": "bbte", "role": "Member of the creditors' committee (pankrotitoimkond)", "period": "Elected 17 September 2026; registered from 1 October 2026", "status": "documented", "direction": "directed", "role_group": "legal", "temporal_status": "current", "claim_ids": [ "c-crisis-committee-register", "c-crisis-first-meeting" ], "kind": "legal" }, { "id": "r-keiman-committee-bbte", "from": "keiman", "to": "bbte", "role": "Member of the creditors' committee (pankrotitoimkond)", "period": "Elected 17 September 2026; registered from 1 October 2026", "status": "documented", "direction": "directed", "role_group": "legal", "temporal_status": "current", "claim_ids": [ "c-crisis-committee-register", "c-crisis-first-meeting" ], "kind": "legal" }, { "id": "r-nogacki-committee-bbte", "from": "nogacki", "to": "bbte", "role": "Member of the creditors' committee (pankrotitoimkond)", "period": "Elected 17 September 2026; registered from 1 October 2026", "status": "documented", "direction": "directed", "role_group": "legal", "temporal_status": "current", "claim_ids": [ "c-crisis-committee-register", "c-crisis-first-meeting" ], "kind": "legal" }, { "id": "r-keiman-claims-bbte", "from": "keiman", "to": "bbte", "role": "Advocate representing creditor claims of about EUR 2 million in the bankruptcy", "period": "September 2026", "status": "reported", "direction": "directed", "role_group": "legal", "temporal_status": "unknown", "claim_ids": [ "c-crisis-claims-count" ], "kind": "legal" }, { "id": "r-magnusson-petition-bbte", "from": "magnusson", "to": "bbte", "role": "Law office that represented the creditor whose petition led to the bankruptcy declaration", "period": "2026", "status": "reported", "direction": "directed", "role_group": "legal", "temporal_status": "historical", "claim_ids": [ "c-crisis-petitioner" ], "kind": "legal" }, { "id": "r-keiman-magnusson", "from": "keiman", "to": "magnusson", "role": "Advocate and partner; 25% shareholder", "period": "Shareholder from 12 August 2026", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-crisis-keiman" ], "kind": "owns" }, { "id": "r-przybylowski-kcod", "from": "przybylowski", "to": "kcod", "role": "Leads the team as licensed restructuring adviser", "period": "As of 2026", "status": "reported", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-crisis-kcod" ], "kind": "employs" }, { "id": "r-audit-advisory-bbte", "from": "audit-advisory", "to": "bbte", "role": "Auditor of the 2019–2020 financial statements (qualified opinion)", "period": "Opinion of 24 September 2021", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-ast-audit-2020" ], "kind": "employs" }, { "id": "r-crowe-bbte", "from": "crowe-dnw", "to": "bbte", "role": "Auditor of the 2021 financial statements (disclaimer of opinion)", "period": "Report of 30 November 2022", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-ast-audit-2021-disclaimer", "c-ast-audit-2021-other-grounds" ], "kind": "employs" }, { "id": "r-assertum-bbte", "from": "assertum", "to": "bbte", "role": "Auditor of the 2022–2024 consolidated statements", "period": "Registered as auditor from 20 June 2023; opinions of 12 January 2024, 30 June 2024 and 29 July 2025", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-ast-audit-2022", "c-ast-audit-2023", "c-ast-audit-2024", "c-crisis-auditor-register" ], "kind": "employs" }, { "id": "r-tamm-signed-bbte", "from": "tamm", "to": "bbte", "role": "Sworn auditor who signed the qualified opinion on the 2020 statements", "period": "24 September 2021", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-ast-audit-2020" ], "kind": "employs" }, { "id": "r-mullo-signed-bbte", "from": "mullo", "to": "bbte", "role": "Sworn auditor who signed the disclaimer of opinion on the 2021 statements", "period": "30 November 2022", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-ast-audit-2021-disclaimer" ], "kind": "employs" }, { "id": "r-tsistjakov-signed-bbte", "from": "tsistjakov", "to": "bbte", "role": "Sworn auditor who signed the opinions on the 2022–2024 statements", "period": "January 2024 to July 2025", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-ast-audit-2022", "c-ast-audit-2023", "c-ast-audit-2024" ], "kind": "employs" }, { "id": "r-tamm-audit-advisory", "from": "tamm", "to": "audit-advisory", "role": "Sole management board member and sole shareholder", "period": "From 1 December 2008", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-ast-auditor-tamm" ], "kind": "owns" }, { "id": "r-mullo-crowe", "from": "mullo", "to": "crowe-dnw", "role": "Procurator (prokurist)", "period": "From 8 October 2021", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-ast-auditor-mullo" ], "kind": "employs" }, { "id": "r-tsistjakov-assertum", "from": "tsistjakov", "to": "assertum", "role": "Management board member", "period": "From 6 May 2015", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-ast-auditor-tsistjakov" ], "kind": "directs" }, { "id": "r-bbte-owns-zonda-token", "from": "bbte", "to": "zonda-token", "role": "Sole shareholder (100%)", "period": "From 7 December 2021 per the 2021 report; consolidated from 2022; 100% at end-2024", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "unknown", "claim_ids": [ "c-grp-zonda-token-acquisition", "c-grp-consolidation-2024", "c-grp-subsidiaries-2024", "c-grp-zonda-token-dates" ], "kind": "owns" }, { "id": "r-bbte-owns-orion", "from": "bbte", "to": "orion", "role": "Sole shareholder (100%; 60,100 shares)", "period": "From 22 July 2022", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-rpt-orion-advances", "c-rpt-orion-acquisition", "c-grp-consolidation-2024", "c-grp-subsidiaries-2024", "c-grp-pl-orion-register", "c-rpt-orion-exposure" ], "kind": "owns" }, { "id": "r-bbte-invests-orion", "from": "bbte", "to": "orion", "role": "Investor making prepayments under an investment agreement (EUR 14.4 million by end-2021)", "period": "2 March 2020 to July 2022", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-rpt-orion-advances", "c-rpt-orion-investment-2020" ], "kind": "business" }, { "id": "r-bbte-lends-orion", "from": "bbte", "to": "orion", "role": "Lender under a loan agreement of 4 August 2022 (balance about EUR 75 million, as reported)", "period": "4 August 2022 to at least 16 March 2026", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-rpt-orion-loan", "c-rpt-orion-exposure" ], "kind": "pays" }, { "id": "r-bbte-owns-znd-ventures", "from": "bbte", "to": "znd-ventures", "role": "Shareholder: 50% in 2022–2023; sole shareholder from 10 January 2024", "period": "2022 onward (sole shareholder from 10 January 2024)", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-grp-znd-ventures-stake", "c-grp-znd-ventures-register", "c-grp-subsidiaries-2024", "c-grp-consolidation-2024", "c-grp-znd-ventures-financing" ], "kind": "owns" }, { "id": "r-bbte-funds-znd-ventures", "from": "bbte", "to": "znd-ventures", "role": "Financed it under an investment agreement (EUR 18.6 million of payments, as reported)", "period": "August 2022 to 6 March 2026", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-rpt-znd-ventures", "c-pay-zen-transfers" ], "kind": "pays" }, { "id": "r-bbte-iceo-agreement", "from": "bbte", "to": "iceo-red-0", "role": "Party to an investment agreement of 10 August 2022 setting up the company later named ZND Ventures OÜ", "period": "From 10 August 2022", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-rpt-znd-ventures", "c-grp-znd-ventures-financing" ], "kind": "business" }, { "id": "r-iceo-red-0-owns-znd-ventures", "from": "iceo-red-0", "to": "znd-ventures", "role": "50% shareholder", "period": "2022–2023", "status": "reported", "direction": "directed", "role_group": "ownership", "temporal_status": "historical", "claim_ids": [ "c-grp-znd-ventures-financing" ], "kind": "owns" }, { "id": "r-bbte-znd-co-associate", "from": "bbte", "to": "znd-co", "role": "Associate holding of 50%, as shown in the 2024 annual report", "period": "At 31 December 2023 and 31 December 2024", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "historical", "claim_ids": [ "c-grp-subsidiaries-2024", "c-grp-zndco-ownership" ], "kind": "owns" }, { "id": "r-bbte-owns-bb-bahamas", "from": "bbte", "to": "bb-bahamas", "role": "Included in the consolidation group; shareholding not disclosed", "period": "From 2024", "status": "reported", "direction": "directed", "role_group": "ownership", "temporal_status": "unknown", "claim_ids": [ "c-grp-consolidation-2024", "c-grp-bs-group-status" ], "kind": "owns" }, { "id": "r-bbte-zonda-gibraltar", "from": "bbte", "to": "zonda-gibraltar", "role": "Reported in its own annual report as having established the company; shareholding not stated", "period": "2022", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "unknown", "claim_ids": [ "c-grp-gi-zonda-gibraltar" ], "kind": "owns" }, { "id": "r-bbte-branch-it", "from": "bbte", "to": "bb-trade-it", "role": "Italian branch of the company (not a separate legal entity), registered with the OAM under No. PSV48", "period": "Registered from 22 July 2022; in the consolidation group from 2024", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "unknown", "claim_ids": [ "c-brand-contacts", "c-grp-it-branch", "c-crisis-debt-listing" ], "kind": "owns" }, { "id": "r-bbte-branch-pl", "from": "bbte", "to": "bbte-pl-branch", "role": "Polish branch (oddział) of the company", "period": "Registered in the KRS from 16 December 2024", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-grp-pl-branch", "c-mgmt-krs-branch-board" ], "kind": "owns" }, { "id": "r-bbte-lends-bb-cyprus", "from": "bbte", "to": "bb-cyprus", "role": "Lender of EUR 300,000 in 2025, described as a group company (as reported)", "period": "April to October 2025", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-grp-cy-lt-group" ], "kind": "pays" }, { "id": "r-bbte-lends-bb-lithuania", "from": "bbte", "to": "bb-lithuania", "role": "Lender of EUR 10,000, described as a group company (as reported)", "period": "From 5 May 2025", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-grp-cy-lt-group" ], "kind": "pays" }, { "id": "r-bbte-funds-bb-bahamas", "from": "bbte", "to": "bb-bahamas", "role": "Credited 400,000 USDT and 4.9 million USDC by balance adjustment without an agreement (as reported)", "period": "June to September 2025", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-rpt-bahamas-balances" ], "kind": "pays" }, { "id": "r-bb-bahamas-rents-bbte", "from": "bb-bahamas", "to": "bbte", "role": "Outsourcing provider from June 2024 and lessee of the exchange's infrastructure, software and addresses from 21 February 2025 (as reported)", "period": "From June 2024", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-rpt-bahamas-arrangements" ], "kind": "business" }, { "id": "r-bb-bahamas-orion", "from": "bb-bahamas", "to": "orion", "role": "Its Nassau accounting was invoiced to Orion Software (as reported)", "period": "2024–2025", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-rpt-bahamas-arrangements" ], "kind": "business" }, { "id": "r-kral-orion", "from": "kral", "to": "orion", "role": "President of the management board; registered beneficial owner", "period": "From 26 March 2020", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-grp-pl-orion-register" ], "kind": "directs" }, { "id": "r-kral-znd-ventures", "from": "kral", "to": "znd-ventures", "role": "Procurator from 28 June 2023; management board member from 20 April 2026; registered beneficial owner (indirect)", "period": "From 28 June 2023", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-grp-znd-ventures-register" ], "kind": "directs" }, { "id": "r-znd-ventures-owns-znd-co", "from": "znd-ventures", "to": "znd-co", "role": "Sole shareholder (50% before, as reported)", "period": "Sole shareholder from 14 May 2025", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-grp-zndco-register", "c-grp-zndco-ownership" ], "kind": "owns" }, { "id": "r-iceo-red-0-owns-znd-co", "from": "iceo-red-0", "to": "znd-co", "role": "50% shareholder", "period": "Until 14 May 2025", "status": "reported", "direction": "directed", "role_group": "ownership", "temporal_status": "historical", "claim_ids": [ "c-grp-zndco-ownership" ], "kind": "owns" }, { "id": "r-sroka-znd-co", "from": "sroka", "to": "znd-co", "role": "Management board member", "period": "From 6 December 2023", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-grp-zndco-register", "c-grp-zndco-ownership" ], "kind": "directs" }, { "id": "r-kral-ubo-znd-co", "from": "kral", "to": "znd-co", "role": "Registered beneficial owner through an indirect holding", "period": "From 6 December 2023", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-grp-zndco-register" ], "kind": "owns" }, { "id": "r-sroka-owns-iceo-red-0", "from": "sroka", "to": "iceo-red-0", "role": "50% shareholder and sole management board member", "period": "From 14 July 2022", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-grp-iceo-red-0" ], "kind": "owns" }, { "id": "r-duniec-owns-iceo-red-0", "from": "duniec", "to": "iceo-red-0", "role": "50% shareholder", "period": "From 14 July 2022", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-grp-iceo-red-0" ], "kind": "owns" }, { "id": "r-iceo-red-0-owns-admitrade", "from": "iceo-red-0", "to": "admitrade", "role": "Sole shareholder", "period": "From 2 September 2023", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-grp-admitrade-register" ], "kind": "owns" }, { "id": "r-sroka-admitrade", "from": "sroka", "to": "admitrade", "role": "Management board member; registered beneficial owner (indirect)", "period": "From 7 September 2021", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-grp-admitrade-register", "c-rpt-admitrade-line" ], "kind": "directs" }, { "id": "r-duniec-admitrade", "from": "duniec", "to": "admitrade", "role": "Registered beneficial owner through an indirect holding", "period": "From 12 September 2022", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-grp-admitrade-register" ], "kind": "owns" }, { "id": "r-bbte-admitrade-credit", "from": "bbte", "to": "admitrade", "role": "Lender under a credit line (limit EUR 100 million from December 2023), terminated 28 July 2025 (as reported)", "period": "12 September 2022 to 28 July 2025", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-rpt-admitrade-line", "c-rpt-admitrade-termination" ], "kind": "pays" }, { "id": "r-beone-group-owns-beone-europe", "from": "beone-group", "to": "beone-europe", "role": "Sole shareholder (500,000 shares)", "period": "From 19 June 2025 (incorporated 27 January 2025)", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-grp-beone-europe", "c-grp-beone-ownership" ], "kind": "owns" }, { "id": "r-znd-ventures-beone-group", "from": "znd-ventures", "to": "beone-group", "role": "50% shareholder", "period": "As of 2025", "status": "reported", "direction": "directed", "role_group": "ownership", "temporal_status": "unknown", "claim_ids": [ "c-grp-beone-ownership" ], "kind": "owns" }, { "id": "r-iceo-group-beone-group", "from": "iceo-group", "to": "beone-group", "role": "50% shareholder", "period": "As of 2025", "status": "reported", "direction": "directed", "role_group": "ownership", "temporal_status": "unknown", "claim_ids": [ "c-grp-beone-ownership" ], "kind": "owns" }, { "id": "r-sroka-beone-group", "from": "sroka", "to": "beone-group", "role": "Board member", "period": "From 2024; sole signature from July 2025, joint from September 2025", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-grp-beone-group" ], "kind": "directs" }, { "id": "r-sroka-iceo-group", "from": "sroka", "to": "iceo-group", "role": "Described as one of its owners", "period": "As of 2025", "status": "reported", "direction": "directed", "role_group": "ownership", "temporal_status": "unknown", "claim_ids": [ "c-grp-beone-ownership" ], "kind": "owns" }, { "id": "r-duniec-iceo-group", "from": "duniec", "to": "iceo-group", "role": "Described as one of its owners", "period": "As of 2025", "status": "reported", "direction": "directed", "role_group": "ownership", "temporal_status": "unknown", "claim_ids": [ "c-grp-beone-ownership" ], "kind": "owns" }, { "id": "r-kral-bb-bahamas", "from": "kral", "to": "bb-bahamas", "role": "Principal and director", "period": "Register as at 30 November 2025", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-grp-bs-scb-officers" ], "kind": "directs" }, { "id": "r-sendecki-bb-bahamas", "from": "sendecki", "to": "bb-bahamas", "role": "Director", "period": "Register as at 30 November 2025", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-grp-bs-scb-officers" ], "kind": "directs" }, { "id": "r-buhler-bb-bahamas", "from": "buhler", "to": "bb-bahamas", "role": "Director", "period": "Register as at 30 November 2025", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-grp-bs-scb-officers" ], "kind": "directs" }, { "id": "r-chipman-bb-bahamas", "from": "chipman", "to": "bb-bahamas", "role": "Director and chief executive officer", "period": "Register as at 30 November 2025", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-grp-bs-scb-officers" ], "kind": "directs" }, { "id": "r-wilkinson-bb-bahamas", "from": "wilkinson", "to": "bb-bahamas", "role": "Compliance officer and money laundering reporting officer", "period": "Register as at 30 November 2025", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-grp-bs-scb-officers" ], "kind": "employs" }, { "id": "r-kral-bb-lithuania", "from": "kral", "to": "bb-lithuania", "role": "Director (as reported)", "period": "2025", "status": "reported", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-grp-cy-lt-group" ], "kind": "directs" }, { "id": "r-kral-branch-pl", "from": "kral", "to": "bbte-pl-branch", "role": "Branch director (dyrektor oddziału)", "period": "From 16 December 2024", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-grp-pl-branch", "c-mgmt-krs-branch-board" ], "kind": "directs" }, { "id": "r-kral-bb-florida", "from": "kral", "to": "bb-florida", "role": "Chief executive officer", "period": "Corporation filed 14 November 2024; officer in the 2026 record", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-grp-us-florida", "c-lic-florida-msb" ], "kind": "directs" }, { "id": "r-terlinden-divisio", "from": "terlinden", "to": "divisio", "role": "Sole board member with sole signature", "period": "24 June 2021 to April 2026 (departure published 27 April 2026)", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-own-divisio-board", "c-own-terlinden-nvp", "c-own-divisio-fees", "c-grp-nvp-press" ], "kind": "directs" }, { "id": "r-divisio-domicile-terlinden", "from": "divisio", "to": "terlinden", "role": "Registered domicile c/o Dr. André Terlinden, Baarerstrasse 78, Zug", "period": "From July 2022", "status": "documented", "direction": "undirected", "role_group": "infrastructure", "temporal_status": "unknown", "claim_ids": [ "c-own-divisio-board" ], "kind": "other" }, { "id": "r-terlinden-zonda-token", "from": "terlinden", "to": "zonda-token", "role": "President of the board with sole signature", "period": "December 2021 to 11 May 2026", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-grp-zonda-token-incorporation", "c-grp-zonda-token-dissolution" ], "kind": "directs" }, { "id": "r-gwozdz-zonda-token", "from": "gwozdz", "to": "zonda-token", "role": "Board member", "period": "From December 2021; still registered in September 2026", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-grp-zonda-token-incorporation", "c-grp-zonda-token-dates", "c-grp-zonda-token-dissolution" ], "kind": "directs" }, { "id": "r-kral-zonda-token", "from": "kral", "to": "zonda-token", "role": "Board member", "period": "From December 2021; still registered in September 2026", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-grp-zonda-token-incorporation", "c-grp-zonda-token-dates", "c-grp-zonda-token-dissolution" ], "kind": "directs" }, { "id": "r-terlinden-bb-switzerland", "from": "terlinden", "to": "bb-switzerland", "role": "Chair of the board at registration; later board member", "period": "30 September 2020 to 29 June 2022", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-grp-bbts-incorporation", "c-grp-bbts-board-2022" ], "kind": "directs" }, { "id": "r-suszek-bb-switzerland", "from": "suszek", "to": "bb-switzerland", "role": "Board member", "period": "Until 24 March 2022", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-grp-bbts-board-2022" ], "kind": "directs" }, { "id": "r-fenner-bb-switzerland", "from": "fenner", "to": "bb-switzerland", "role": "Board member; sole signature from 6 May 2026; liquidator from 16 July 2026", "period": "From 29 June 2022", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-grp-bbts-board-2022", "c-grp-bbts-board-2024", "c-grp-bbts-board-2026", "c-grp-bbts-liquidation", "c-grp-bbts-register-2026", "c-grp-bbts-ownership" ], "kind": "directs" }, { "id": "r-kral-bb-switzerland", "from": "kral", "to": "bb-switzerland", "role": "President of the board without signing authority; board member in the 2026 register data", "period": "Entered 10 January 2024", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-grp-bbts-board-2024", "c-grp-bbts-register-2026" ], "kind": "directs" }, { "id": "r-buhler-bb-switzerland", "from": "buhler", "to": "bb-switzerland", "role": "Board member signing jointly by two", "period": "By 10 January 2024 until 6 May 2026", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-grp-bbts-board-2024", "c-grp-bbts-board-2026", "c-grp-bbts-ownership", "c-mgmt-giloca" ], "kind": "directs" }, { "id": "r-bbte-owns-bb-switzerland", "from": "bbte", "to": "bb-switzerland", "role": "Described as a wholly owned subsidiary by claimants' counsel; ownership not shown in the register or the 2024 consolidation list", "period": "Not dated", "status": "reported", "direction": "directed", "role_group": "ownership", "temporal_status": "unknown", "claim_ids": [ "c-grp-bbts-ownership" ], "kind": "owns" }, { "id": "r-bb-switzerland-bbte-terms", "from": "bb-switzerland", "to": "bbte", "role": "Tripartite partner for zondacrypto Swiss clients: takes orders and handles fiat, which it passes to BB Trade Estonia for execution", "period": "Terms in force from 30 June 2025", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-brand-swiss-terms", "c-brand-swiss-fiat" ], "kind": "business" }, { "id": "r-brand-entities", "from": "bbte", "to": "bb-switzerland", "role": "Both described as entities using the zondacrypto trademark", "period": "January 2025 release", "status": "documented", "direction": "undirected", "role_group": "associations", "temporal_status": "unknown", "claim_ids": [ "c-brand-trademark-disclaimer" ], "kind": "other" }, { "id": "r-bb-switzerland-nvp-address", "from": "bb-switzerland", "to": "nvp", "role": "Registered c/o Neupert, Vuille & Partner, Dufourstrasse 58, Zollikon", "period": "From July 2026", "status": "documented", "direction": "undirected", "role_group": "infrastructure", "temporal_status": "current", "claim_ids": [ "c-grp-bbts-liquidation" ], "kind": "other" }, { "id": "r-terlinden-nvp", "from": "terlinden", "to": "nvp", "role": "Partner and shareholder of the law firm (press report)", "period": "As of April 2026", "status": "reported", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-own-terlinden-nvp" ], "kind": "employs" }, { "id": "r-fenner-nvp", "from": "fenner", "to": "nvp", "role": "Lawyer; partner since 2021 (senior associate 2018–2020)", "period": "From 2018", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-grp-fenner-nvp" ], "kind": "employs" }, { "id": "r-bb-switzerland-incore", "from": "bb-switzerland", "to": "incore", "role": "Banking partner announced for the Swiss brand entity", "period": "Announced 14 January 2025", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-pay-incore", "c-lic-swiss-vqf", "c-brand-trademark-disclaimer" ], "kind": "business" }, { "id": "r-bb-switzerland-sbf", "from": "bb-switzerland", "to": "swiss-blockchain-federation", "role": "Member (self-statement)", "period": "January 2025 release", "status": "reported", "direction": "directed", "role_group": "associations", "temporal_status": "unknown", "claim_ids": [ "c-lic-swiss-vqf" ], "kind": "other" }, { "id": "r-buhler-sbf", "from": "buhler", "to": "swiss-blockchain-federation", "role": "Member of the executive board (Vorstand)", "period": "Until 15 July 2026", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-grp-buhler-sbf" ], "kind": "directs" }, { "id": "r-divisio-owns-zondacrypto-sk", "from": "divisio", "to": "zondacrypto-sk", "role": "Sole shareholder (EUR 5,000 contribution)", "period": "From 22 April 2023", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-grp-sk-owner", "c-own-divisio-zondacrypto-sk" ], "kind": "owns" }, { "id": "r-kral-zondacrypto-sk", "from": "kral", "to": "zondacrypto-sk", "role": "Sole statutory director (konateľ)", "period": "From 25 March 2023 (entry effective 22 April 2023)", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-grp-sk-director" ], "kind": "directs" }, { "id": "r-divisio-owns-bb-poland", "from": "divisio", "to": "bb-poland", "role": "Sole shareholder (10 shares, PLN 5,000)", "period": "As of the KRS entry of 13 October 2025", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-grp-pl-bb-poland" ], "kind": "owns" }, { "id": "r-kral-bb-poland", "from": "kral", "to": "bb-poland", "role": "Chief executive from registration; liquidator from 15 September 2025; registered beneficial owner", "period": "From 23 June 2020", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-grp-pl-bb-poland" ], "kind": "directs" }, { "id": "r-bb-poland-orion-address", "from": "bb-poland", "to": "orion", "role": "Same registered seat: Aleja Wojciecha Korfantego 141B, Katowice", "period": "As of 2025–2026", "status": "documented", "direction": "undirected", "role_group": "infrastructure", "temporal_status": "unknown", "claim_ids": [ "c-grp-pl-bb-poland" ], "kind": "other" }, { "id": "r-kral-fundacja", "from": "kral", "to": "fundacja-zondacrypto", "role": "President of the management board; registered beneficial owner", "period": "From 9 May 2024", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-grp-pl-fundacja" ], "kind": "directs" }, { "id": "r-fundacja-branch-address", "from": "fundacja-zondacrypto", "to": "bbte-pl-branch", "role": "Same registered seat: Ligocka 103, Katowice", "period": "As of 2026", "status": "documented", "direction": "undirected", "role_group": "infrastructure", "temporal_status": "unknown", "claim_ids": [ "c-grp-pl-fundacja" ], "kind": "other" }, { "id": "r-kral-owns-seed", "from": "kral", "to": "seed-investments", "role": "Sole shareholder and registered beneficial owner", "period": "From 9 April 2020", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-grp-kral-seed" ], "kind": "owns" }, { "id": "r-kral-ceo-seed", "from": "kral", "to": "seed-investments", "role": "Chief executive", "period": "9 April 2020 to 5 January 2026", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-grp-kral-seed" ], "kind": "directs" }, { "id": "r-gwozdz-seed", "from": "gwozdz", "to": "seed-investments", "role": "Liquidator", "period": "From 5 January 2026", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-grp-kral-seed" ], "kind": "employs" }, { "id": "r-kral-owns-digesta", "from": "kral", "to": "digesta-pro", "role": "Sole shareholder and registered beneficial owner", "period": "From 11 February 2021", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-grp-kral-digesta" ], "kind": "owns" }, { "id": "r-kral-ceo-digesta", "from": "kral", "to": "digesta-pro", "role": "Chief executive", "period": "11 February 2021 to 15 January 2026", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-grp-kral-digesta" ], "kind": "directs" }, { "id": "r-kral-decori", "from": "kral", "to": "decori", "role": "Management board member", "period": "10 July 2020 to 3 June 2024", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-grp-kral-decori" ], "kind": "directs" }, { "id": "r-kral-duraj", "from": "kral", "to": "duraj-reck-kral", "role": "Partner of the advocates and tax advisers partnership", "period": "14 March 2011 to 9 September 2020", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-grp-kral-duraj" ], "kind": "employs" }, { "id": "r-kral-expofer", "from": "kral", "to": "expofer", "role": "Statutory director (jednatel)", "period": "From 3 January 2022 (entered 2 February 2022)", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-grp-cz-expofer-director" ], "kind": "directs" }, { "id": "r-kral-expofer-described", "from": "kral", "to": "expofer", "role": "Described as his company in the exchange's 2023 related-party statement (as reported) and as part of his network (press)", "period": "As reported in 2026", "status": "reported", "direction": "directed", "role_group": "associations", "temporal_status": "unknown", "claim_ids": [ "c-rpt-expofer-receivable", "c-crim-donations-press" ], "kind": "other" }, { "id": "r-suszek-expofer", "from": "suszek", "to": "expofer", "role": "Signed for the company as its executive (jednatel) on 2 March 2020 (as reported)", "period": "2 March 2020", "status": "reported", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-rpt-orion-investment-2020" ], "kind": "directs" }, { "id": "r-divisio-owns-expofer", "from": "divisio", "to": "expofer", "role": "100% shareholder according to an aggregator's unverified network view", "period": "Shown as current in 2026", "status": "reported", "direction": "directed", "role_group": "ownership", "temporal_status": "unknown", "claim_ids": [ "c-grp-cz-expofer-owners" ], "kind": "owns" }, { "id": "r-luxbay-owns-expofer", "from": "luxbay", "to": "expofer", "role": "Former 100% shareholder according to an aggregator's unverified network view", "period": "Dates not shown", "status": "reported", "direction": "directed", "role_group": "ownership", "temporal_status": "historical", "claim_ids": [ "c-grp-cz-expofer-owners" ], "kind": "owns" }, { "id": "r-admi-expofer", "from": "admi-business", "to": "expofer", "role": "Named in an April 2024 publication on changes of shareholdings", "period": "Before or in April 2024", "status": "reported", "direction": "directed", "role_group": "ownership", "temporal_status": "historical", "claim_ids": [ "c-grp-cz-expofer-owners" ], "kind": "owns" }, { "id": "r-bbte-expofer-receivable", "from": "bbte", "to": "expofer", "role": "Creditor for prepayments of about EUR 30.45 million at end-2024 and buyer of its services (as reported)", "period": "2023–2024", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-rpt-expofer-receivable" ], "kind": "pays" }, { "id": "r-bbte-guarantee-expofer", "from": "bbte", "to": "expofer", "role": "Guarantor of Expofer's obligations of up to EUR 567,240 under a contract with ZEN UAB", "period": "28 December 2020 to 2022 (obligations fulfilled in 2022)", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-rpt-expofer-guarantee" ], "kind": "business" }, { "id": "r-bbte-zen-contract", "from": "bbte", "to": "zen", "role": "Party to the contract of 28 December 2020 with ZEN UAB and Expofer", "period": "From 28 December 2020", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-rpt-expofer-guarantee" ], "kind": "business" }, { "id": "r-orion-expofer-commitment", "from": "orion", "to": "expofer", "role": "Undertook to recapitalise Expofer up to PLN 100 million (as reported)", "period": "2 March 2020", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-rpt-orion-investment-2020", "c-rpt-orion-exposure" ], "kind": "business" }, { "id": "r-bbte-fenige", "from": "bbte", "to": "fenige", "role": "Client of Fenige: card-payment agreement (2020); listed payment operator for client deposits and withdrawals", "period": "2020 to 2026", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-pay-2020-fenige", "c-pay-revenue-2024", "c-pay-operator-list", "c-pay-accounts-list" ], "kind": "business" }, { "id": "r-bbte-poczta-polska", "from": "bbte", "to": "poczta-polska", "role": "PLN deposits and cash withdrawals through Polish Post offices", "period": "2020", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-pay-2020-poczta" ], "kind": "business" }, { "id": "r-payment-technology-bbte", "from": "payment-technology", "to": "bbte", "role": "Provided payment services (money remittance) under a cooperation agreement, including Polish Post withdrawals", "period": "By 2020 until April–June 2022", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-pay-2020-poczta", "c-pay-pt-cooperation", "c-pay-trypay-2022", "c-pay-pt-volume" ], "kind": "business" }, { "id": "r-trypay-bbte", "from": "trypay", "to": "bbte", "role": "Payment institution providing payment services under a partnership agreement", "period": "29 April 2022 to 20 April 2026 (terminated with immediate effect)", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-pay-trypay-2022", "c-pay-trypay-termination", "c-pay-revenue-2024", "c-pay-operator-list", "c-pay-pt-volume", "c-pay-accounts-list" ], "kind": "business" }, { "id": "r-trypay-payment-technology", "from": "trypay", "to": "payment-technology", "role": "Took over Payment Technology's agreement with BB Trade Estonia by assignment", "period": "29 April 2022", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-pay-trypay-2022" ], "kind": "business" }, { "id": "r-femion-owns-trypay", "from": "femion", "to": "trypay", "role": "Sole shareholder", "period": "From 27 July 2022", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-pay-trypay-ownership", "c-pay-femion-kral", "c-pay-trypay-termination", "c-pay-trypay-2022", "c-pay-trypay-insolvency", "c-pay-femion-insolvency", "c-pay-kral-loan-femion" ], "kind": "owns" }, { "id": "r-femion-owns-payment-technology", "from": "femion", "to": "payment-technology", "role": "Acquired the company in 2022; wrote down the shares after its bankruptcy", "period": "2022 to 2024", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "historical", "claim_ids": [ "c-pay-pt-bankruptcy", "c-pay-pt-volume" ], "kind": "owns" }, { "id": "r-kral-femion", "from": "kral", "to": "femion", "role": "Largest shareholder (49.8674% at 31 December 2025); registered beneficial owner", "period": "At 31 December 2025", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "unknown", "claim_ids": [ "c-pay-femion-kral" ], "kind": "owns" }, { "id": "r-kral-ubo-trypay", "from": "kral", "to": "trypay", "role": "Registered beneficial owner", "period": "As of the 2026 KRS entry", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-pay-trypay-ownership", "c-pay-femion-kral" ], "kind": "owns" }, { "id": "r-kral-lends-femion", "from": "kral", "to": "femion", "role": "Lender: EUR 60,000 loan increased to EUR 120,000", "period": "After 31 December 2025", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-pay-kral-loan-femion" ], "kind": "pays" }, { "id": "r-bbte-zen-paybyzen", "from": "bbte", "to": "zen", "role": "Client of ZEN UAB: PayByZEN deposits and withdrawals; listed payment operator", "period": "2021 to 2026", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-pay-paybyzen", "c-pay-revenue-2024", "c-pay-operator-list" ], "kind": "business" }, { "id": "r-bbte-zen-account", "from": "bbte", "to": "zen", "role": "Account at ZEN.COM used for monthly outgoing transfers (as reported)", "period": "Until 31 March 2026", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-pay-accounts-list", "c-pay-zen-transfers" ], "kind": "business" }, { "id": "r-bbte-clear-junction", "from": "bbte", "to": "clear-junction", "role": "Listed payment operator for client deposits and withdrawals; account holder (as reported)", "period": "As listed in 2026", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-pay-operator-list", "c-pay-accounts-list" ], "kind": "business" }, { "id": "r-bbte-kip", "from": "bbte", "to": "kip", "role": "Listed payment operator (Tpay) for client deposits and withdrawals; account holder (as reported)", "period": "As listed in 2026", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-pay-operator-list", "c-pay-accounts-list" ], "kind": "business" }, { "id": "r-bbte-amina-stake", "from": "bbte", "to": "amina", "role": "Holder of B shares / participation certificates (about 1.01%); agreed in January 2025 to sell them", "period": "2020 to January 2025 (closing of the sale not shown)", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "unknown", "claim_ids": [ "c-pay-seba-stake", "c-pay-amina-sale", "c-pay-amina-price-account" ], "kind": "owns" }, { "id": "r-amina-lends-bbte", "from": "amina", "to": "bbte", "role": "Lender: short-term loans of EUR 5 million (2022) and EUR 10 million (2023) at 4%", "period": "At 31 December 2022 and 2023; none at end-2024", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-pay-seba-loans" ], "kind": "pays" }, { "id": "r-bbte-amina-account", "from": "bbte", "to": "amina", "role": "Account holder (as reported)", "period": "Including June 2023", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-pay-amina-price-account", "c-pay-accounts-list", "c-rpt-suszek-receipts-2023" ], "kind": "business" }, { "id": "r-buhler-amina", "from": "buhler", "to": "amina", "role": "Co-founder and first chief executive of SEBA Bank (as reported)", "period": "Before his roles at BB Trade Estonia", "status": "reported", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-pay-buhler-seba" ], "kind": "employs" }, { "id": "r-bbte-sells-ll-bvi", "from": "bbte", "to": "ll-bvi", "role": "Seller of AMINA participation certificates for CHF 2,656,250 (as reported; closing not shown)", "period": "Agreement of 21 January 2025", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-pay-amina-sale" ], "kind": "business" }, { "id": "r-bbte-sygnum", "from": "bbte", "to": "sygnum", "role": "Account holder: designated account for the certificate price; EUR 330,000 transferred on 27 March 2026 (as reported)", "period": "2025–2026", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-pay-amina-price-account", "c-pay-accounts-list", "c-rpt-march-2026-outflows" ], "kind": "business" }, { "id": "r-bbte-payward", "from": "bbte", "to": "payward", "role": "Transferred crypto-assets to the Kraken exchange before the withdrawal crisis (as reported)", "period": "December 2025 to April 2026", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-pay-kraken", "c-ast-hot-wallet-forensics" ], "kind": "business" }, { "id": "r-bbte-fireblocks", "from": "bbte", "to": "fireblocks", "role": "Wallet-custody platform for client vaults (as reported from an export)", "period": "From 25 March 2021 to 2026", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-ast-fireblocks-2024", "c-ast-vault-creation", "c-pay-accounts-list" ], "kind": "business" }, { "id": "r-bbte-bitgo", "from": "bbte", "to": "bitgo", "role": "Custodian for bitcoin deposits (as reported); migration to BitGo V2 planned for 2024", "period": "2024–2025", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-ast-bitgo-plan", "c-ast-fireblocks-2024", "c-pay-accounts-list" ], "kind": "business" }, { "id": "r-bbte-giloca", "from": "bbte", "to": "giloca", "role": "Client of Giloca AG for services of EUR 101,316 (2023) and EUR 244,100 (2024) (as reported)", "period": "2023–2024", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-mgmt-giloca" ], "kind": "business" }, { "id": "r-buhler-giloca", "from": "buhler", "to": "giloca", "role": "Board member", "period": "As of 2026", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "current", "claim_ids": [ "c-mgmt-giloca" ], "kind": "directs" }, { "id": "r-bbte-lends-divisio", "from": "bbte", "to": "divisio", "role": "Lender: EUR 2.7 million loan to the parent company, repaid in 2022", "period": "2021–2022", "status": "documented", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-rpt-divisio-loan" ], "kind": "pays" }, { "id": "r-divisio-invoices-bbte", "from": "divisio", "to": "bbte", "role": "Invoiced services of EUR 200,000 (2023) and EUR 400,000 (2024) (as reported)", "period": "2023–2024", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-own-divisio-fees" ], "kind": "business" }, { "id": "r-bbte-lends-kral", "from": "bbte", "to": "kral", "role": "Lender of EUR 407,297 (borrower identified by claimants' counsel)", "period": "At 31 December 2024", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-rpt-kral-loan" ], "kind": "pays" }, { "id": "r-bbte-pays-kral-2026", "from": "bbte", "to": "kral", "role": "Fourteen payments of EUR 501,037.80 in total (as reported)", "period": "2 to 24 March 2026", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-rpt-march-2026-outflows" ], "kind": "pays" }, { "id": "r-bbte-lends-sb-bay", "from": "bbte", "to": "sb-bay", "role": "Lender of EUR 500,000, PLN 495,000 and PLN 200,000, unpaid at end-2023 (as reported)", "period": "From summer 2020", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-rpt-sb-bay-loans", "c-rpt-expofer-receivable" ], "kind": "pays" }, { "id": "r-suszek-sb-bay", "from": "suszek", "to": "sb-bay", "role": "Director and owner (as reported)", "period": "2020", "status": "reported", "direction": "directed", "role_group": "ownership", "temporal_status": "unknown", "claim_ids": [ "c-rpt-sb-bay-loans", "c-rpt-expofer-receivable" ], "kind": "owns" }, { "id": "r-suszek-pays-bbte-2023", "from": "suszek", "to": "bbte", "role": "Named as sender of EUR 1,041,826.22 and PLN 1,323,493.15 received in June 2023 (as reported; control of the sending account open)", "period": "6 and 12 June 2023", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "historical", "claim_ids": [ "c-rpt-suszek-receipts-2023" ], "kind": "pays" }, { "id": "r-bitbay-licenses-bbte", "from": "bitbay", "to": "bbte", "role": "Licensed the operation of the BitBay exchange to BB Trade Estonia (as reported)", "period": "From November 2019", "status": "reported", "direction": "directed", "role_group": "business", "temporal_status": "unknown", "claim_ids": [ "c-brand-bitbay-licensing" ], "kind": "business" }, { "id": "r-bitbay-brand-predecessor", "from": "bitbay", "to": "bbte", "role": "Earlier operator of the exchange brand; no legal succession shown", "period": "Until 2018–2019", "status": "reported", "direction": "directed", "role_group": "associations", "temporal_status": "historical", "claim_ids": [ "c-brand-lineage" ], "kind": "other" }, { "id": "r-pinewood-transfer-bbte", "from": "pinewood-holdings", "to": "bbte", "role": "Exchange operations transferred to BB Trade Estonia (as reported); no legal succession shown", "period": "May 2018 to November 2019", "status": "reported", "direction": "directed", "role_group": "associations", "temporal_status": "historical", "claim_ids": [ "c-brand-lineage", "c-brand-bitbay-licensing" ], "kind": "other" }, { "id": "r-suszek-bitbay", "from": "suszek", "to": "bitbay", "role": "Commercial proxy (prokurent), then chief executive", "period": "28 May 2014 to 17 February 2026 (chief executive from 21 September 2017)", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-brand-bitbay-registry", "c-grp-suszek-bitbay" ], "kind": "directs" }, { "id": "r-arial-bitbay", "from": "arial", "to": "bitbay", "role": "Shareholder (41.4% in 2019, as reported)", "period": "26 July 2018 to 17 February 2026", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "historical", "claim_ids": [ "c-brand-bitbay-owners", "c-grp-suszek-uae", "c-grp-suszek-bitbay-shares" ], "kind": "owns" }, { "id": "r-central-bay-bitbay", "from": "central-bay", "to": "bitbay", "role": "Shareholder (13.8%, as reported)", "period": "26 July 2018 to 17 February 2026", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "historical", "claim_ids": [ "c-brand-bitbay-owners", "c-grp-suszek-bitbay-shares" ], "kind": "owns" }, { "id": "r-skybay-bitbay", "from": "skybay", "to": "bitbay", "role": "Largest shareholder (44.8% in 2019, as reported)", "period": "26 July 2018 to 17 February 2026", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "historical", "claim_ids": [ "c-brand-bitbay-owners", "c-grp-suszek-uae", "c-grp-suszek-bitbay-shares" ], "kind": "owns" }, { "id": "r-suszek-skybay", "from": "suszek", "to": "skybay", "role": "Partner (49%) and manager, per register printouts described by claimants' counsel", "period": "Licence of 28 February 2017", "status": "reported", "direction": "directed", "role_group": "ownership", "temporal_status": "unknown", "claim_ids": [ "c-grp-suszek-uae", "c-grp-suszek-bitbay-shares" ], "kind": "owns" }, { "id": "r-arial-skybay-office", "from": "arial", "to": "skybay", "role": "Same office address (as reported)", "period": "From 9 May 2018", "status": "reported", "direction": "undirected", "role_group": "infrastructure", "temporal_status": "unknown", "claim_ids": [ "c-grp-suszek-uae" ], "kind": "other" }, { "id": "r-luxbay-owns-pinewood", "from": "luxbay", "to": "pinewood-holdings", "role": "Shareholder", "period": "As shown in Maltese register data (updated February 2025)", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "unknown", "claim_ids": [ "c-brand-pinewood-registry" ], "kind": "owns" }, { "id": "r-sobkow-owns-pinewood", "from": "sobkow", "to": "pinewood-holdings", "role": "First and sole shareholder at incorporation (as reported)", "period": "From 10 May 2018", "status": "reported", "direction": "directed", "role_group": "ownership", "temporal_status": "historical", "claim_ids": [ "c-brand-pinewood-history" ], "kind": "owns" }, { "id": "r-sobkow-pinewood", "from": "sobkow", "to": "pinewood-holdings", "role": "Director", "period": "10 May 2018 to 22 June 2021", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-brand-pinewood-registry", "c-brand-pinewood-history" ], "kind": "directs" }, { "id": "r-suszek-pinewood", "from": "suszek", "to": "pinewood-holdings", "role": "Director and legal representative; sole director from 22 June 2021", "period": "As shown in register data", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-brand-pinewood-registry", "c-brand-pinewood-history" ], "kind": "directs" }, { "id": "r-suszek-luxbay", "from": "suszek", "to": "luxbay", "role": "Director", "period": "9 July 2021 to 31 December 2025", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-grp-suszek-luxbay-sb", "c-own-luxbay-entity" ], "kind": "directs" }, { "id": "r-suszek-sb-investment", "from": "suszek", "to": "sb-investment", "role": "Director", "period": "9 July 2021 to 14 November 2023", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "historical", "claim_ids": [ "c-grp-suszek-luxbay-sb" ], "kind": "directs" }, { "id": "r-kral-sb-investment", "from": "kral", "to": "sb-investment", "role": "Director", "period": "From 13 November 2023", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-grp-suszek-luxbay-sb" ], "kind": "directs" }, { "id": "r-suszek-creative-invest", "from": "suszek", "to": "creative-invest", "role": "Sole shareholder and management board member", "period": "From February 2018", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-grp-suszek-creative-invest" ], "kind": "owns" }, { "id": "r-creative-invest-bbte-address", "from": "creative-invest", "to": "bbte", "role": "Same registered address (Lõõtsa tn 5, Tallinn) and contact e-mail as BB Trade Estonia in 2019–2020", "period": "2019–2020", "status": "documented", "direction": "undirected", "role_group": "infrastructure", "temporal_status": "historical", "claim_ids": [ "c-grp-suszek-creative-invest" ], "kind": "other" }, { "id": "r-sobkow-ico-house", "from": "sobkow", "to": "ico-house", "role": "Sole shareholder, registered beneficial owner and supervisory board member", "period": "From 6 July 2018", "status": "documented", "direction": "directed", "role_group": "ownership", "temporal_status": "current", "claim_ids": [ "c-grp-sobkow-ico-house" ], "kind": "owns" }, { "id": "r-suszek-ico-house", "from": "suszek", "to": "ico-house", "role": "Supervisory board member", "period": "Appointed 6 July 2018", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-grp-sobkow-ico-house" ], "kind": "directs" }, { "id": "r-sroka-ico-house", "from": "sroka", "to": "ico-house", "role": "Supervisory board member", "period": "Appointed 6 July 2018", "status": "documented", "direction": "directed", "role_group": "people", "temporal_status": "unknown", "claim_ids": [ "c-grp-sobkow-ico-house" ], "kind": "directs" }, { "id": "r-iceo-red-0-bbte-address", "from": "iceo-red-0", "to": "bbte", "role": "Same registered address: Tähesaju tee 9, Tallinn", "period": "As of 2026", "status": "documented", "direction": "undirected", "role_group": "infrastructure", "temporal_status": "unknown", "claim_ids": [ "c-grp-iceo-red-0" ], "kind": "other" }, { "id": "r-admitrade-bbte-address", "from": "admitrade", "to": "bbte", "role": "Same registered address: Tähesaju tee 9, Tallinn", "period": "As of 2026", "status": "documented", "direction": "undirected", "role_group": "infrastructure", "temporal_status": "unknown", "claim_ids": [ "c-grp-admitrade-register" ], "kind": "other" } ], "history": [], "claims": [ { "id": "c-id-register", "kind": "fact", "text": "BB Trade Estonia OÜ is a private limited company (osaühing) entered in the Estonian Commercial Register on 30 September 2019 under registry code 14814864 (EUID EEARIREG.14814864). Its current register card gives its status as bankrupt (pankrotis), its share capital as EUR 350,000, its legal entity identifier (LEI) as 984500L05A5D0E66Q610 and its registered address as Tähesaju tee 9, Lasnamäe district, Tallinn 13917.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-001" ], "entity_ids": [ "bbte" ] }, { "id": "c-id-vat", "kind": "fact", "text": "The register card records BB Trade Estonia OÜ as registered for value added tax under number EE102200164 from 22 October 2019, with no end date recorded.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-001" ], "entity_ids": [ "bbte" ] }, { "id": "c-id-former-name", "kind": "fact", "text": "The company was registered as Pinewood Estonia OÜ. Its first annual report (30 September 2019 – 31 December 2020) states that it carried that name until 13 February 2020 and has used the name BB Trade Estonia OÜ since that date; the register card lists Pinewood Estonia OÜ as a former name.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-001", "src-006" ], "entity_ids": [ "bbte" ] }, { "id": "c-id-addresses", "kind": "fact", "text": "The company's registered address has changed several times. Its first annual report states that in April 2020 the address Lõõtsa tn 5, Tallinn was replaced by Lõõtsa tn 8a, Tallinn; the 2021 annual report gives Rävala pst 2, Tallinn 10145; the 2022 annual report gives Tähesaju tee 9, Tallinn 13917, which is also the address on the current register card.", "qualification": "The 2022 annual report dates the move from Rävala pst 2 to Tähesaju tee 9 to 13 September 2023, whereas the register's publication history, as reproduced by a registry-data aggregator, lists address changes on 1 March 2022 and 13 September 2022; the retained records do not resolve which year is correct.", "response": "", "outcome": "", "source_ids": [ "src-003", "src-006", "src-028", "src-104" ], "entity_ids": [ "bbte" ] }, { "id": "c-id-capital", "kind": "fact", "text": "The company was registered with share capital of EUR 2,500. Its first annual report states that the capital was raised to EUR 100,000 and fully paid; the register's publication history shows increases to EUR 50,000 published on 22 May 2020 and to EUR 100,000 on 24 September 2020. The 2021 annual report states that the capital was raised to EUR 350,000, fully paid, and its 2022 cash-flow statement shows EUR 250,000 received from the issue of shares in 2022.", "qualification": "The 2021 annual report gives 21 February 2022 as the date the increase to EUR 350,000 was registered, while the publication history reproduced by a registry-data aggregator lists the EUR 350,000 capital on 31 March 2022.", "response": "", "outcome": "", "source_ids": [ "src-028", "src-104", "src-006", "src-003" ], "entity_ids": [ "bbte" ] }, { "id": "c-id-filed-figures", "kind": "fact", "text": "The register's summary of the company's filed annual reports gives revenue (tulud) and profit (kasum) in euros of 8,837,007 and 6,491,835 for 2020; 23,819,262 and 17,205,468 for 2021; 6,215,330 and 1,735,279 for 2022; 4,679,522 and 2,645,524 for 2023; and 6,076,753 and 10,601,975 for 2024.", "qualification": "These are the register's summary figures; they do not say whether each figure is the company-only or the consolidated result. The consolidated balance sheet in the 2022 annual report shows a profit of EUR 1,142,183 for 2022.", "response": "", "outcome": "", "source_ids": [ "src-001", "src-028" ], "entity_ids": [ "bbte" ] }, { "id": "c-id-trademarks", "kind": "fact", "text": "European Union trademark-filing data reproduced by a registry-data aggregator list applications filed by BB Trade Estonia OÜ: 9 in 2023 (including TRADE TOMORROW TODAY, ZONDACRYPTO, ZONDACRYPTO ACADEMY, ZONDACRYPTO PAY and zondacrypto token), 8 in 2024 (including ZND and ZND VENTURES), 17 in 2025 (including TMPL, Token TeamPL, ZONDACRYPTO and ZONDACRYPTO PAY) and 7 in 2026.", "qualification": "The listing gives counts and sample mark names only; the registration status and present owner of each mark are not in the retained record.", "response": "", "outcome": "", "source_ids": [ "src-104" ], "entity_ids": [ "bbte" ] }, { "id": "c-id-real-estate", "kind": "fact", "text": "An Estonian business-information service drawing on national registers reported in October 2026 that no real-estate register units (kinnistud) were registered to BB Trade Estonia OÜ.", "qualification": "Summary by a commercial information service; the land register extract itself was not retained, and the statement does not cover assets held through subsidiaries or outside Estonia.", "response": "", "outcome": "", "source_ids": [ "src-067" ], "entity_ids": [ "bbte" ] }, { "id": "c-brand-bitbay-2020", "kind": "fact", "text": "In its first annual report (30 September 2019 – 31 December 2020) BB Trade Estonia OÜ describes itself as the operator of the BitBay.net web-based trading platform, a fiat-to-crypto exchange on which prospective buyers and sellers of crypto-currencies place buy and sell orders.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006" ], "entity_ids": [ "bbte" ] }, { "id": "c-brand-zonda-2021", "kind": "fact", "text": "Its 2021 annual report gives its main activity as running the Zonda cryptocurrency trading platform and states that the platform was rebranded in November 2021, with Zonda Global as the new brand from that month.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003" ], "entity_ids": [ "bbte" ] }, { "id": "c-brand-zondacrypto-reports", "kind": "fact", "text": "Its annual reports for 2022, 2023 and 2024 describe the company as the operator of the zondacrypto online exchange at zondacrypto.com (formerly www.BitBay.net and www.zondaglobal.com) and record its virtual-currency service licence FVT000209, with the Estonian Financial Intelligence Unit (Rahapesu Andmebüroo) as the regulator.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028", "src-027", "src-013" ], "entity_ids": [ "bbte" ] }, { "id": "c-brand-terms-2025", "kind": "fact", "text": "The zondacrypto exchange's terms of service in the version valid from 3 October 2025 name BB Trade Estonia OÜ, Tähesaju tee 9, Tallinn (registry code 14814864, holder of virtual-currency licence FVT000209), as the provider of the services and the operator of the zondacrypto virtual-currency exchange at zondacrypto.com and its subdomains.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-039" ], "entity_ids": [ "bbte" ] }, { "id": "c-brand-terms-substitution", "kind": "fact", "text": "The same terms (§ 11) allow the provider of the services to be replaced by another entity related to zondacrypto; the previous provider then ceases to be a party to the agreement with the user, and the conditions of service may not become less favourable to users as a result of the change.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-039" ], "entity_ids": [ "bbte" ] }, { "id": "c-brand-contacts", "kind": "fact", "text": "The zondacrypto.com contact page (archived copy of December 2025) names two contracting entities: BB Trade Estonia OÜ (registry code 14814864, VAT number EE102200164) for users in the European Economic Area other than Italy, and BB Trade IT, Via Fatebenefratelli 20, Milan (registration number PSV48, Italian VAT number 12490930968) for Italian users and users outside the European Economic Area.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-086" ], "entity_ids": [ "bbte", "bb-trade-it" ] }, { "id": "c-brand-trademark-disclaimer", "kind": "fact", "text": "A January 2025 press release issued for the brand with Incore Bank states that \"zondacrypto\" is a trademark identifying the services of various entities within the group, does not in itself refer to any single legal entity and does not imply a single corporate identity, ownership structure or legal responsibility; the release describes the Estonian entity as licensed as an exchange in Estonia and BB Trade Switzerland AG as the brand's Swiss entity.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-113" ], "entity_ids": [ "bbte", "bb-switzerland", "incore" ] }, { "id": "c-brand-swiss-terms", "kind": "fact", "text": "The terms of the zondacrypto Swiss platform (in force from 30 June 2025) make each client a party to a tripartite agreement with BB Trade Switzerland AG and BB Trade Estonia OÜ: BB Trade Switzerland processes the client's order and transmits it to BB Trade Estonia for execution, BB Trade Switzerland is responsible for the fiat-currency part of each transaction and BB Trade Estonia for the digital-asset part, including transfers of purchased digital assets to customers and acceptance of customers' digital-asset payments for exchange into fiat.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-107" ], "entity_ids": [ "bbte", "bb-switzerland" ] }, { "id": "c-brand-swiss-fiat", "kind": "fact", "text": "Under those terms BB Trade Switzerland AG accepts customers' fiat payments and transfers them on the customer's behalf to BB Trade Estonia OÜ to close the transaction, or returns them; customer fiat held by BB Trade Switzerland bears no interest, is not invested or converted and is held for no longer than 30 days. The zondacrypto.com contact page states that on the zondacrypto Swiss platform funds are sent directly to the customer's wallet or bank account and are not stored on the platform.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-107", "src-086" ], "entity_ids": [ "bbte", "bb-switzerland" ] }, { "id": "c-brand-swiss-release", "kind": "fact", "text": "A press release issued for the brand on 2 July 2025 describes zondacrypto Swiss as a regulated crypto on- and off-ramp operated by BB Trade Switzerland and part of the \"zondacrypto Group\", which it says operates the zondacrypto exchange, the zondacrypto pay crypto-fiat payment gateway and the ZND platform.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-052" ], "entity_ids": [ "bb-switzerland" ] }, { "id": "c-brand-znd", "kind": "fact", "text": "The ZND platform website (archived copy of January 2026) states that the ZND Token crypto-asset is offered by BB Trade Estonia OÜ, with its registered office in Tallinn, the operator of the zondacrypto exchange.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-114" ], "entity_ids": [ "bbte" ] }, { "id": "c-brand-authorities", "kind": "fact", "text": "Authorities and the press identify BB Trade Estonia OÜ as the operator of the brand: the warning issued by Finantsinspektsioon (the Estonian Financial Supervision and Resolution Authority) on 6 May 2026 lists zondacrypto.com as the company's webpage; a release of Poland's National Public Prosecutor's Office (Prokuratura Krajowa) of 28 August 2026 refers to the cryptocurrency exchange ZondaCrypto \"and its operator, BB Trade Estonia OU\"; and Swiss specialist press in May 2026 described BB Trade Estonia OÜ as the operating company behind Zondacrypto.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-004", "src-094", "src-096" ], "entity_ids": [ "bbte" ] }, { "id": "c-brand-lineage", "kind": "attributed", "text": "A law firm acting for claimants in the bankruptcy describes the exchange now marketed as zondacrypto as having passed through several entities: BitBay sp. z o.o. in Katowice; Pinewood Holdings Limited in Malta from May 2018; Pinewood Estonia OÜ (the subject's former name) in Tallinn from 1 November 2019; and, from 2021, BB Trade Estonia OÜ under the Zonda brand, renamed zondacrypto in 2023.", "qualification": "This is the claimants' representatives' reconstruction of the brand's history; the retained record does not show a legal succession between these companies. BB Trade Estonia's own reports describe it as operator of BitBay.net in 2019–2020, of Zonda in 2021 and of zondacrypto from 2022.", "response": "", "outcome": "", "source_ids": [ "src-008" ], "entity_ids": [ "bbte", "bitbay", "pinewood-holdings" ] }, { "id": "c-brand-bitbay-licensing", "kind": "attributed", "text": "The same law firm quotes the 2019 management report of BitBay sp. z o.o. as stating that from November 2019 the Polish company \"has subsisted on fees for the licensing of the operation of the cryptocurrency exchange 'BitBay'\" to BB Trade Estonia OÜ, and states that the exchange's operations were transferred that month from Pinewood Holdings Limited to BB Trade Estonia OÜ.", "qualification": "Quotation of a management report that the law firm says it read; the report itself is not in the retained record.", "response": "", "outcome": "", "source_ids": [ "src-088" ], "entity_ids": [ "bbte", "bitbay", "pinewood-holdings" ] }, { "id": "c-brand-bitbay-registry", "kind": "fact", "text": "Polish National Court Register (KRS) data reproduced by a registry-data aggregator show BitBay sp. z o.o. (KRS 0000373405) registered in Warsaw on 16 December 2010, named Bitbay sp. z o.o. and based in Katowice from 14 March 2014, with share capital of PLN 105,000 from 26 July 2018. Sylwester Jan Suszek was its authorised signatory (prokurent) from 28 May 2014 and its chief executive from 21 September 2017 until the company was struck off on 17 February 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-023" ], "entity_ids": [ "bitbay", "suszek" ] }, { "id": "c-brand-bitbay-owners", "kind": "fact", "text": "The same data list three companies as BitBay sp. z o.o.'s shareholders from 26 July 2018, when three earlier shareholders left: Arial Investment in Commercial Enterprises LLC, Central Bay Investment in Commercial Enterprises LLC and Skybay Investment in Commercial Enterprises LLC. Changes in Arial Investment's holding were published on 14 November 2018 and 27 May 2020, and three corporate shareholders ceased to be shareholders when the company was struck off on 17 February 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-023" ], "entity_ids": [ "bitbay", "arial", "central-bay", "skybay" ] }, { "id": "c-brand-knf-warning", "kind": "fact", "text": "The public-warning list of the Polish Financial Supervision Authority (KNF) includes BitBay sp. z o.o. of Katowice (KRS 0000373405), entered on a notification of suspected crime made by the KNF Office (UKNF) under Article 150(1) of the Act on payment services, with the Regional Prosecutor's Office in Katowice as the competent prosecutor.", "qualification": "", "response": "", "outcome": "The Provincial Prosecutor's Office in Katowice discontinued the investigation on 15 June 2022; that decision became final and binding on 12 May 2023.", "source_ids": [ "src-077" ], "entity_ids": [ "bitbay" ], "adverse_subject_ids": [ "bitbay" ] }, { "id": "c-brand-pinewood-registry", "kind": "fact", "text": "Malta Business Registry data reproduced by commercial aggregators show Pinewood Holdings Limited (company C 86244) incorporated on 10 May 2018 with 1,200 issued shares (EUR 1,200) and registered at 230 Eucharistic Congress Road, Mosta; one aggregator, updated in February 2025, lists Pawel Lukasz Sobkow and Sylwester Jan Suszek as directors and Luxbay S.A. as shareholder.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-058", "src-021" ], "entity_ids": [ "pinewood-holdings", "sobkow", "suszek", "luxbay" ] }, { "id": "c-brand-pinewood-history", "kind": "attributed", "text": "A law firm acting for claimants, citing the Maltese registry file C 86244, states that Paweł Łukasz Sobków was Pinewood Holdings Limited's first and sole shareholder and its first director, that its EUR 1,200 capital was paid on 7 May 2018 by a transfer sent by a Polish payment institution, that Sobków resigned all positions on 22 June 2021, leaving Sylwester Jan Suszek as the only director, that the company never filed financial statements, and that its corporate-service provider terminated its services on 26 June 2022.", "qualification": "The firm's reading of registry documents that are not themselves in the retained record.", "response": "", "outcome": "", "source_ids": [ "src-088" ], "entity_ids": [ "pinewood-holdings", "sobkow", "suszek" ] }, { "id": "c-brand-pinewood-licence", "kind": "attributed", "text": "The same law firm states that Pinewood Holdings Limited never applied to the Malta Financial Services Authority for a virtual financial assets licence, did not submit a letter of intent in October 2019 and appears neither on the list of 32 formal applicants nor on the regulator's April 2020 list of 57 companies, and concludes that the brand's Maltese entity held no Maltese licence.", "qualification": "Assertion by claimants' representatives; the regulator's lists are not in the retained record.", "response": "The same firm recounts that in 2018 Sylwester Suszek publicly announced BitBay's relocation to Malta, citing friendly regulation and a forward-looking licensing framework, and called the KNF's public warning on BitBay an act of repression rather than consumer protection; no reply by Pinewood, Suszek or BB Trade Estonia to the registry findings is in the retained record.", "outcome": "", "source_ids": [ "src-088" ], "entity_ids": [ "pinewood-holdings", "suszek" ] }, { "id": "c-own-sobkow-luxbay-2020", "kind": "fact", "text": "According to the company's first annual report, Paweł Sobków was the sole participant, holding 100% of the shares, and acted as chief executive until 13 February 2020; he then transferred the entire holding to LUXBAY S.A., a company incorporated under Luxembourg law with its seat at Place de Strasbourg 2, Luxembourg, whereby Sylwester Jan Suszek became the company's ultimate beneficial owner. The same report names LuxBay S.A. of Luxembourg as the parent undertaking.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006" ], "entity_ids": [ "bbte", "sobkow", "luxbay", "suszek" ] }, { "id": "c-own-register-history", "kind": "fact", "text": "The Estonian register's publication history, as reproduced by a registry-data aggregator, shows the previous shareholder leaving and Luxbay SA entered as shareholder on 27 April 2020, changes in Luxbay's holding with the capital increases of 22 May and 24 September 2020, and, on 14 July 2021, Divisio Holding AG entered as shareholder with Luxbay SA no longer a shareholder. It lists beneficial-owner updates on 28 April 2020, 16 July 2021 and 8 March 2022, and a change in Divisio Holding AG's shareholding on 30 March 2022.", "qualification": "The register publication dates follow the transfer agreed after 13 February 2020 and the July 2021 share sale described in the annual reports, and show Luxbay as the shareholder of BB Trade Estonia.", "response": "", "outcome": "", "source_ids": [ "src-104" ], "entity_ids": [ "bbte", "luxbay", "divisio" ] }, { "id": "c-own-luxbay-entity", "kind": "fact", "text": "Luxembourg register data reproduced by a registry-data aggregator show Luxbay SA (RCS B237593) registered on 4 September 2019 with share capital of EUR 30,000 and terminated on 31 December 2025; Sylwester Jan Suszek is listed among its directors from 9 July 2021 until the termination.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-047" ], "entity_ids": [ "luxbay", "suszek" ] }, { "id": "c-own-divisio-2021", "kind": "fact", "text": "BB Trade Estonia's 2021 annual report states that in July 2021 a share-transfer agreement was concluded under which a Swiss company acquired the company's shares and Przemysław Kral became its ultimate beneficial owner, a change published in the Estonian register on 15 July 2021, and that its parent undertaking became DIVISIO HOLDING AG of Switzerland in July 2021. The 2024 annual report names Divisio Holding A.G. of Switzerland as the parent undertaking.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003", "src-013" ], "entity_ids": [ "bbte", "divisio", "kral" ] }, { "id": "c-own-register-card", "kind": "fact", "text": "The current register card lists DIVISIO HOLDING AG (Swiss identifier CHE-161.370.248) as sole owner of 100% (EUR 350,000) with the date 30 March 2022, and Przemysław Janusz Kral as beneficial owner through an indirect holding from 8 March 2022, with beneficial-owner data last updated on 29 July 2025; the register states that its shareholder and beneficial-owner data are informative.", "qualification": "These dates differ from the July 2021 change described in the annual reports; the register's publication history lists Divisio's entry as shareholder on 14 July 2021 and later updates on 8 and 30 March 2022, and the retained records do not explain the difference further.", "response": "", "outcome": "", "source_ids": [ "src-001" ], "entity_ids": [ "bbte", "divisio", "kral" ] }, { "id": "c-own-divisio-registry", "kind": "fact", "text": "Divisio Holding AG (also Divisio Holding SA and Divisio Holding Ltd.), Swiss identifier CHE-161.370.248 and commercial-register number CH-170.3.045.992-5, was entered in the commercial register of the canton of Zug on 24 June 2021 and published in the Swiss Official Gazette of Commerce (SHAB) on 29 June 2021. Its articles are dated 14 June 2021; its purpose is holding and managing participations, and it may grant loans to its direct or indirect shareholders or subsidiaries. Its share capital of CHF 100,000 is divided into 1,000 registered shares with restricted transferability; notices go to the shareholders recorded in its share register, which the publication does not disclose. It opted out of a limited audit.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-005", "src-099" ], "entity_ids": [ "divisio" ] }, { "id": "c-own-divisio-board", "kind": "fact", "text": "André Terlinden was entered at incorporation as Divisio Holding AG's only board member, with sole signature. Its initial domicile was c/o Afrag AG, Chamerstrasse 14, Zug; a SHAB notice of 28 July 2022 records the new domicile c/o Dr. André Terlinden, Baarerstrasse 78, 6300 Zug. On 27 April 2026 SHAB published (no. HR02-1006635349) that Dr. André Marcel Terlinden had left the board, and a commercial-register summary retrieved in October 2026 shows no registered managers and no information on the company's ownership structure.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-005", "src-099" ], "entity_ids": [ "divisio", "terlinden" ] }, { "id": "c-own-divisio-address", "kind": "fact", "text": "A commercial-register summary states that 119 other active companies are registered at Divisio Holding AG's address (Baarerstrasse 78, Zug), and a registry-data aggregator lists the legal entity identifier 506700IIY4O9G6R2AS52 for the company.", "qualification": "A shared business address does not by itself establish any link between the companies registered there.", "response": "", "outcome": "", "source_ids": [ "src-005", "src-002", "src-063" ], "entity_ids": [ "divisio" ] }, { "id": "c-own-white-paper", "kind": "attributed", "text": "A law firm acting for claimants in the bankruptcy quotes the ZND token white paper dated 27 June 2024 (page 11) as stating that \"the sole shareholder of DIVISIO HOLDING AG is Przemysław Kral, CEO of zondacrypto\", and describes Divisio as a holding company with no operating business of its own.", "qualification": "The white paper itself is not in the retained record, and the Swiss register publications do not disclose Divisio's shareholders; the Estonian register separately records Kral as BB Trade Estonia's beneficial owner through an indirect holding.", "response": "", "outcome": "", "source_ids": [ "src-008" ], "entity_ids": [ "divisio", "kral" ] }, { "id": "c-own-single-beneficiary", "kind": "attributed", "text": "The same law firm states that the group had a single ultimate beneficiary, Przemysław Kral, with no outside investors holding voting rights, and that only in March 2025, before the company's application as a crypto-asset service provider, was a three-member supervisory board of Guido Bühler, Georgi Džaniašvili and Giorgio Chiellini announced.", "qualification": "Characterisation by claimants' representatives. BB Trade Estonia's 2024 annual report records that in March 2025, in preparation for its application under the EU Markets in Crypto-Assets Regulation (MiCA), a supervisory board of these three persons was formed.", "response": "", "outcome": "", "source_ids": [ "src-008", "src-013" ], "entity_ids": [ "bbte", "kral", "buhler", "dzaniasvili", "chiellini" ] }, { "id": "c-own-divisio-fees", "kind": "attributed", "text": "The same law firm states that BB Trade Estonia OÜ is wholly owned by Divisio Holding AG, which belongs to Kral, and that LuxBay S.A. held that position until 12 July 2021. Citing the company's records, it reports that Divisio invoiced BB Trade Estonia for services of EUR 200,000 in 2023 and EUR 400,000 in 2024, that BB Trade Switzerland invoiced EUR 200,000 in 2023, and that Divisio's director, André Terlinden, received EUR 100,200 in remuneration from the exchange in 2023 while his advisory firm billed domicile and directorship fees.", "qualification": "Figures as reported by claimants' representatives from the company's records; the underlying invoices are not in the retained record. The annual reports give July 2021 for the change of parent without a day.", "response": "", "outcome": "", "source_ids": [ "src-010" ], "entity_ids": [ "bbte", "divisio", "kral", "luxbay", "bb-switzerland", "terlinden" ] }, { "id": "c-own-terlinden-nvp", "kind": "attributed", "text": "A Polish news report of 27 April 2026 described André Marcel Terlinden as Divisio Holding AG's only director and as a partner and shareholder of the law firm Neupert Vuille Partners AG on Lake Zurich, at whose premises, it reported, several hundred entities are registered.", "qualification": "Press account; the list of entities registered at the firm's premises is not in the retained record.", "response": "", "outcome": "", "source_ids": [ "src-091" ], "entity_ids": [ "terlinden", "divisio", "nvp" ] }, { "id": "c-own-divisio-zondacrypto-sk", "kind": "fact", "text": "Slovak commercial-register publications of 13 January and 7 April 2026, as indexed by a registry-data aggregator, list Divisio Holding AG as a partner (shareholder) of zondacrypto SK s.r.o.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-063" ], "entity_ids": [ "divisio", "zondacrypto-sk" ] }, { "id": "c-mgmt-board-2019-2020", "kind": "fact", "text": "According to BB Trade Estonia OÜ's annual report for its first financial period (30 September 2019 to 31 December 2020), the management board until 13 February 2020 consisted of Dawid Grzegorz Sendecki, Sylwester Jan Suszek and Paweł Łukasz Sobków. Sobków resigned in spring 2020, after which the board had two members: Suszek as chairman and Sendecki. The report was signed by Suszek as a management board member on 24 September 2021.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006" ], "entity_ids": [ "bbte", "sendecki", "suszek", "sobkow" ] }, { "id": "c-mgmt-board-2021", "kind": "fact", "text": "BB Trade Estonia OÜ's annual report for 2021 states that Dawid Grzegorz Sendecki was a management board member from June 2021 and that from November 2021 the company's chief executive, Przemysław Kral, was the second board member. Both signed the 2021 report as management board members on 30 November 2022.", "qualification": "The 2019–2020 annual report already lists Sendecki on the management board in 2020; the retained records do not explain why the 2021 report dates his membership from June 2021.", "response": "", "outcome": "", "source_ids": [ "src-003" ], "entity_ids": [ "bbte", "sendecki", "kral" ] }, { "id": "c-mgmt-register-card-2026", "kind": "fact", "text": "The Estonian commercial register card of BB Trade Estonia OÜ, as retrieved on 19 October 2026, lists Przemysław Janusz Kral as a management board member since 8 November 2021 and Margus Lentsius as trustee in bankruptcy (pankrotihaldur) since 28 August 2026; the card notes that the trustee disposes of the company's bankruptcy estate. The card shows no current supervisory board members.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-001" ], "entity_ids": [ "bbte", "kral", "lentsius" ] }, { "id": "c-mgmt-representation", "kind": "fact", "text": "The register card records, from 8 November 2021, a special representation rule under which BB Trade Estonia OÜ is represented by Przemysław Janusz Kral alone or by two management board members jointly, one of whom must be Kral.", "qualification": "The same card section also states that no special representation rules are currently in force, and since 28 August 2026 the trustee in bankruptcy disposes of the estate; the card does not show when the rule ceased to apply.", "response": "", "outcome": "", "source_ids": [ "src-001" ], "entity_ids": [ "bbte", "kral" ] }, { "id": "c-mgmt-board-2023", "kind": "fact", "text": "According to BB Trade Estonia OÜ's annual report for 2022, the management board from 10 December 2023 consisted of three members: Przemysław Kral, Dawid Sendecki and Guido Bühler; all three signed the 2022 report as management board members on 12 January 2024. The 2023 annual report also lists the same three-member board as of 31 December 2023 and was signed by Kral alone on 30 June 2024.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028", "src-027" ], "entity_ids": [ "bbte", "kral", "sendecki", "buhler" ] }, { "id": "c-mgmt-mlro-2023", "kind": "fact", "text": "BB Trade Estonia OÜ's annual report for 2022 states that a new money laundering reporting officer (MLRO) of the company, Reet Jurik, was appointed and approved by the Estonian Financial Intelligence Unit (FIU) in 2023.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028" ], "entity_ids": [ "bbte", "jurik" ] }, { "id": "c-mgmt-krs-branch-board", "kind": "fact", "text": "The Polish National Court Register (KRS) entry of BB Trade Estonia OÜ's Polish branch, registered on 16 December 2024 and reproduced by a registry-data aggregator, lists the parent company's management board as Przemysław Janusz Kral, Dawid Sendecki and Guido Bühler and records that the company is represented by Kral alone or by two board members jointly, one of whom must be Kral. Kral is entered as director of the branch from 16 December 2024.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-009" ], "entity_ids": [ "bbte", "bbte-pl-branch", "kral", "sendecki", "buhler" ] }, { "id": "c-mgmt-restructuring-2025", "kind": "fact", "text": "BB Trade Estonia OÜ's annual report for 2024 states that on 31 December 2024 the management board had three members, Przemyslaw Kral, David Sendecki and Guido Buhler, and that in March 2025, in preparing an application under the EU Markets in Crypto-Assets Regulation (MiCA), the company changed its structure: a two-member management board of Kral and Dawid Sendecki and a three-member supervisory board (nõukogu) of Guido Buhler, Georgi Džaniašvili and Giorgio Chiellini. The 2024 report was signed on 29 July 2025 by Kral alone as a management board member and was approved by the shareholders' meeting.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte", "kral", "sendecki", "buhler", "dzaniasvili", "chiellini" ] }, { "id": "c-mgmt-register-changes", "kind": "fact", "text": "Estonian register publications for BB Trade Estonia OÜ, as listed by a registry-data aggregator, record a supervisory-board chair and two members being entered on 17 March 2025, a management board member leaving on 24 March 2025, a change of supervisory-board chair on 10 September 2025, supervisory-board members and the chair leaving on 15 and 17 April 2026, an interim trustee on 28 July 2026, and on 28 August 2026 the opening of bankruptcy with a trustee, when Dawid G. Sendecki ceased to be a board member.", "qualification": "The listing names persons only as \"N.N.\" for the 2025 and April 2026 supervisory-board entries; the names come from the annual report and the supervisory board's own statement.", "response": "", "outcome": "", "source_ids": [ "src-104" ], "entity_ids": [ "bbte", "sendecki" ] }, { "id": "c-mgmt-buhler-capacity", "kind": "unresolved", "text": "Records describe Guido Bühler's capacity at BB Trade Estonia OÜ between October 2023 and March 2025 differently. The company's 2022 and 2023 annual reports list him as a management board member from 10 December 2023, and he signed the 2022 report in that capacity; Swiss financial press reported in October 2023, citing a press release, that he would take the role of a non-executive director in the management of Zondacrypto; a law firm acting for claimants in the bankruptcy states that he joined the supervisory board in October 2023 as a non-executive director.", "qualification": "The 2024 annual report places him on the management board until March 2025 and on the new supervisory board from then; the retained record does not contain a register entry for a supervisory board before March 2025.", "response": "", "outcome": "", "source_ids": [ "src-098", "src-028" ], "entity_ids": [ "bbte", "buhler" ] }, { "id": "c-mgmt-board-may-2026", "kind": "fact", "text": "In its public warning of 6 May 2026, the Estonian Financial Supervision and Resolution Authority (Finantsinspektsioon) listed the management board of BB Trade Estonia OÜ as Dawid Grzegorz Sendecki and Przemysław Janusz Kral.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-004" ], "entity_ids": [ "bbte", "sendecki", "kral" ] }, { "id": "c-mgmt-sendecki-resignation", "kind": "attributed", "text": "A Polish news report of 20 April 2026 said that Dawid Sendecki, management board member and director of risk and compliance of BB Trade Estonia OÜ, had announced his departure on social media a few days earlier; according to his professional profile as cited in the report, he was money laundering reporting officer from January 2020 to April 2024 and then director of risk and compliance.", "qualification": "This is Sendecki's own account as reported by the press; the retained record does not include his post itself.", "response": "Sendecki said he had no involvement with client funds other than in his anti-money-laundering role, that managing them and liquidity had always been the chief executive's role, and that he learned only that week, together with everyone else, that there were no private keys to the funds declared as the company's reserve.", "outcome": "Estonian register publications record that his management board membership ended on 28 August 2026, when bankruptcy proceedings opened.", "source_ids": [ "src-025", "src-104" ], "entity_ids": [ "bbte", "sendecki" ] }, { "id": "c-mgmt-supervisory-resignations", "kind": "attributed", "text": "In a statement published on 20 April 2026, the former members of BB Trade Estonia OÜ's supervisory board, Veronika Tugo (chair; spelled Togo in the statement), Guido Bühler and Georgi Džaniašvili, said that each of them had independently resigned that week; that the board learned of the situation only from public sources after it escalated in the Polish media; that material inconsistencies had emerged between certain public statements, operational realities and information previously given to the board; and that in a structure where ownership and executive management were concentrated in one individual, the trust needed for oversight had been materially undermined.", "qualification": "This is the former board members' own account; the statement does not name the individual.", "response": "The former members added that all their decisions as supervisory-board members were made in good faith on the information then available to them, including auditor reports and the MiCA-related regulatory process.", "outcome": "Estonian register publications record supervisory-board members and the chair leaving on 15 and 17 April 2026.", "source_ids": [ "src-044", "src-025", "src-104" ], "entity_ids": [ "bbte", "tugo", "buhler", "dzaniasvili" ] }, { "id": "c-mgmt-court-register-rulings", "kind": "fact", "text": "Court register-division rulings listed for BB Trade Estonia OÜ in file Ä 50129412 include an order of 29 April 2026 to remedy deficiencies in an application and a refusal of 15 May 2026 to make the requested entry because the deficiencies had not been remedied, followed by a procedural order of 10 July 2026, an entry made on 28 July 2026 to implement another court decision, and an ex officio entry of 28 August 2026.", "qualification": "The listing does not disclose what the applications or entries concerned.", "response": "", "outcome": "", "source_ids": [ "src-024" ], "entity_ids": [ "bbte" ] }, { "id": "c-mgmt-giloca", "kind": "attributed", "text": "A law firm acting for claimants in the bankruptcy states that BB Trade Estonia OÜ's statement of related-party transactions for 2023 lists Guido Bühler as a director of BB Trade Estonia and of BB Trade Switzerland, and his company Giloca AG of Chamerstrasse 85, Zug, as a supplier of services worth EUR 101,316 in 2023 and EUR 244,100 in 2024. Swiss commercial register data show Giloca AG, formerly Giloca Real Estate AG, registered in Zug on 30 April 2015, with Bühler among the three members of its management.", "qualification": "The amounts come from the law firm's reading of the company's accounts; the related-party note itself is not in the retained record, and the Swiss register data contain no information on Giloca AG's owners.", "response": "", "outcome": "", "source_ids": [ "src-010", "src-069" ], "entity_ids": [ "bbte", "buhler", "giloca", "bb-switzerland" ] }, { "id": "c-grp-consolidation-2024", "kind": "fact", "text": "BB Trade Estonia OÜ's consolidated annual report for 2024 lists the companies in its consolidation group as ZND Ventures OÜ (Estonia, from 2024), Zonda Token AG (Switzerland, from 2022), Orion Software sp. z o.o. (Poland, from 2022), BB Trade Estonia Italian Branch (Italy, from 2024) and BB Trade Bahamas Ltd (Bahamas, from 2024).", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte", "znd-ventures", "zonda-token", "orion", "bb-trade-it", "bb-bahamas" ] }, { "id": "c-grp-subsidiaries-2024", "kind": "fact", "text": "The notes to BB Trade Estonia OÜ's 2024 annual report list as subsidiaries Zonda Token AG (Switzerland, consulting services, 100% at the end of 2023 and 2024), Orion Software sp. z o.o. (Poland, IT services, 100% at both dates) and ZND Ventures OÜ (Estonia, programming, 50% at the end of 2023 and 100% at the end of 2024), and ZND.CO OÜ as an associate held at 50% at both dates. The carrying amount of the Orion Software shares rose from EUR 12,975,010 to EUR 19,272,407 and that of ZND Ventures from EUR 1,250 to EUR 2,510,000 during 2024.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte", "zonda-token", "orion", "znd-ventures", "znd-co" ] }, { "id": "c-grp-zonda-token-acquisition", "kind": "fact", "text": "According to BB Trade Estonia OÜ's 2021 annual report, the company acquired 100% of Zonda Token AG, a Swiss company in crypto services, on 7 December 2021 at a cost of EUR 105,627; the report adds that Zonda Token AG did not operate actively in the 2021 financial year.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003" ], "entity_ids": [ "bbte", "zonda-token" ] }, { "id": "c-grp-zonda-token-incorporation", "kind": "fact", "text": "Swiss commercial register publications (SHAB, 14 December 2021) record the incorporation of Zonda Token AG in Zug, with articles dated 30 November 2021, an address c/o Afrag AG, Chamerstrasse 14, Zug, and share capital of CHF 100,000 in 1,000 registered shares. Its stated purpose includes holding participations and, to finance group companies, issuing tokens carrying rights to services or products of parent, subsidiary or affiliated companies. André Marcel Terlinden was entered as president of the board with sole signature, and Karolina Ewa Gwóźdź and Przemysław Janusz Kral as board members without signing authority.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-026", "src-062" ], "entity_ids": [ "zonda-token", "terlinden", "gwozdz", "kral" ] }, { "id": "c-grp-zonda-token-dates", "kind": "unresolved", "text": "Records give different dates for Zonda Token AG joining BB Trade Estonia OÜ's group: the 2021 annual report gives an acquisition date of 7 December 2021, two days before the company's entry in the Swiss commercial register on 9 December 2021; the 2024 report lists it in the consolidation group from 2022; and a law firm acting for claimants in the bankruptcy states that it was brought into the group in January 2022, the month of a domicile change, describing it as wholly owned by BB Trade Estonia, with Kral and Karolina Gwóźdź on its board and an obscure operational role.", "qualification": "The retained records do not explain the sequence; a company can be subscribed before it is registered, and none of the records contains the share transfer itself.", "response": "", "outcome": "On 6 August 2026 a single judge of the Cantonal Court of Zug dissolved Zonda Token AG under Article 731b of the Swiss Code of Obligations and ordered its liquidation under bankruptcy rules; on 29 September 2026 the bankruptcy proceedings were suspended for lack of assets.", "source_ids": [ "src-008", "src-013", "src-062" ], "entity_ids": [ "zonda-token", "bbte", "kral", "gwozdz" ] }, { "id": "c-grp-zonda-token-dissolution", "kind": "fact", "text": "A SHAB publication of 2 September 2026 records that by a decision of a single judge of the Cantonal Court of Zug of 6 August 2026, Zonda Token AG was dissolved under Article 731b of the Swiss Code of Obligations, the provision on deficiencies in a company's legally required organisation, and its liquidation under bankruptcy rules was ordered; the company was renamed Zonda Token AG in Liquidation. André M. Terlinden had ceased to be chair of its board on 11 May 2026, and the board members remaining on the register are Karolina Ewa Gwóźdź and Przemysław Janusz Kral.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-062", "src-016" ], "entity_ids": [ "zonda-token", "terlinden", "gwozdz", "kral" ], "adverse_subject_ids": [ "zonda-token" ] }, { "id": "c-grp-zonda-token-bankruptcy", "kind": "fact", "text": "The bankruptcy office of the Canton of Zug published a preliminary bankruptcy notice for Zonda Token AG on 3 September 2026 and, on 1 October 2026, a notice suspending the bankruptcy proceedings as of 29 September 2026 for lack of assets: the proceedings would be closed unless a creditor requested their continuation and advanced CHF 5,000 by 21 October 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-062" ], "entity_ids": [ "zonda-token" ], "adverse_subject_ids": [ "zonda-token" ] }, { "id": "c-grp-bbts-incorporation", "kind": "fact", "text": "BB Trade Switzerland AG was entered in the Zug commercial register on 30 September 2020 with share capital of CHF 100,000; register publications list André Terlinden as chair of the board at registration and a second board member identified only by the initials S. S.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-016", "src-014" ], "entity_ids": [ "bb-switzerland", "terlinden" ] }, { "id": "c-grp-bbts-board-2022", "kind": "fact", "text": "Swiss register publications for BB Trade Switzerland AG record André M. Terlinden as chair of the board in a publication of 24 January 2022; on 24 March 2022 Sylwester Jan Suszek left the board and Terlinden was entered as a member; on 29 June 2022 Timo Fenner joined the board and Terlinden left it.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-016" ], "entity_ids": [ "bb-switzerland", "terlinden", "suszek", "fenner" ] }, { "id": "c-grp-bbts-board-2024", "kind": "fact", "text": "A SHAB publication of 10 January 2024 entered Przemyslaw Kral as president of the board of BB Trade Switzerland AG without signing authority, with Guido Bühler and Timo Fenner as board members signing jointly by two; Fenner previously had sole signature. The company's address was then c/o Dr. André Terlinden, Baarerstrasse 78, Zug.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-026", "src-079" ], "entity_ids": [ "bb-switzerland", "kral", "buhler", "fenner", "terlinden" ] }, { "id": "c-grp-bbts-board-2026", "kind": "fact", "text": "A SHAB publication of 6 May 2026 records that Guido Bühler left the board of BB Trade Switzerland AG and that Dr. Timo Fabian Fenner, a board member, was given sole signature; the company's address was then Dammstrasse 16, Zug.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-014", "src-018", "src-080" ], "entity_ids": [ "bb-switzerland", "buhler", "fenner" ] }, { "id": "c-grp-bbts-liquidation", "kind": "fact", "text": "A SHAB publication of 29 July 2026 records that BB Trade Switzerland AG was dissolved by resolution of its general meeting of 16 July 2026, renamed BB Trade Switzerland AG in Liquidation and moved from Zug to Zollikon, c/o NEUPERT, VUILLE & PARTNER, Dufourstrasse 58. Dr. Timo Fabian Fenner was entered as board member and liquidator with sole signature. The same entry replaced the company's purpose with services related to trading and transferring digital assets, including fiduciary services, and developing and operating trading and IT platforms, allowing loans to direct or indirect shareholders and subsidiaries, and lifted the restriction on transferring its registered shares.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-014", "src-082" ], "entity_ids": [ "bb-switzerland", "fenner", "nvp" ] }, { "id": "c-grp-bbts-register-2026", "kind": "fact", "text": "Swiss register data for BB Trade Switzerland AG in Liquidation, last changed on 29 July 2026, list Dr. Timo Fabian Fenner and Przemyslaw Janusz Kral as its board members, Fenner as liquidator and sole authorised signatory, and 32 other active companies registered at its Zollikon address.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-014" ], "entity_ids": [ "bb-switzerland", "fenner", "kral" ] }, { "id": "c-grp-bbts-ownership", "kind": "unresolved", "text": "The ownership of BB Trade Switzerland AG is not shown in the retained register data, which state that no information on its ownership structure is known. A law firm acting for claimants in the bankruptcy describes it as a wholly owned subsidiary of the exchange, registered at Baarerstrasse 78 in Zug with Timo Fenner and Guido Bühler as directors, and states that it invoiced BB Trade Estonia EUR 200,000 in 2023. BB Trade Estonia OÜ's 2024 consolidated report does not list BB Trade Switzerland AG among the companies in its consolidation group.", "qualification": "Shareholders of a Swiss AG are recorded in its private share register; none of the retained records shows who holds the shares.", "response": "", "outcome": "BB Trade Switzerland AG was dissolved by resolution of its general meeting of 16 July 2026 and is in liquidation (SHAB, 29 July 2026).", "source_ids": [ "src-010", "src-014", "src-013", "src-082" ], "entity_ids": [ "bb-switzerland", "bbte", "fenner", "buhler" ] }, { "id": "c-grp-nvp-press", "kind": "attributed", "text": "Swiss financial press reported on 27 April 2026 that two senior lawyers of the Zollikon law firm Neupert Vuille Partners sat on important boards around the crypto platform: one partner on the board of BB Trade Switzerland, apparently the operator of the Swiss ZondaCrypto platform, and another as the sole board member of Divisio Holding in Zug, described in media reports as the owner of the operator BB Trade Estonia.", "qualification": "The article does not name the two lawyers; register entries show Timo Fenner on the board of BB Trade Switzerland and André Marcel Terlinden as the board member of Divisio Holding AG.", "response": "According to the report, both lawyers left the outlet's requests of the previous week unanswered.", "outcome": "", "source_ids": [ "src-106", "src-080" ], "entity_ids": [ "nvp", "bb-switzerland", "divisio", "bbte", "fenner", "terlinden" ] }, { "id": "c-grp-fenner-nvp", "kind": "fact", "text": "Lawyer-directory profiles describe Timo Fenner as a lawyer and, since 2021, a partner of Neupert Vuille Partners (a senior associate there from 2018 to 2020), with the firm's postal address at Dufourstrasse 58, 8702 Zollikon, the address that BB Trade Switzerland AG adopted c/o NEUPERT, VUILLE & PARTNER in July 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-105", "src-116", "src-082" ], "entity_ids": [ "fenner", "nvp", "bb-switzerland" ] }, { "id": "c-grp-buhler-sbf", "kind": "fact", "text": "A SHAB publication of 15 July 2026 records that Guido Bühler left the executive board (Vorstand) of the Swiss Blockchain Federation, an association registered in Bern.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-017" ], "entity_ids": [ "buhler", "swiss-blockchain-federation" ] }, { "id": "c-grp-znd-ventures-register", "kind": "fact", "text": "The Estonian register card of ZND Ventures OÜ (registry code 16382854), retrieved on 19 October 2026, shows a company registered on 6 December 2021 under earlier names Norion OÜ and Stenotype OÜ, with share capital of EUR 10,000 and the address Tähesaju tee 9, Tallinn. BB Trade Estonia OÜ is its sole shareholder from 10 January 2024; Przemysław Janusz Kral is a management board member from 20 April 2026 and a procurator (prokurist) from 28 June 2023, and is recorded as its beneficial owner through indirect holding from 20 September 2022.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-045" ], "entity_ids": [ "znd-ventures", "bbte", "kral" ] }, { "id": "c-grp-znd-ventures-filings", "kind": "fact", "text": "ZND Ventures OÜ's annual reports filed in the Estonian register show revenue of EUR 5,597 and profit of EUR 2,588 for 2021-2022, revenue of EUR 41,196 and a loss of EUR 241,635 for 2023, and revenue of EUR 28,000 and a loss of EUR 885,590 for 2024; its 2025 report, due on 30 June 2026, had not been filed by 19 October 2026. On that date the company had no tax debt but had not filed its VAT returns due from May 2026, and five document-delivery notices of the Tax and Customs Board had been published for it between 3 August and 7 October 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-045" ], "entity_ids": [ "znd-ventures" ] }, { "id": "c-grp-znd-ventures-stake", "kind": "fact", "text": "BB Trade Estonia OÜ's 2022 annual report states that it held 50% of ZND Ventures OÜ at the end of 2022, carried at EUR 792,000 because payments had been made under an investment agreement, and that after the balance-sheet date, on 10 January 2024, it acquired a 100% holding; the 2024 report records the stake at 50% at the end of 2023 and 100% at the end of 2024.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028" ], "entity_ids": [ "bbte", "znd-ventures" ] }, { "id": "c-grp-znd-ventures-financing", "kind": "attributed", "text": "A law firm acting for claimants in the bankruptcy, reading BB Trade Estonia's accounts and general ledger, states that ZND Ventures OÜ first appeared in 2022 as an associate owned half by BB Trade Estonia and half by ICEO RED Venture Builder OÜ, a company of Wojciech Sroka, at a nominal value of EUR 1,250 against an investment cost of EUR 792,000; that the investment was shown at EUR 4,914,500 in the 2023 notes and EUR 4,924,500 in the balance sheet; that conversions of the investment agreement into reserve capital of EUR 2,500,000 (December 2024) and EUR 2,414,500 (May 2025) followed; and that after the stake became 100% in 2024 at a book value of EUR 2,510,000 the rest of the funding was carried as intercompany loans and receivables.", "qualification": "This is the law firm's reading of accounting records obtained in the bankruptcy; the general ledger is not in the retained record.", "response": "", "outcome": "", "source_ids": [ "src-010" ], "entity_ids": [ "bbte", "znd-ventures", "iceo-red-0", "sroka" ] }, { "id": "c-grp-zndco-register", "kind": "fact", "text": "ZND.CO OÜ (registry code 16874675) was registered in Estonia on 6 December 2023 with share capital of EUR 10,000 at Tähesaju tee 9, Tallinn. Its register card, retrieved on 19 October 2026, lists Wojciech Piotr Sroka as management board member from 6 December 2023 and ZND Ventures OÜ as sole shareholder from 14 May 2025, and records Przemysław Janusz Kral as beneficial owner through indirect holding from 6 December 2023.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-046" ], "entity_ids": [ "znd-co", "sroka", "znd-ventures", "kral" ] }, { "id": "c-grp-zndco-filings", "kind": "fact", "text": "ZND.CO OÜ's annual report for 6 December 2023 to 31 December 2024, filed on 28 June 2025, shows no revenue and a loss of EUR 954; its 2025 report, due on 30 June 2026, had not been filed by 19 October 2026. On that date the company owed EUR 600 in a coercive payment (sunniraha) outstanding since 23 August 2026, had not filed its VAT returns due from May 2026, and five document-delivery notices of the Tax and Customs Board had been published for it between 3 August and 8 October 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-046" ], "entity_ids": [ "znd-co" ] }, { "id": "c-grp-zndco-ownership", "kind": "attributed", "text": "A law firm acting for claimants in the bankruptcy states that ZND.CO OÜ was owned 50% by ZND Ventures OÜ and 50% by ICEO RED 0 OÜ until 14 May 2025, when ZND Ventures bought out the ICEO stake, and quotes the ZND token white paper as naming ZND.CO OÜ as the entity responsible for developing the software licensed to the issuer and used to operate the platform; it describes its managing director, Wojciech Piotr Sroka, as also running ICEO Group. BB Trade Estonia OÜ's 2024 annual report lists ZND.CO OÜ as an associate held at 50% at the end of 2023 and 2024.", "qualification": "The white paper itself is not in the retained record; the Estonian register shows ZND Ventures as sole shareholder only from 14 May 2025 and does not show earlier shareholders.", "response": "", "outcome": "", "source_ids": [ "src-008", "src-013" ], "entity_ids": [ "znd-co", "znd-ventures", "iceo-red-0", "sroka", "bbte" ] }, { "id": "c-grp-iceo-red-0", "kind": "fact", "text": "ICEO RED 0 OÜ (registry code 16536033, formerly ICEO Red Venture Builder OÜ) was registered in Estonia on 14 July 2022 with share capital of EUR 2,500 at Tähesaju tee 9, Tallinn, the same address as BB Trade Estonia OÜ. Its register card lists Wojciech Piotr Sroka and Dawid Mateusz Duniec as shareholders with 50% each (entered on 1 September 2023) and as beneficial owners through direct holding from 14 July 2022, and Sroka as its sole management board member from 14 July 2022.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-057" ], "entity_ids": [ "iceo-red-0", "sroka", "duniec", "bbte" ] }, { "id": "c-grp-admitrade-register", "kind": "fact", "text": "AdmiTrade OÜ (registry code 16309521, earlier names ICEO CAPITAL EST-1 OÜ and Norion OÜ) was registered in Estonia on 7 September 2021 with share capital of EUR 2,500 at Tähesaju tee 9, Tallinn, the same address as BB Trade Estonia OÜ. Its register card lists ICEO RED 0 OÜ as sole shareholder from 2 September 2023, Wojciech Piotr Sroka as management board member from 7 September 2021, and Dawid Mateusz Duniec and Sroka as beneficial owners through indirect holding from 12 September 2022. The card shows no licences in the Register of Economic Activities, and the 2025 annual report, due on 30 June 2026, had not been filed by 19 October 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-093" ], "entity_ids": [ "admitrade", "iceo-red-0", "sroka", "duniec", "bbte" ] }, { "id": "c-grp-admitrade-financials", "kind": "fact", "text": "AdmiTrade OÜ's annual reports filed in the Estonian register show revenue of EUR 655,875 and profit of EUR 360,369 for 2021-2022, no revenue and a profit of EUR 7,577 for 2023, and revenue of EUR 1,690,941 and profit of EUR 4,048,044 for 2024; its main activity is recorded as other software publishing (EMTAK 58291).", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-093" ], "entity_ids": [ "admitrade" ] }, { "id": "c-grp-beone-group", "kind": "fact", "text": "Swiss register data show BeOne Group AG (UID CHE-169.308.129) entered in the Zug commercial register on 17 September 2024 with share capital of CHF 100,000, at c/o AT Advisory Services AG, Baarerstrasse 78, Zug, with two board members including Wojciech Piotr Sroka; SHAB publications record Sroka moving from no signing authority to sole signature (July 2025) and then to joint signature (September 2025), and a third board member who joined on 4 September 2025 and left on 1 May 2026. The register data show no information on its owners.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-061" ], "entity_ids": [ "beone-group", "sroka" ] }, { "id": "c-grp-beone-ownership", "kind": "attributed", "text": "A law firm acting for claimants in the bankruptcy states that BeOne Group AG is owned half by ZND Ventures OÜ and half by Iceo group AG, the company of Wojciech Sroka and D. Duniec, and that it is the sole owner of BeOne Europe SIA of Riga, incorporated on 27 January 2025 with EUR 500,000 of capital paid in June 2025 and described in the group's own structure chart as the holder of an electronic money institution licence.", "qualification": "The structure chart is not in the retained record; the Swiss register does not show BeOne Group AG's shareholders, and no Latvian regulator's record of an electronic money licence was retrieved.", "response": "", "outcome": "", "source_ids": [ "src-010" ], "entity_ids": [ "beone-group", "znd-ventures", "iceo-group", "sroka", "duniec", "beone-europe" ] }, { "id": "c-grp-beone-europe", "kind": "fact", "text": "Latvian Register of Enterprises data reproduced by an aggregator show BeOne Europe SIA (registration number 50203620371), registered in Riga on 27 January 2025 in other financial service activities, with paid-up capital of EUR 500,000 (registered on 25 June 2025) and BeOne Group AG of Baarerstrasse 78, Zug, as sole shareholder of all 500,000 shares from 19 June 2025. The company reports beneficial owners and a two-member board, whose names the page does not show. As of 2 October 2026 it had a tax debt of EUR 58,949.72 and registered restrictions, with no liquidation or insolvency entry.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-060" ], "entity_ids": [ "beone-europe", "beone-group" ] }, { "id": "c-grp-pl-orion-register", "kind": "fact", "text": "Orion Software sp. z o.o. is a Polish limited company (KRS 0000827257) registered on 7 February 2020 at Aleja Wojciecha Korfantego 141B, Katowice, with share capital of PLN 3 million. Polish National Court Register (KRS) data reproduced by a commercial aggregator, current after entry no. 18 of 21 September 2026, list BB Trade Estonia OÜ as its sole shareholder (60,100 shares worth PLN 3 million) and Przemysław Janusz Kral as president of the management board since 26 March 2020 and as its beneficial owner.", "qualification": "The beneficial-owner entry describes Kral as the company's president; the KRS data do not show him holding shares in Orion directly.", "response": "", "outcome": "", "source_ids": [ "src-055" ], "entity_ids": [ "orion", "bbte", "kral" ] }, { "id": "c-grp-pl-orion-2024", "kind": "fact", "text": "A commercial aggregator's summary of Orion Software sp. z o.o.'s filed financial statements for 2024 gives total assets of PLN 258.1 million, revenue of PLN 19.7 million, costs of PLN 18.4 million and a profit of PLN 1.1 million. Under the company's articles as recorded in the KRS, each management board member may represent the company alone.", "qualification": "The figures are the aggregator's rounded summary of the company's own 2024 statements; the statements themselves and any audit report were not retained.", "response": "", "outcome": "", "source_ids": [ "src-055" ], "entity_ids": [ "orion" ] }, { "id": "c-grp-pl-bb-poland", "kind": "fact", "text": "BB Trade Poland sp. z o.o. (KRS 0000847033) was registered on 23 June 2020 under the name KP Immobiliare sp. z o.o., with Przemysław Janusz Kral as chief executive and share capital of PLN 5,000. Its seat, Aleja Wojciecha Korfantego 141B in Katowice, is also Orion Software's registered address. KRS data reproduced by a commercial aggregator, current after entry no. 16 of 13 October 2025, list Divisio Holding AG, the parent company of BB Trade Estonia OÜ, as sole shareholder (10 shares, PLN 5,000) and Kral as beneficial owner; BB Trade Estonia OÜ itself is not a shareholder.", "qualification": "", "response": "", "outcome": "An extraordinary shareholders' meeting on 15 September 2025 resolved to dissolve the company; it has been in liquidation since that date with Kral as liquidator. Its 2024 accounts show assets of PLN 5 thousand and no revenue.", "source_ids": [ "src-007", "src-059", "src-002" ], "entity_ids": [ "bb-poland", "kral", "orion", "divisio", "bbte" ] }, { "id": "c-grp-pl-branch", "kind": "fact", "text": "BB Trade Estonia OÜ has a registered Polish branch, entered in the KRS on 16 December 2024 as \"BB TRADE ESTONIA OÜ PRYWATNA SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ ODDZIAŁ W POLSCE\" (KRS 0001144319; legal form: branch of a foreign entrepreneur), with its seat at Ligocka 103, Katowice. The KRS entry names Przemysław Janusz Kral as branch director (dyrektor oddziału) from 16 December 2024 and identifies the foreign entrepreneur as BB Trade Estonia OÜ of Tähesaju tee 9, Tallinn.", "qualification": "Read through a commercial aggregator's reproduction of the KRS entry.", "response": "", "outcome": "", "source_ids": [ "src-009" ], "entity_ids": [ "bbte-pl-branch", "bbte", "kral" ] }, { "id": "c-grp-pl-fundacja", "kind": "fact", "text": "Fundacja Zondacrypto (KRS 0001103797) is a Polish foundation registered on 9 May 2024 with its seat at Ligocka 103, Katowice, the same address as BB Trade Estonia OÜ's Polish branch. KRS data reproduced by a commercial aggregator, current after entry no. 4 of 5 October 2026, list Przemysław Kral as president of its management board since 9 May 2024 and Przemysław Janusz Kral as its beneficial owner. Its stated objectives include social, educational, charitable and health activities and the promotion of modern technologies.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-011", "src-007", "src-009" ], "entity_ids": [ "fundacja-zondacrypto", "kral", "bbte-pl-branch", "bbte" ] }, { "id": "c-grp-kral-seed", "kind": "fact", "text": "Seed Investments sp. z o.o. (KRS 0000498898, Warsaw) is a company of which Przemysław Janusz Kral has been the sole shareholder (100 shares, PLN 5,000) and beneficial owner since 9 April 2020, according to KRS data reproduced by a commercial aggregator. Kral became its chief executive in the publication of 9 April 2020 and ceased to be chief executive on 5 January 2026, when the company went into liquidation with Karolina Ewa Gwóźdź as liquidator.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-035", "src-007" ], "entity_ids": [ "seed-investments", "kral", "gwozdz" ] }, { "id": "c-grp-kral-digesta", "kind": "fact", "text": "Digesta Pro sp. z o.o. (KRS 0000563616, Katowice, registered 1 July 2015) has had Przemysław Janusz Kral as sole shareholder (100 shares, PLN 5,000) and beneficial owner since 11 February 2021, according to KRS data reproduced by a commercial aggregator. Kral was its chief executive from 11 February 2021 until 15 January 2026, when another person became president of the management board.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-007", "src-071" ], "entity_ids": [ "digesta-pro", "kral" ] }, { "id": "c-grp-kral-decori", "kind": "fact", "text": "Przemysław J. Kral was a member of the management board of Decori sp. z o.o. (KRS 0000462946, Pszczyna) from 10 July 2020 to 3 June 2024, according to Polish register publications reproduced by a commercial aggregator. Current KRS data for Decori list another person as sole shareholder since 11 October 2019 and do not list Kral in its governing bodies.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-007", "src-072" ], "entity_ids": [ "decori", "kral" ] }, { "id": "c-grp-kral-duraj", "kind": "fact", "text": "Przemysław Janusz Kral was one of four partners of Duraj, Reck & Kral Adwokaci, Doradcy Podatkowi sp.p., a Katowice partnership of advocates and tax advisers registered on 14 March 2011 and terminated on 9 September 2020, according to Polish register publications reproduced by a commercial aggregator.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-007" ], "entity_ids": [ "duraj-reck-kral", "kral" ] }, { "id": "c-grp-cz-expofer-director", "kind": "fact", "text": "Przemysław Janusz Kral has been a statutory director (jednatel) of EXPOFÉR SERVIS HOUSE s.r.o., V Zátiší 810/1, Ostrava, since 3 January 2022; the entry was made in the Czech commercial register on 2 February 2022. Czech register data reproduced by a commercial aggregator list this as the only Czech company in which he has held a position.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-012", "src-002" ], "entity_ids": [ "expofer", "kral" ] }, { "id": "c-grp-cz-expofer-owners", "kind": "attributed", "text": "EXPOFÉR SERVIS HOUSE s.r.o. was registered on 11 May 2017. A commercial aggregator's summary of a Czech register publication of 23 April 2024 records a change of shareholdings naming Divisio Holding AG, Luxbay SA and ADMI BUSINESS SERVIS s.r.o., and the aggregator's network view shows Divisio Holding AG as current 100% shareholder and Luxbay SA as a former 100% shareholder.", "qualification": "This rests on an aggregator's automated summary and network graph, which states that the direction and identity of its links are not verified; the Czech register extract itself was not retained, so the sequence and dates of the earlier holdings are not shown.", "response": "", "outcome": "", "source_ids": [ "src-007", "src-063", "src-002" ], "entity_ids": [ "expofer", "divisio", "luxbay", "admi-business" ] }, { "id": "c-grp-sk-company", "kind": "fact", "text": "zondacrypto SK, s. r. o. (IČO 55157157) came into existence on 26 January 2023 under the name TRJK CO s.r.o., registered with the Commercial Register of the Prešov District Court; it bore that name until 24 April 2023 and had its seat in Prešov until 12 May 2023. It is now seated at Odborárska 21, Bratislava, with registered capital of EUR 5,000, fully paid. For 2025 it reported no revenue and a loss of EUR 370.", "qualification": "Read through a Slovak business-information service reproducing the commercial register and the company's accounts.", "response": "", "outcome": "", "source_ids": [ "src-049", "src-050" ], "entity_ids": [ "zondacrypto-sk" ] }, { "id": "c-grp-sk-owner", "kind": "fact", "text": "According to the full extract of the Slovak Commercial Register (ORSR), Divisio Holding AG of Baarerstrasse 78, Zug (CHE-161.370.248) has been the sole shareholder of zondacrypto SK, s. r. o. since 22 April 2023, with a fully paid cash contribution of EUR 5,000; from 26 January to 21 April 2023 the shareholders were an individual and TRJK s. r. o. The Slovak company is therefore held by BB Trade Estonia OÜ's parent company, not by BB Trade Estonia OÜ.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-051" ], "entity_ids": [ "zondacrypto-sk", "divisio", "bbte" ] }, { "id": "c-grp-sk-director", "kind": "fact", "text": "The ORSR extract records Przemysław Kral as the sole statutory director (konateľ) of zondacrypto SK, s. r. o., with his function beginning on 25 March 2023 (entry effective from 22 April 2023); the director may act for the company alone. A different individual was the company's director from 26 January to 24 March 2023.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-051" ], "entity_ids": [ "zondacrypto-sk", "kral" ] }, { "id": "c-grp-sk-activities", "kind": "fact", "text": "Since 12 May 2023 the registered business activities of zondacrypto SK, s. r. o. have included the provision of virtual-currency exchange services and the provision of virtual-currency wallet services (poskytovanie služieb zmenárne virtuálnej meny; poskytovanie služieb peňaženky virtuálnej meny), alongside activities registered on 26 January 2023.", "qualification": "These are entries in the list of business activities reproduced from the commercial register by a Slovak business-information service; they are not a licence decision of a financial supervisor.", "response": "", "outcome": "", "source_ids": [ "src-050" ], "entity_ids": [ "zondacrypto-sk" ] }, { "id": "c-grp-it-branch", "kind": "fact", "text": "BB Trade Estonia OÜ's consolidated annual report for 2024 lists \"BB Trade Estonia Italian Branch (Italy)\" in its consolidation group from 2024. The Italian operation is a branch of BB Trade Estonia OÜ rather than a separate company: the Italian register of virtual-currency service providers kept by the Organismo Agenti e Mediatori enters BB TRADE ESTONIA OU itself, with an Italian tax code and a Milan address, under number PSV48.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013", "src-100" ], "entity_ids": [ "bb-trade-it", "bbte" ] }, { "id": "c-grp-gi-zonda-gibraltar", "kind": "fact", "text": "In the events after the reporting date of its 2021 annual report, BB Trade Estonia OÜ states that Zonda Gibraltar Ltd was also established in 2022, and that an operating licence was registered and obtained in Italy.", "qualification": "The report gives no shareholding, registration number or later status for Zonda Gibraltar Ltd, and no Gibraltar register record was retained.", "response": "", "outcome": "", "source_ids": [ "src-003" ], "entity_ids": [ "bbte", "zonda-gibraltar" ] }, { "id": "c-grp-cy-register", "kind": "fact", "text": "BB Trade (Cyprus) Limited (registration number HE 468498) was registered in Cyprus on 4 December 2024 as a limited company with its address at Thasou 3, Nicosia. Cypriot register data reproduced by commercial aggregators record two individual directors, one of whom is also company secretary. One aggregator snapshot gives its status as active; a later one, updated on 13 October 2026, gives the register status \"Three month notice published\".", "qualification": "The retained pages show neither the company's members nor its share capital, and they do not include the Registrar of Companies' own record or the notice itself, so the reason for the three-month notice is not shown.", "response": "", "outcome": "", "source_ids": [ "src-036", "src-053" ], "entity_ids": [ "bb-cyprus" ] }, { "id": "c-grp-cy-lei", "kind": "fact", "text": "The legal entity identifier record of BB Trade (Cyprus) Limited (LEI 984500FBK7072B5C0944), first registered on 17 September 2025 and last updated on 21 July 2026, reports no direct or ultimate parent, giving the reason code NON_CONSOLIDATING for both.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-054" ], "entity_ids": [ "bb-cyprus" ] }, { "id": "c-grp-cy-lt-group", "kind": "attributed", "text": "According to a law firm acting for claimants in BB Trade Estonia OÜ's bankruptcy, which says it reviewed the exchange's records, BB Trade (Cyprus) Limited and BB Trade Lithuania UAB belong to the group below BB Trade Estonia OÜ but do not yet appear in any of its financial statements. The firm says the exchange lent the Cypriot company EUR 100,000 on 25 April 2025, EUR 50,000 on 26 September 2025 and EUR 150,000 on 10 October 2025 at ten per cent, repayable in 2030, and lent BB Trade Lithuania UAB, whose director it names as Przemysław Kral, EUR 10,000 on 5 May 2025 for one year at ten per cent.", "qualification": "The loan agreements and the share registers were not retained. The Cypriot company's LEI record reports no parent (reason code NON_CONSOLIDATING), and the Lithuanian business directory names only an unnamed corporate shareholder, so the retained records do not confirm who owns either company.", "response": "", "outcome": "", "source_ids": [ "src-010" ], "entity_ids": [ "bb-cyprus", "bb-lithuania", "bbte", "kral" ] }, { "id": "c-grp-lt-company", "kind": "fact", "text": "BB Trade Lithuania, UAB (company code 305790188) was founded on 7 June 2021, has share capital of EUR 125,000 and is located at A. Goštauto g. 8-224, Vilnius. A Lithuanian business directory records one corporate shareholder, whose name it does not give, computers and software as main activity, and for 2025 revenue of EUR 0 and a net loss of EUR 6,312.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-037" ], "entity_ids": [ "bb-lithuania" ] }, { "id": "c-grp-bs-scb-officers", "kind": "fact", "text": "The register of digital asset businesses of the Securities Commission of The Bahamas, with information as at 30 November 2025, lists BB Trade Bahamas Ltd at 201 Church Street, Sandyport, West Bay Street, Nassau. It names Przemyslaw Kral as principal; Przemyslaw Kral, Dawid Sendecki, Guido Buhler and Reece Chipman as directors; Reece Chipman as chief executive officer; and Samuel Wilkinson as compliance officer and money laundering reporting officer.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-020" ], "entity_ids": [ "bb-bahamas", "kral", "sendecki", "buhler", "chipman", "wilkinson" ] }, { "id": "c-grp-bs-lei-vat", "kind": "fact", "text": "BB Trade Bahamas Ltd holds legal entity identifier 894500Q6B8UQVD0BXY93; its LEI record gives the Bahamian registration number 213148B, a creation date of 10 June 2024 and an active status. A list of registered VAT taxpayers published by the Bahamas Department of Inland Revenue includes BB Trade Bahamas Ltd. of New Providence under tax identification number 131-213-434.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-092", "src-048" ], "entity_ids": [ "bb-bahamas" ] }, { "id": "c-grp-bs-group-status", "kind": "unresolved", "text": "The records disagree on how BB Trade Bahamas Ltd relates to BB Trade Estonia OÜ. BB Trade Estonia OÜ's consolidated annual report for 2024 lists BB Trade Bahamas Ltd in its consolidation group from 2024. The company's LEI record, however, reports no direct or ultimate parent, giving the reason code NATURAL_PERSONS. A law firm acting for claimants in the bankruptcy notes that the 2024 report names the Bahamian company only in its consolidation-policy note and not in the note on subsidiaries, so no acquisition date, ownership percentage or book value is given, although the auditor's opinion on that report was unqualified.", "qualification": "No Bahamian share register or acquisition document was retained; the Securities Commission register names Przemyslaw Kral as the company's principal. Who owns BB Trade Bahamas Ltd therefore remains unresolved in the retained material.", "response": "", "outcome": "", "source_ids": [ "src-048", "src-010", "src-013" ], "entity_ids": [ "bb-bahamas", "bbte" ] }, { "id": "c-grp-us-florida", "kind": "fact", "text": "BB TRADE FLORIDA INC. is a Florida profit corporation (document number P24000070168, FEI/EIN 33-1989108) filed on 14 November 2024 and recorded as active by the Florida Division of Corporations. Its principal address has been 200 South Biscayne Boulevard, 20th floor, Miami since an amendment of 28 April 2026; the record shows a reinstatement on 6 October 2025, annual reports for 2025 and 2026, and Przemyslaw Kral as chief executive officer.", "qualification": "The state record lists officers and a registered agent but not shareholders, so it does not show whether BB Trade Estonia OÜ, another group company or Kral owns the corporation.", "response": "", "outcome": "", "source_ids": [ "src-118" ], "entity_ids": [ "bb-florida", "kral" ] }, { "id": "c-grp-suszek-bitbay", "kind": "fact", "text": "Sylwester Jan Suszek was registered as a commercial proxy (prokurent) of BitBay sp. z o.o. from 28 May 2014 and as its chief executive from 21 September 2017, according to Polish register publications reproduced by a commercial aggregator. BitBay sp. z o.o. was terminated on 17 February 2026, when Suszek ceased to be chief executive and three corporate shareholders were recorded as no longer shareholders.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-015" ], "entity_ids": [ "suszek", "bitbay" ] }, { "id": "c-grp-suszek-luxbay-sb", "kind": "fact", "text": "Sylwester Jan Suszek was a director of Luxbay SA, Luxembourg, in a publication of 21 July 2021, and a director of S&B Investment SA (Luxembourg trade register B237594) from 9 July 2021 until 14 November 2023. S&B Investment SA, whose registered purpose is acquiring and managing shareholdings, was registered on 4 September 2019 with capital of EUR 30,000. Przemysław Janusz Kral has been one of its directors since 13 November 2023; the publication of 14 November 2023 records Kral's appointment, Suszek's departure and a change of auditor.", "qualification": "Read through a commercial aggregator's reproduction of Luxembourg register publications; the company has had further directors, who are not named here.", "response": "", "outcome": "", "source_ids": [ "src-015", "src-022", "src-007" ], "entity_ids": [ "suszek", "luxbay", "sb-investment", "kral" ] }, { "id": "c-grp-suszek-creative-invest", "kind": "fact", "text": "The Estonian e-Business Register lists Sylwester Jan Suszek as management board member of Creative Invest Int OÜ (registry code 14432051, registered on 19 February 2018) since 23 February 2018 and as its sole shareholder. The company's registered address, Lõõtsa tn 5, 11415 Tallinn, is the address BB Trade Estonia OÜ used until April 2020, and its contact e-mail address is the one given in BB Trade Estonia OÜ's annual report for 2019–2020.", "qualification": "", "response": "", "outcome": "The register shows unpaid fines imposed by the registration department of Tartu County Court and no annual report filed for any financial year from 2018 to 2025.", "source_ids": [ "src-056", "src-006" ], "entity_ids": [ "suszek", "creative-invest", "bbte" ] }, { "id": "c-grp-suszek-uae", "kind": "attributed", "text": "A law firm acting for claimants in the bankruptcy says it obtained printouts from the Dubai Department of Economy (DED) register for Skybay Investment in Commercial Enterprises L.L.C. and Arial Investment in Commercial Enterprises L.L.C., two of the three Dubai companies that held BitBay sp. z o.o. Per those printouts, Sylwester Jan Suszek is the partner (49 per cent) and manager of Skybay (licence 777127 of 28 February 2017, capital AED 300,000), while Arial (licence 781995 of 7 May 2017) has a different individual as partner and manager and moved to Skybay's office address on 9 May 2018; the remaining 51 per cent of each belongs to a local sponsor.", "qualification": "The DED printouts are not in the retained record; this is the firm's description of them. The firm itself calls the earlier press thesis that all three companies were Suszek's 'a simplification' and says it holds no documents for the third shareholder, Central Bay.", "response": "", "outcome": "", "source_ids": [ "src-074" ], "entity_ids": [ "suszek", "skybay", "arial", "central-bay", "bitbay" ] }, { "id": "c-grp-suszek-bitbay-shares", "kind": "attributed", "text": "The same law firm, citing BitBay sp. z o.o.'s accounts, says Skybay held 47 per cent of BitBay at a shareholders' meeting on 8 December 2017 and 940 of 2,100 shares (44.8 per cent) in 2019, remaining the largest shareholder; Arial held 38.5 per cent in December 2017 and 870 shares (41.4 per cent) in 2019; and Central Bay held 290 shares (13.8 per cent), disclosed in the Polish register on 26 July 2018. It adds that BitBay's largest shareholder has had no active manager since Suszek disappeared in March 2022, and that Polish press, citing court files, reported that beforehand Suszek moved his BitBay shares to three Dubai companies of his own.", "qualification": "BitBay's statements and the court files are not in the retained record; the percentages are the firm's account. Its own reading of the Dubai documents attributes only Skybay, not Arial, to Suszek.", "response": "", "outcome": "", "source_ids": [ "src-074" ], "entity_ids": [ "skybay", "arial", "central-bay", "bitbay", "suszek" ] }, { "id": "c-grp-sobkow-ico-house", "kind": "fact", "text": "ICO HOUSE S.A. (KRS 0000739579, Warsaw) was registered on 6 July 2018 with share capital of PLN 100,000, of which PLN 25,000 paid. KRS data reproduced by a commercial aggregator, current after entry no. 7 of 5 June 2026, list Paweł Sobków as its sole shareholder and beneficial owner since 6 July 2018 and a supervisory board appointed on 6 July 2018 consisting of Paweł Sobków, Sylwester Suszek and Wojciech Sroka.", "qualification": "The KRS data do not show the company's business or any dealings with BitBay sp. z o.o. or BB Trade Estonia OÜ.", "response": "", "outcome": "", "source_ids": [ "src-101" ], "entity_ids": [ "ico-house", "sobkow", "suszek", "sroka" ] }, { "id": "c-lic-fvt-2020", "kind": "fact", "text": "According to BB Trade Estonia OÜ's annual report for 2019–2020, the company obtained two operating licences, numbered FRK001037 and FVR0011, in October 2020; after a change in Estonian legislation the two were combined into a single licence for providing virtual currency services, numbered FVT000209.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006" ], "entity_ids": [ "bbte" ] }, { "id": "c-lic-fiu-2023-continuation", "kind": "attributed", "text": "In its annual report for 2023 BB Trade Estonia OÜ stated that it had gone through a two-year audit covering several business areas and that in July 2023 it received the Financial Intelligence Unit's permission to continue operating under the new rules. Its 2022 annual report similarly describes the end of a regulatory review with positive feedback and the grant of an operating licence under the new rules.", "qualification": "This is the company's own account in its annual reports; no FIU decision of July 2023 was retained, and the FIU's register lists a precept issued to the company on 1 February 2023.", "response": "", "outcome": "", "source_ids": [ "src-027", "src-028" ], "entity_ids": [ "bbte" ] }, { "id": "c-lic-fiu-precept-2023", "kind": "fact", "text": "The Estonian Financial Intelligence Unit (Rahapesu Andmebüroo, FIU) lists in its register of precepts a compliance notice issued on 1 February 2023 to BB Trade Estonia OÜ as holder of virtual currency service licence FVT000209.", "qualification": "The register entry for 2023 gives only the company, licence, area of activity and date; it does not state the content of the precept. Several other virtual-currency providers are listed with notices dated 1 or 2 February 2023.", "response": "", "outcome": "", "source_ids": [ "src-111" ], "entity_ids": [ "bbte" ] }, { "id": "c-lic-fiu-precept-2025", "kind": "fact", "text": "On 16 July 2025 the FIU issued precept No. 6-2/102 to BB Trade Estonia OÜ (licence FVT000209, virtual currency services) under § 72(1)(7) and § 72³(4) of the Money Laundering and Terrorist Financing Prevention Act because the company had not submitted an auditor's report on its own funds. Other virtual-currency providers received precepts with the same cause on the same day.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-111" ], "entity_ids": [ "bbte" ], "adverse_subject_ids": [ "bbte" ] }, { "id": "c-lic-fiu-suspension-2026", "kind": "fact", "text": "On 18 May 2026 the FIU partially suspended BB Trade Estonia OÜ's operating licence FVT000209 (Zondacrypto brand): the company was prohibited from accepting any additional assets, including fiat funds and crypto-assets, from existing clients and from entering into business relationships with new clients, while the return or withdrawal of assets by existing clients was not affected. By the same decision the FIU ordered the company to bring its operations into compliance with the licence conditions within 30 days, citing among other grounds § 75(1)(4) of the Money Laundering and Terrorist Financing Prevention Act and § 43 of the General Part of the Economic Activities Code Act.", "qualification": "", "response": "", "outcome": "The FIU revoked the licence on 29 June 2026 after the company neither responded to nor complied with the precept.", "source_ids": [ "src-081", "src-030" ], "entity_ids": [ "bbte" ], "adverse_subject_ids": [ "bbte" ] }, { "id": "c-lic-fiu-revocation-2026", "kind": "fact", "text": "On 29 June 2026 the FIU revoked BB Trade Estonia OÜ's licence No. FVT000209 to provide virtual currency services under § 75(1)(4) of the Money Laundering and Terrorist Financing Prevention Act, stating that the company had not responded to or complied with the precept of 18 May 2026 requiring it to bring its activities into line with the licence conditions. According to the FIU the licence had been valid from 5 October 2020 until 29 June 2026.", "qualification": "The FIU stated that its supervision mainly assesses whether a company's documentation complies with the anti-money laundering law and that it has no mandate for prudential supervision, including the safekeeping and protection of clients' assets, their physical existence or liquidity.", "response": "According to the FIU, BB Trade Estonia OÜ did not respond to the precept of 18 May 2026; no reply, statement or appeal by the company on the suspension or the revocation is in the retained record.", "outcome": "", "source_ids": [ "src-030" ], "entity_ids": [ "bbte" ], "adverse_subject_ids": [ "bbte" ] }, { "id": "c-lic-efsa-warning-2026", "kind": "fact", "text": "On 6 May 2026 Finantsinspektsioon, the Estonian Financial Supervision and Resolution Authority, issued a public warning about BB Trade Estonia OÜ (website zondacrypto.com): the white paper of the crypto-asset \"TeamPL Token\" (TMPL) offered by the company was not available on its official website, which the authority described as a violation of Article 9(1) of Regulation (EU) 2023/1114 (MiCA), under which a white paper must remain available on the offeror's website for as long as the crypto-assets are held by the public.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-004" ], "entity_ids": [ "bbte" ], "adverse_subject_ids": [ "bbte" ] }, { "id": "c-lic-mica-whitepaper", "kind": "fact", "text": "Registry data compiled by a commercial aggregator from the ESMA interim MiCA register and the Estonian supervisor's register (snapshot of 16 October 2026) list BB Trade Estonia OÜ as a crypto-asset offeror that notified one white paper, dated 16 February 2026 and hosted under a TMPL-token address, to the Estonian Financial Supervision Authority, with the offer notified for 27 EU member states and no crypto-asset service provider named.", "qualification": "A white paper under MiCA is notified to the authority, not approved by it. The ESMA register itself was not retained; the aggregator first recorded the entry in its snapshot of 23 February 2026.", "response": "", "outcome": "", "source_ids": [ "src-038" ], "entity_ids": [ "bbte" ] }, { "id": "c-lic-cysec-2024", "kind": "fact", "text": "The Cyprus Securities and Exchange Commission's EEA CASP Register under Cyprus's national crypto-asset regime lists BB Trade Estonia OU, with its Tallinn address, a registration date of 2 September 2024 and the approved trade name zondacrypto.com.", "qualification": "The entry is a listing of a provider from another EEA state under Cyprus's pre-MiCA national regime, relying on the company's Estonian status; it is not a Cypriot licence or a MiCA authorisation. The register page was retained only as an archived copy of December 2025.", "response": "", "outcome": "", "source_ids": [ "src-085" ], "entity_ids": [ "bbte" ] }, { "id": "c-lic-cysec-press-2024", "kind": "attributed", "text": "In October 2024 a crypto-industry news report said that CySEC had licensed the Zondacrypto exchange, its \"7th license\", quoting a social-media post by chief executive Przemysław Kral, and that the brand had obtained an over-the-counter licence in Switzerland the previous year.", "qualification": "The report names no legal entity. The CySEC record retained for this period is BB Trade Estonia OÜ's listing under Cyprus's national regime of 2 September 2024, which is not a Cypriot licence; no Swiss licensing record was retained, and a January 2025 release for the brand states that its Swiss entity is not licensed or supervised by FINMA.", "response": "", "outcome": "", "source_ids": [ "src-084", "src-113" ], "entity_ids": [ "kral", "bbte" ] }, { "id": "c-lic-oam-2022", "kind": "fact", "text": "The register of virtual-currency service providers kept by the Italian Organismo Agenti e Mediatori (OAM) lists \"BB TRADE ESTONIA OU\" as a legal person with Italian tax code 12490930968, a seat at Via Fatebenefratelli 20, Milan, and the website zondaglobal.com/it, registered under No. PSV48 on 22 July 2022 with the status \"ISCRITTO\" (registered).", "qualification": "The export shows no suspension or cancellation; it does not state when it was generated.", "response": "", "outcome": "", "source_ids": [ "src-100" ], "entity_ids": [ "bbte" ] }, { "id": "c-lic-bahamas-dare", "kind": "fact", "text": "According to the Securities Commission of The Bahamas register of digital asset businesses as at 30 November 2025, BB Trade Bahamas Ltd is registered as a digital asset exchange and digital asset business for operating a digital asset exchange, exchanging digital assets for fiat currency or other digital assets, payment services involving digital assets and executing orders; the registration is marked \"Approved on Condition\", with no sanctions and no registrations or licences held outside The Bahamas.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-020" ], "entity_ids": [ "bb-bahamas" ] }, { "id": "c-lic-swiss-vqf", "kind": "attributed", "text": "A January 2025 press release issued for the zondacrypto brand together with Incore Bank states that BB Trade Switzerland AG is affiliated with VQF, a Swiss self-regulatory organisation for anti-money-laundering purposes, and is permitted to offer payment transaction services, and that the brand's Swiss entity is a member of the Swiss Blockchain Federation. The same release states that in Switzerland the brand is not licensed or supervised by FINMA.", "qualification": "This is a self-statement of the brand and its banking partner; no VQF membership record was retained. A Swiss consultancy's April 2026 publication repeats the VQF membership.", "response": "", "outcome": "", "source_ids": [ "src-113", "src-087" ], "entity_ids": [ "bb-switzerland", "incore", "swiss-blockchain-federation" ] }, { "id": "c-lic-florida-msb", "kind": "attributed", "text": "In November 2025 a news report, based on the company's announcement, said that BB Trade Florida Inc., described as the U.S. entity of zondacrypto, had been granted a money services business licence by the Florida Office of Financial Regulation under Chapter 560 of the Florida Statutes, covering money transmission including virtual currencies, and quoted Przemysław Kral as chief executive of zondacrypto.", "qualification": "This rests on the company's announcement; no record from the Florida regulator's licence portal was retained, so the licence number and its later status are not established.", "response": "", "outcome": "", "source_ids": [ "src-117" ], "entity_ids": [ "bb-florida", "kral" ] }, { "id": "c-lic-uokik-2025", "kind": "attributed", "text": "According to Polish legal press quoting the Office of Competition and Consumer Protection (UOKiK), UOKiK opened proceedings concerning BB Trade Estonia OÜ in January 2025 on its rules for concluding, performing and terminating contracts, examining possible infringements and unfair contract clauses, and the proceedings were still under way.", "qualification": "Reported by the press from UOKiK's answer; no UOKiK decision was retained and the outcome is not known.", "response": "", "outcome": "", "source_ids": [ "src-095" ], "entity_ids": [ "bbte" ], "adverse_subject_ids": [ "bbte" ] }, { "id": "c-lic-brand-claims-2025", "kind": "attributed", "text": "Press releases issued for the zondacrypto brand claimed broad regulatory coverage: a January 2025 release said the brand's local entities held operating licences or self-regulatory memberships in Estonia, Italy, Cyprus, Canada, Switzerland, Slovakia, Poland and Lithuania, and a July 2025 release said the exchange operator had operating licences, VASP registrations or SRO memberships in Italy, Switzerland, Cyprus, Poland, Estonia, Slovakia and Canada.", "qualification": "These are self-statements that do not say which legal entity holds which authorisation. Retained official records cover the Estonian FIU licence, the Italian OAM registration and the Cypriot national-regime listing of BB Trade Estonia OÜ; no Polish, Canadian or Lithuanian authorisation record was retained, and the January release itself states that the Swiss entity is not licensed or supervised by FINMA.", "response": "", "outcome": "", "source_ids": [ "src-052", "src-113" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-2020-offbalance", "kind": "fact", "text": "In its annual report for 2019–2020 BB Trade Estonia OÜ stated that it held various classes of crypto-assets on behalf of its clients, that it had no responsibility or obligations in connection with holding them and derived no economic benefit from them, and it reported off-balance-sheet obligations relating to clients' crypto-assets of EUR 192,688,141 at 31 December 2020.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-2021-onbalance", "kind": "fact", "text": "From its 2021 annual report BB Trade Estonia OÜ recognised clients' crypto-assets on its balance sheet as client assets within inventories, with matching liabilities to clients. At 31 December 2021 clients owned virtual currencies worth EUR 482,676,641 and the company EUR 132,683; the report restated the 31 December 2020 holdings as EUR 191,758,642, all belonging to clients. The largest holdings at the end of 2021 were bitcoin (36%) and ether (31.5%).", "qualification": "The 2019–2020 report had given EUR 192,688,141 as the off-balance amount for the same date; the reports do not reconcile the two figures.", "response": "", "outcome": "", "source_ids": [ "src-003", "src-006" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-2021-client-money", "kind": "fact", "text": "According to the 2021 annual report, client money held by BB Trade Estonia OÜ amounted to EUR 31,750,893 at 31 December 2021 (EUR 48,390,205 a year earlier); it was kept separate from the company's working capital and partly held by payment service providers. Under the client agreement the company had the right to use funds in client accounts and had done so in 2020, recording EUR 906,184 as a debt to clients at 31 December 2020. The company's own cash was EUR 1,483,972 at the end of 2021 (nil a year earlier); of all cash, EUR 5,648,135 was in bank accounts and EUR 27,586,730 with payment service providers at 31 December 2021.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-2022-client-money", "kind": "fact", "text": "According to the 2022 annual report, client money amounted to EUR 34,206,833 at 31 December 2022 and the company's own cash was nil (EUR 1,483,972 a year earlier). The report states that the company holds part of clients' funds in crypto-assets, that it used its contractual right to use client funds in 2022 and that the amount used, recorded as a debt to clients, totalled EUR 26,220,117; the note dates that figure \"as at 31.12.2023\".", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-2022-crypto-liabilities", "kind": "fact", "text": "At 31 December 2022, according to the 2022 annual report, clients owned virtual currencies worth EUR 154,384,891 and the company EUR 868,039. Liabilities to clients were EUR 164,207,285, made up of a client cash balance of EUR 34,206,833 (deposits awaiting confirmation or rejection and funds awaiting withdrawal) and a liability to clients in crypto-assets of EUR 130,000,453.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028", "src-027" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-use-of-funds-2022", "kind": "unresolved", "text": "BB Trade Estonia OÜ's annual reports give different figures for the use of client funds in 2022: the 2022 report records EUR 26,220,117 of client money used and owed to clients, while the 2023 report shows EUR 1,835,679 as the 2022 comparative for liabilities arising from the use of client funds. A law firm acting for claimants in the bankruptcy cites the company's balance sheets as showing \"customer-fund-use\" of EUR 26.2 million (2022), EUR 19 million (2023) and EUR 82.7 million (2024).", "qualification": "The two notes may measure different items (fiat client money used versus a crypto-denominated liability), but the reports do not reconcile them and the retained record does not resolve the difference.", "response": "", "outcome": "", "source_ids": [ "src-008", "src-028", "src-027" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-2023-client-funds", "kind": "fact", "text": "According to the 2023 consolidated annual report, client money was EUR 30,851,817 at 31 December 2023 (2022: EUR 34,206,833). The company used client funds in 2023 under the client agreement, recording EUR 18,939,269 as a debt to clients, and held its fiat obligations to clients in crypto-assets. Of the EUR 308,223,793 owed to clients in crypto-assets, EUR 289,189,285 was the liability for virtual currencies and EUR 19,034,508 the liability arising from the use of client funds.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-027" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-2024-crypto", "kind": "fact", "text": "According to the 2024 consolidated annual report, at 31 December 2024 clients owned virtual currencies worth EUR 565,415,120 and the company EUR 28,712,020, of which EUR 7,886,423 was its own ZND token; bitcoin made up 71% of the holdings, ZND 5% and ether 4%.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-2024-liabilities", "kind": "fact", "text": "The 2024 consolidated annual report shows client assets and liabilities of EUR 722,356,044 at 31 December 2024 (2023: EUR 338,875,597), including a client cash balance of EUR 74,195,735 (2023: EUR 30,851,817). Of EUR 648,160,309 owed to clients in crypto-assets, EUR 565,415,120 was the liability for clients' crypto-assets and EUR 82,745,189 (2023: EUR 19,034,508) the liability arising from the use of client funds, in fiat and crypto. The report states that the company holds part of client funds in crypto rather than money, may use funds in client accounts under the client agreement, and has reinvested client funds both short- and long-term.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-audit-2020", "kind": "fact", "text": "Audit Advisory OÜ, through sworn auditor Liina Tamm, gave a qualified opinion dated 24 September 2021 on BB Trade Estonia OÜ's 2020 financial statements: it found revenue understated by about EUR 280,000 and expenses understated by about EUR 146,000 because of the accounting system used, and could not assess whether loan and interest receivables of about EUR 1,302,000 needed impairment.", "qualification": "", "response": "", "outcome": "In its 2021 annual report the company stated that it had corrected its 2020 revenue and expenses: 2020 revenue rose by EUR 280,000 to EUR 9,117,007, costs of goods, materials and services by EUR 144,845, and the 2020 profit from EUR 6,491,835 to EUR 6,626,090.", "source_ids": [ "src-006", "src-003" ], "entity_ids": [ "bbte", "audit-advisory", "tamm" ] }, { "id": "c-ast-audit-2021-disclaimer", "kind": "fact", "text": "Crowe DNW OÜ, through sworn auditor Anton Mullo, disclaimed an opinion on BB Trade Estonia OÜ's 2021 financial statements in a report dated 30 November 2022. Its main ground was virtual currencies of about EUR 482.8 million in inventories: bitcoin worth about EUR 145.7 million was, according to the company, held in a wallet to which management had restricted access citing security measures, so the auditor could not verify its existence or ownership.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003" ], "entity_ids": [ "bbte", "crowe-dnw", "mullo" ] }, { "id": "c-ast-audit-2021-other-grounds", "kind": "fact", "text": "The 2021 disclaimer also cited other virtual currencies of about EUR 9.5 million for which management gave no wallet statements or addresses, a LUNA balance of about EUR 13.1 million and a litecoin balance of about EUR 2.4 million that could not be verified, about EUR 1.9 million of tokens valued at prices from the company's own platform, liabilities to clients of about EUR 34.2 million that the accounting system could not attribute to individual clients, and investments of about EUR 2.4 million that management had not tested for impairment. It further cited loan receivables of about EUR 3.9 million not repaid by the time of the report, on whose borrowers' intention and ability to repay it could obtain no evidence, a point also made in the auditor's report on the previous year; about EUR 0.9 million of sales revenue for which it received no detailed transaction statements; a gain of about EUR 0.6 million from changes in crypto-currency values for which management provided no underlying data; and an opening balance containing virtual currencies of about EUR 182.4 million and liabilities to clients of about EUR 241.4 million that had not been audited in earlier years.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003" ], "entity_ids": [ "bbte", "crowe-dnw" ] }, { "id": "c-ast-audit-2022", "kind": "fact", "text": "Assertum Audit OÜ, through sworn auditor Sergei Tšistjakov, gave a qualified opinion dated 12 January 2024 on the 2022 consolidated statements of BB Trade Estonia OÜ and its subsidiaries. Because the previous auditor had disclaimed an opinion on 2021, it gave no assurance on opening balances and comparatives, and it reported that crypto-assets of EUR 155,252,930 were partly held by third-party service providers that do not issue confirmations of the assets they hold.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028" ], "entity_ids": [ "bbte", "assertum", "tsistjakov" ] }, { "id": "c-ast-audit-2023", "kind": "fact", "text": "Assertum Audit OÜ (Sergei Tšistjakov) qualified its opinion dated 30 June 2024 on the 2023 consolidated statements: crypto-assets of EUR 172 million (2022: EUR 155 million) had been identified but the auditor could not test that the group had substantive control over them, because they sat in the \"wallet\" of the group's own platform; instead of testing, group management proposed to provide a notarial confirmation of control. The auditor also gave no opinion on EUR 1.8 million of fee revenue it could not test substantively.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-027" ], "entity_ids": [ "bbte", "assertum", "tsistjakov" ] }, { "id": "c-ast-audit-2024", "kind": "fact", "text": "Assertum Audit OÜ (Sergei Tšistjakov) issued an unqualified opinion dated 29 July 2025 on BB Trade Estonia OÜ's 2024 consolidated financial statements, stating that they present fairly in all material respects the group's position at 31 December 2024.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte", "assertum", "tsistjakov" ] }, { "id": "c-ast-auditor-tamm", "kind": "fact", "text": "According to the Estonian e-Business Register, Liina Tamm, who signed the 2020 opinion, has been the sole management board member of Audit Advisory OÜ since 1 December 2008 and holds all of its share capital; the firm's registered address matches the one given in the audit report.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-121", "src-006" ], "entity_ids": [ "tamm", "audit-advisory" ] }, { "id": "c-ast-auditor-mullo", "kind": "fact", "text": "According to the Estonian e-Business Register, Anton Mullo, who signed the 2021 disclaimer, has been a procurator (prokurist) of Crowe DNW OÜ, formerly DNW Audit OÜ, since 8 October 2021.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-120" ], "entity_ids": [ "mullo", "crowe-dnw" ] }, { "id": "c-ast-auditor-tsistjakov", "kind": "fact", "text": "According to the Estonian e-Business Register, Sergei Tšistjakov, who signed the 2022–2024 opinions, has been a management board member of Assertum Audit OÜ since 6 May 2015; the firm was registered on 21 November 2003.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-119" ], "entity_ids": [ "tsistjakov", "assertum" ] }, { "id": "c-ast-terms-2021-2024", "kind": "attributed", "text": "According to a law firm acting for claimants in the bankruptcy, the exchange's terms of service in the Zonda period (2021–2024) let it hold clients' fiat and crypto funds with external operators in its own name but on the client's behalf, while the version of 30 December 2024 for the first time contained the client's consent to zondacrypto using, in its own name, funds and crypto-assets in client accounts without paying interest.", "qualification": "This is the law firm's reading of successive versions of the terms; those versions were not retained in the case.", "response": "BB Trade Estonia's own annual reports from 2021 onward state that, under the client agreement in force, the company had the right to use funds held in client accounts, and report the amounts used.", "outcome": "", "source_ids": [ "src-008", "src-003" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-terms-2025", "kind": "attributed", "text": "The same law firm states that the version of the terms of 19 July 2025 dropped the clause on using client funds on the exchange's own account and added that the exchange does not speculate on prices and is not a market maker, while separate ZND Earn and ZND Farming terms that took effect at the same time allow Earn customers' funds to be used for operations of zondacrypto or its related entities, including secured loans.", "qualification": "Law firm's reading; the July 2025 exchange terms were not retained, but the retained version of 3 October 2025 contains the market-maker statement.", "response": "", "outcome": "", "source_ids": [ "src-008", "src-039" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-terms-2025-10", "kind": "fact", "text": "The exchange's terms of service valid from 3 October 2025 state that zondacrypto itself does not provide payment services: licensed payment operators handle deposits and withdrawals and safekeep clients' fiat, which is held on dedicated accounts with them and remains at the clients' disposal. By accepting the terms the client agrees that zondacrypto may hold the client's fiat and crypto-assets with various external operators in its own name but for the client, without paying interest; the terms also state that zondacrypto does not speculate on prices and is not a market maker.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-039" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-safety-page", "kind": "attributed", "text": "The exchange's \"safety of funds\" page (archived in January 2026) told clients that all crypto-assets were kept in cold wallets not directly connected to the exchange's servers and that \"a bank\" was the guarantor of clients' fiat funds.", "qualification": "This is the operator's marketing statement; the terms of service of October 2025 say that fiat is safekept by payment operators, and the auditors of the 2021–2023 statements could not verify control of large crypto balances.", "response": "", "outcome": "", "source_ids": [ "src-041" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-znd-earn", "kind": "attributed", "text": "The ZND platform's website (archived in January 2026) advertised digital assets \"securely stored offline\" and an Earn service paying weekly rewards on 34 crypto-assets, tokens and stablecoins at up to 23% a year.", "qualification": "Marketing statement of the platform; according to a law firm acting for claimants, the ZND Earn terms allowed Earn customers' funds to be used for operations of zondacrypto or related entities.", "response": "", "outcome": "", "source_ids": [ "src-114" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-bitgo-plan", "kind": "fact", "text": "The 2022 annual report lists a migration to BitGo V2 among the IT department's plans for 2024.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028" ], "entity_ids": [ "bbte", "bitgo" ] }, { "id": "c-ast-reserves-2020", "kind": "attributed", "text": "A law firm acting for claimants describes an 80-page statement of BB Trade Estonia OÜ dated 18 June 2021 and signed by Sylwester Suszek as chairman of the management board, certifying the exchange's wallets at 31 December 2020: 4,513.93 BTC in the cold wallet and 308.48 BTC in the hot wallet, and 51,646.73 ETH in the cold ether wallet; for bitcoin the source was the exchange's internal \"Funds Monitor\" system.", "qualification": "The statement itself was not retained; the law firm notes that it gives no bitcoin address, so it cannot be matched to the 4,503 BTC address cited in 2026.", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte", "suszek" ] }, { "id": "c-ast-cold-wallet-2026", "kind": "attributed", "text": "On 16 April 2026 the company, in a statement attributed to Przemysław Kral, identified a bitcoin address holding 4,503 BTC as its cold wallet and said the keys had been held by Sylwester Suszek, who according to the law firm has been missing since 2022. A law firm acting for claimants says the address is a publicly known wallet dormant since March 2016 with no outgoing transactions, and that the company never provided auditors or the public with a signed message or test transaction proving control.", "qualification": "The company's account and the law firm's reading of public blockchain data are both unverified in the retained record; the address is not published here.", "response": "", "outcome": "In the bankruptcy, according to the same law firm citing the trustee's report, the trustee could confirm only about EUR 167,000 of cash on accounts abroad, and the chief executive maintains that there is no key to the address, which accounted for 77% of the assets in the 2024 statements.", "source_ids": [ "src-008", "src-083", "src-075" ], "entity_ids": [ "bbte", "kral", "suszek" ] }, { "id": "c-ast-fireblocks-2024", "kind": "attributed", "text": "According to a law firm acting for claimants, a Fireblocks export dated 31 December 2024 and filed in the bankruptcy proceedings before Harju County Court lists 685,738 wallets in 227,496 vaults, including a cold vault with 4,796 ETH, but only 0.000012 BTC; bitcoin deposits were handled by a second custodian, BitGo, which held 59.9 BTC on 1 January 2025, while the 4,503 BTC that balanced the accounts sat on a 2016 address outside any vault.", "qualification": "The law firm's reading of the export; the export itself was not retained in the case.", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte", "fireblocks", "bitgo" ] }, { "id": "c-ast-vault-creation", "kind": "attributed", "text": "The same law firm counts client vaults in the Fireblocks export by creation date: 14,846 from 25 March to the end of 2021, 34,901 in 2022, 78,273 in 2023 and 99,463 in 2024, so that 20,230 were created before the end of March 2022 and 207,253 afterwards.", "qualification": "The law firm links the timing to its view that the exchange's own reconciliations showed only partial coverage of client liabilities after March 2022; the export and reconciliations were not retained.", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte", "fireblocks" ] }, { "id": "c-ast-eth-cold-vault", "kind": "attributed", "text": "According to the same law firm, the Fireblocks export ties the exchange's ether cold vault, hot wallet and network-fee wallet to addresses that a public block explorer labels \"Zonda\"; by 15 September 2026 the cold-vault address held 0.4999 ETH and illiquid tokens worth about USD 236,000, and nothing remained of the 4,796 ETH and 1.5 million USDC held at the balance-sheet date.", "qualification": "Law firm's reading of public blockchain data; addresses and transaction identifiers are not published here.", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-wallet-outflows-2026", "kind": "attributed", "text": "The law firm further states that tokens left the cold-vault address throughout the first quarter of 2026, the last movement on 13 April 2026, three days before the cold-wallet statement, and that on 19 April 2026, after client payouts had stopped, about 1.39 ETH left the exchange's hot wallet, including a transfer to a deposit address of the Binance exchange.", "qualification": "Law firm's reading of public blockchain data; not verified in the retained record.", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte" ] }, { "id": "c-ast-hot-wallet-forensics", "kind": "attributed", "text": "Swiss crypto-industry press reported in May 2026, citing a Zug blockchain-forensics firm, that bitcoin in the Zondacrypto exchange's hot wallets fell from 55.7 BTC in August 2024 to 0.07 BTC on 1 April 2026, and that between December 2025 and April 2026 there were 511 transactions to wallets at the Kraken exchange totalling about USD 21 million, including USD 4.59 million in bitcoin.", "qualification": "Forensic findings reported by the press; the underlying analysis was not retained. The same article names BB Trade Estonia OÜ as the exchange's operating company.", "response": "", "outcome": "", "source_ids": [ "src-096" ], "entity_ids": [ "bbte", "payward" ] }, { "id": "c-pay-2020-fenige", "kind": "fact", "text": "According to its annual report for 2020, BB Trade Estonia concluded an agreement with Fenige Sp. z o.o. in 2020 to enable card payments, which it says widened the deposit and withdrawal options available to users.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006" ], "entity_ids": [ "bbte", "fenige" ] }, { "id": "c-pay-2020-poczta", "kind": "fact", "text": "The same 2020 report describes express deposits of Polish zloty to the BitBay.net platform through Polish Post (Poczta Polska), at a fee of 2% and at least PLN 5, and cash withdrawals of up to PLN 15,000 at a time at Polish Post offices; it states that the withdrawal service is provided by the payment service provider Payment Technology.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006" ], "entity_ids": [ "bbte", "poczta-polska", "payment-technology" ] }, { "id": "c-pay-gateway", "kind": "fact", "text": "BB Trade Estonia's annual reports state that since December 2020 it has offered a payment gateway for instant cryptocurrency transactions, first as BitBayPay and later as 'Pay with zondacrypto' (formerly BitBayPay.com and zondacryptopay.com), charging a commission on each transaction.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028", "src-006" ], "entity_ids": [ "bbte" ] }, { "id": "c-pay-paybyzen", "kind": "fact", "text": "BB Trade Estonia's annual report for 2021 lists PayByZEN among the functions launched in addition to its existing services: instant deposits and withdrawals in PLN, USD and EUR between a client's account on zondaglobal.com and the client's account with ZEN.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003" ], "entity_ids": [ "bbte", "zen" ] }, { "id": "c-pay-operator-fees", "kind": "fact", "text": "The 2022 annual report states that BB Trade Estonia also receives a monthly intermediary fee in fiat currency from payment operators, paid out after deduction of the operators' costs; the report does not name the operators.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028" ], "entity_ids": [ "bbte" ] }, { "id": "c-pay-costs-2022-2023", "kind": "fact", "text": "In its 2023 annual report BB Trade Estonia recorded fees of payment intermediaries of EUR 97,339 for 2023 (EUR 413,057 for 2022), transaction-related costs including bank fees of EUR 205,080 (EUR 242,986) and licence fees and platform use of EUR 1,122,170 (EUR 2,498,010); the providers are not named.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-027" ], "entity_ids": [ "bbte" ] }, { "id": "c-pay-revenue-2024", "kind": "fact", "text": "The 2024 annual report gives revenue of EUR 6,076,753 (2023: EUR 4,679,521), of which EUR 4,694,517 came from Poland. By service it lists Trading EUR 4,980,510 (2023: 2,354,855), TryPay EUR 325,293 (2023: none), Pay EUR 264,185 (1,854,554), Pay-ZEN EUR 175,057 (none), Fenige EUR 108,084 (97,245), ZEN none (161,243) and Fiat exchange EUR 49,009 (151,920).", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte", "trypay", "zen", "fenige" ] }, { "id": "c-pay-pt-cooperation", "kind": "fact", "text": "In current report 21/2022 of 29 April 2022, Femion Technology S.A. stated that BB Trade Estonia OÜ operated the ZONDA virtual-currency exchange at zondaglobal.com and that Payment Technology sp. z o.o. had until then provided it with payment services in the form of money remittance under a cooperation agreement.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-032" ], "entity_ids": [ "femion", "bbte", "payment-technology" ] }, { "id": "c-pay-trypay-2022", "kind": "fact", "text": "The same day Femion's subsidiary TryPay S.A., a Polish national payment institution, signed with Payment Technology and BB Trade Estonia an assignment of all rights and obligations under the Payment Technology–BB Trade Estonia cooperation agreement, to take effect when Femion concluded the final agreement to buy Payment Technology's shares, and signed directly with BB Trade Estonia an open-ended partnership agreement on developing and providing payment services to it in Poland and other countries where it operates.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-032" ], "entity_ids": [ "trypay", "femion", "payment-technology", "bbte" ] }, { "id": "c-pay-pt-volume", "kind": "attributed", "text": "A press report summarising Femion's stock-exchange reports said that in June 2022 Femion announced completion of its purchase of Payment Technology, with the BB Trade Estonia agreement passing to TryPay, and that Payment Technology had processed about PLN 275 million a month over the preceding six months against about PLN 14 million at TryPay. A law firm acting for claimants describes Payment Technology as the intermediary that processed about USD 70 million a month between Polish bank accounts and BB Trade Estonia until April 2022.", "qualification": "Both are secondary accounts: Femion's June 2022 report is not in the retained record, the press figure covers all of Payment Technology's processing rather than BB Trade Estonia alone, and the law firm's figure is an approximation.", "response": "", "outcome": "Payment Technology was later declared bankrupt and fined PLN 200,000 by KNF for anti-money-laundering breaches; on 20 April 2026 TryPay terminated its agreement with BB Trade Estonia with immediate effect, and on 30 April 2026 TryPay's board resolved that it was insolvent.", "source_ids": [ "src-029", "src-088", "src-064", "src-076", "src-031", "src-090" ], "entity_ids": [ "femion", "payment-technology", "trypay", "bbte" ] }, { "id": "c-pay-pt-bankruptcy", "kind": "fact", "text": "Payment Technology was later declared bankrupt. Femion's management report for 2025 states that in 2024 the court declared Payment Technology sp. z o.o. bankrupt; a law firm acting for claimants gives the date as 3 October 2024 (file GD1G/GU/1487/2023), while a machine-generated summary of Femion's filings on a registry-data aggregator gives 4 October 2024 and says Femion wrote down its shares in the company.", "qualification": "The bankruptcy decision itself is not in the retained record; the two secondary accounts differ by one day on its date.", "response": "", "outcome": "", "source_ids": [ "src-064" ], "entity_ids": [ "payment-technology", "femion" ], "adverse_subject_ids": [ "payment-technology" ] }, { "id": "c-pay-pt-knf-fine", "kind": "fact", "text": "On 13 June 2025 the Polish Ministry of Finance published the final decision of the Polish Financial Supervision Authority (KNF) imposing an administrative fine of PLN 200,000 on Payment Technology sp. z o.o. w upadłości (in bankruptcy), Gdynia, for breaches of the Anti-Money Laundering Act: failing to identify and assess its institutional money-laundering risk, to identify and verify customers and beneficial owners, to monitor business relationships and analyse transactions, to document beneficial-owner measures and to train staff. The company did not appeal to a court.", "qualification": "The publication does not state the period of the breaches or link them to particular customers, including BB Trade Estonia.", "response": "", "outcome": "", "source_ids": [ "src-076" ], "entity_ids": [ "payment-technology" ], "adverse_subject_ids": [ "payment-technology" ] }, { "id": "c-pay-trypay-ownership", "kind": "fact", "text": "Polish National Court Register (KRS) data reproduced by a registry-data aggregator list Femion Technology S.A. as TryPay S.A.'s sole shareholder since 27 July 2022 and Przemysław Kral as TryPay's beneficial owner.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-033" ], "entity_ids": [ "trypay", "femion", "kral" ] }, { "id": "c-pay-femion-kral", "kind": "fact", "text": "Femion's management report for 2025 shows Przemysław Kral as its largest shareholder at 31 December 2025, with 14,109,812 shares or 49.8674% of share capital; the next largest holder had 11.8303%. The report describes TryPay S.A., a national payment institution (KNF register IP25/2014), as the operating company of the Femion group. KRS data reproduced by an aggregator also list Kral as Femion's beneficial owner, as a shareholder.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-064" ], "entity_ids": [ "kral", "femion", "trypay" ] }, { "id": "c-pay-kral-loan-femion", "kind": "fact", "text": "Among events after the 2025 balance-sheet date, Femion's management report lists a loan of EUR 60,000 from Przemysław Kral, increased by annex to EUR 120,000, Femion's subscription for 500,000 series M shares of TryPay at PLN 0.50 each, and an annex extending repayment of a loan from TryPay to 31 December 2027. At 31 December 2025 Femion owed its subsidiary PLN 2,266.8 thousand under a loan.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-064" ], "entity_ids": [ "kral", "femion", "trypay" ] }, { "id": "c-pay-trypay-uknf", "kind": "attributed", "text": "A machine-generated summary of TryPay's filings on a registry-data aggregator states that the Polish financial supervisor (UKNF) inspected TryPay S.A. in 2024 on anti-money-laundering and sanctions compliance.", "qualification": "The aggregator labels the text as generated with AI from source documents; the underlying financial-statement document and any supervisory record are not in the retained record.", "response": "According to the same summary, TryPay implemented all post-inspection recommendations by February 2025, commissioned an audit in September 2025 and faced no pending administrative proceedings.", "outcome": "", "source_ids": [ "src-033" ], "entity_ids": [ "trypay" ] }, { "id": "c-pay-operator-list", "kind": "fact", "text": "The list of payment service operators available on zondacrypto, published with the exchange's terms of service (archived copy of 8 April 2026), named TryPay S.A. (Wrocław; KNF national payment institution licence IP25/2014, without safekeeping of funds), ZEN UAB (Lithuania; Bank of Lithuania electronic-money licence LB000457), Clear Junction Limited (United Kingdom; FCA licence 900684), Krajowy Integrator Płatności S.A. (Poznań; KNF IP27/2014) and Fenige S.A. (Warsaw; KNF IP42/2017).", "qualification": "This is the exchange's own document; the licence numbers are as stated in it and were not checked against the regulators' registers in the retained record.", "response": "", "outcome": "", "source_ids": [ "src-040" ], "entity_ids": [ "bbte", "trypay", "zen", "clear-junction", "kip", "fenige" ] }, { "id": "c-pay-trypay-termination", "kind": "fact", "text": "In current report 3/2026 of 20 April 2026, issued as inside information under Article 17(1) of the Market Abuse Regulation, Femion Technology announced that its subsidiary TryPay S.A. had terminated with immediate effect the agreement for payment services to \"BB Trade Estonia EU\" following a negative result of its risk assessment of further cooperation, and that it expected the termination to have a negative effect on the financial results of Femion and its group.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-031" ], "entity_ids": [ "femion", "trypay", "bbte" ] }, { "id": "c-pay-trypay-insolvency", "kind": "fact", "text": "On 30 April 2026 Femion reported (current report 8/2026) that TryPay's management board had resolved that TryPay was insolvent and would file for bankruptcy, citing mainly the loss of a key counterparty, which sharply reduced its revenue, and failed talks on external financing; TryPay also applied to KNF to extinguish its authorisation as a national payment institution.", "qualification": "The report does not name the key counterparty.", "response": "", "outcome": "", "source_ids": [ "src-090" ], "entity_ids": [ "femion", "trypay" ], "adverse_subject_ids": [ "trypay" ] }, { "id": "c-pay-femion-insolvency", "kind": "fact", "text": "The same day Femion's management board resolved that Femion itself was insolvent and would file for bankruptcy immediately (current report 9/2026), citing the deteriorating finances of TryPay, its key asset, and its inability to obtain external financing.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-097" ], "entity_ids": [ "femion", "trypay" ], "adverse_subject_ids": [ "femion" ] }, { "id": "c-pay-seba-stake", "kind": "fact", "text": "BB Trade Estonia's annual reports show that it acquired B shares of SEBA Bank AG for EUR 2,317,819 in 2020, carried at cost at the end of 2020 and 2021; the 2021 report states that they were converted in 2021 into equity tokens and that the holding was about 1.01%. In 2022 it bought more for EUR 952,199 and recorded a revaluation gain of EUR 214,698, carrying the stake at a fair value of EUR 3,484,716 at 31 December 2022. The value was EUR 3,827,891 at the end of 2023 and, after a revaluation loss of EUR 42,804, EUR 3,785,087 at the end of 2024; the 2024 report gives these figures without naming the issuer.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003", "src-028", "src-027", "src-013" ], "entity_ids": [ "bbte", "amina" ] }, { "id": "c-pay-seba-loans", "kind": "fact", "text": "The 2023 annual report lists short-term loans from SEBA Bank AG of EUR 5,000,000 at 31 December 2022 (due 2023) and EUR 10,000,000 at 31 December 2023 (due 2024), both in euros at 4%; the 2024 balance sheet shows no loan liabilities at 31 December 2024.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-027", "src-013" ], "entity_ids": [ "bbte", "amina" ] }, { "id": "c-pay-amina-identity", "kind": "fact", "text": "AMINA Bank AG of Zug (UID CHE-434.446.643) was entered in the commercial register on 24 April 2018; Swiss commercial-register data reproduced by an aggregator list SEBA Crypto AG and SEBA Bank AG among its past company names.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-070" ], "entity_ids": [ "amina" ] }, { "id": "c-pay-amina-sale", "kind": "attributed", "text": "A law firm acting for claimants, citing a share purchase agreement dated 21 January 2025, states that BB Trade Estonia agreed to sell 781,250 registered participation certificates of AMINA Bank AG (par value CHF 1; about 1.014% of the bank's capital) to LL (BVI) Investment Limited for CHF 3.40 each, CHF 2,656,250 in total, about a quarter below the EUR 3,785,087 at which the position stood on 31 December 2024. According to the firm, closing required consents from the bank's board, other holders and the regulator, either party could withdraw if these were not obtained by 30 April 2025, the buyer signed on 22 January 2025 and disputes go to the Cantonal Court of Zug.", "qualification": "Account of a law firm acting for claimants in the bankruptcy, based on a copy of the agreement it obtained; the agreement is not in the retained record, and no record shows whether the sale closed or the price was paid.", "response": "", "outcome": "", "source_ids": [ "src-010" ], "entity_ids": [ "bbte", "amina", "ll-bvi" ] }, { "id": "c-pay-amina-price-account", "kind": "attributed", "text": "The same firm states that the price was to be paid to BB Trade Estonia's account at Sygnum Bank AG in Zurich, and that in the exchange's ledgers the position fell from about EUR 3.79 million on 1 January 2025 to one cent by 22 April 2026, with no cash received and no loss recognised. It describes SEBA (now AMINA) as the bank that kept BB Trade Estonia's accounts and lent to it.", "qualification": "Law-firm reading of the ledgers and the agreement; no statement from Sygnum and no extract from AMINA's register is in the retained record, so whether the sale closed and where the price went remain open.", "response": "", "outcome": "", "source_ids": [ "src-010" ], "entity_ids": [ "bbte", "sygnum", "amina" ] }, { "id": "c-pay-ll-bvi-lei", "kind": "fact", "text": "The LEI record 9845005WDBECL4CE6726 identifies LL (BVI) Investment Limited as an active British Virgin Islands company limited by shares (Registry of Corporate Affairs number 2088640), created on 12 January 2022, with its legal address at Vistra Corporate Services Centre, Road Town, Tortola, and its headquarters at 100 Queen's Road Central, Hong Kong; its direct and ultimate parents are reported as not provided, with the reason NO_KNOWN_PERSON.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-068" ], "entity_ids": [ "ll-bvi" ] }, { "id": "c-pay-buhler-seba", "kind": "attributed", "text": "The claimants' law firm states that Guido Bühler, later a member of the exchange's supervisory board, was SEBA Bank's first chief executive, having come from UBS Wealth Management, and notes that in January 2025, when the exchange sold that bank's certificates at a quarter below book value, a co-founder of the bank sat on its supervisory board.", "qualification": "The firm itself writes that the certificates were acquired before 2021 and the loan taken in 2022, that Bühler joined the exchange about a year and a half after leaving the bank, that no document suggests he brokered either, and that it does not know whether the board knew of the sale. BB Trade Estonia's 2024 annual report lists Bühler as a management-board member at 31 December 2024 and moves him to the supervisory board only in March 2025.", "response": "", "outcome": "", "source_ids": [ "src-010", "src-013" ], "entity_ids": [ "buhler", "amina", "bbte" ] }, { "id": "c-pay-incore", "kind": "fact", "text": "A press release issued for the zondacrypto brand together with Incore Bank on 14 January 2025 announced that the brand was opening an office in Zug for its Swiss entity BB Trade Switzerland AG and entering a collaboration with the bank; Swiss financial press reported the partnership the same day, quoting Przemysław Kral as chief executive of Zondacrypto.", "qualification": "Announcement by the partners; no account or service agreement is in the retained record.", "response": "", "outcome": "", "source_ids": [ "src-113", "src-073" ], "entity_ids": [ "bb-switzerland", "incore", "kral" ] }, { "id": "c-pay-accounts-list", "kind": "attributed", "text": "According to a law firm acting for claimants, which says it handed the trustee a list of account numbers, contract dates and transaction identifiers on 17 September 2026, BB Trade Estonia held accounts at AMINA Bank and Sygnum in Switzerland, ZEN.COM in Lithuania, Clear Junction in London and Fenige, TryPay and Tpay in Poland, kept the keys to 685,000 wallets in a Fireblocks workspace and used wallets at BitGo, while its subsidiaries had accounts at the Kraken and Gate exchanges.", "qualification": "List compiled by claimants' counsel; no bank, payment-institution or custodian confirmation is in the retained record.", "response": "", "outcome": "", "source_ids": [ "src-075" ], "entity_ids": [ "bbte", "amina", "sygnum", "zen", "clear-junction", "fenige", "trypay", "kip", "fireblocks", "bitgo", "payward" ] }, { "id": "c-pay-zen-transfers", "kind": "attributed", "text": "The same firm, citing BB Trade Estonia's general ledger, states that monthly payments to Orion Software under its loan and investment agreements, some booked as \"Zen Regular outgoing\", ran through ZEN.com until 31 March 2026, and that ZEN.COM carried the monthly transfers to Orion and ZND Ventures.", "qualification": "The ledger is not in the retained record; the account is the firm's reading of it.", "response": "", "outcome": "", "source_ids": [ "src-083", "src-075" ], "entity_ids": [ "bbte", "zen", "orion", "znd-ventures" ] }, { "id": "c-pay-kraken", "kind": "attributed", "text": "A law firm acting for claimants, citing criminal complaints filed with the National Prosecutor's Office in Katowice and press coverage, states that shortly before the withdrawal crisis the company transferred crypto-assets worth more than PLN 76 million to the Kraken exchange, operated by Payward Ltd.", "qualification": "Allegation reported by claimants' counsel from complaints and press accounts; no transfer records are in the retained record.", "response": "According to the same firm, the company explained the transfer to customers as market-making activity; on 14 April 2026 Kral wrote that investing customer funds was not to be confused with liquidity management (market making).", "outcome": "", "source_ids": [ "src-008" ], "entity_ids": [ "bbte", "payward", "kral" ] }, { "id": "c-crisis-register-notices", "kind": "fact", "text": "The Estonian e-Business Register lists notices published for BB Trade Estonia in the official gazette Ametlikud Teadaanded: a notice of the declaration of bankruptcy (27 August 2026, notice 2641740), a notice making a disposal ban known (28 July 2026) and notices of service of procedural documents in labour dispute committee proceedings (24 July 2026). A business-information service's list of the same official notices also shows notices of service of labour dispute committee summonses dated 22 June 2026.", "qualification": "The notices' content is not in the retained record; the listings show that labour dispute committee proceedings involved the company but not their parties, number or subject.", "response": "", "outcome": "", "source_ids": [ "src-001", "src-067" ], "entity_ids": [ "bbte" ] }, { "id": "c-crisis-tax-filings", "kind": "fact", "text": "As of 19 October 2026 the register showed a tax debt of EUR 1,997.12 (VAT EUR 1,112.12, a penalty payment of EUR 800 and interest of EUR 85) dating from 20 April 2026; VAT returns due from 20 May 2026 and income and social tax returns due from 11 May 2026 had not been filed; the 2025 annual report, due by 30 June 2026, had not been submitted; and the company reported no taxable turnover and no employees for the third quarter of 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-001" ], "entity_ids": [ "bbte" ] }, { "id": "c-crisis-court-ruling", "kind": "fact", "text": "Harju County Court (Tallinn courthouse) issued a bankruptcy ruling (pankrotimäärus) on 26 August 2026 in civil case 2-26-14436/10, a bankruptcy petition against a legal person, after proceedings that began on 2 July 2026 (judge Priit Lember; ECLI:EE:HMK:2026:2.26.14436.14025). A business-information service lists the ruling on BB Trade Estonia's page with an enforcement date of 17 September 2026.", "qualification": "Only the ruling's metadata is in the retained record, not its text.", "response": "", "outcome": "", "source_ids": [ "src-024" ], "entity_ids": [ "bbte" ], "adverse_subject_ids": [ "bbte" ] }, { "id": "c-crisis-disposal-ban", "kind": "attributed", "text": "According to a Polish news report, on 27 July 2026 the Harju County Court prohibited the company from disposing of any of its assets without the consent of an interim administrator, Margus Lentsius, the same lawyer who a month later became trustee in bankruptcy; the register shows the notice of the disposal ban published on 28 July 2026.", "qualification": "The court's interim order is not in the retained record; its date and scope come from the news report.", "response": "", "outcome": "", "source_ids": [ "src-108" ], "entity_ids": [ "bbte", "lentsius" ] }, { "id": "c-crisis-bankruptcy-notice", "kind": "fact", "text": "The declaration of bankruptcy was published in Ametlikud Teadaanded on 27 August 2026 under number 2641740. Polish press reported that Margus Lentsius of Advokaadibüroo Lentsius & CASUS became trustee, that the court set the first creditors' meeting for 17 September 2026, and that creditors had two months from publication, until 27 October 2026, to file their claims with the trustee.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-108", "src-001" ], "entity_ids": [ "bbte", "lentsius" ], "adverse_subject_ids": [ "bbte" ] }, { "id": "c-crisis-trustee", "kind": "fact", "text": "The e-Business Register lists Margus Lentsius as BB Trade Estonia's trustee in bankruptcy (pankrotihaldur) from 28 August 2026 and states that the trustee administers the company's bankruptcy estate. The register of the Estonian Chamber of Bailiffs and Bankruptcy Trustees lists Lentsius, of Advokaadibüroo Lentsius & CASUS OÜ, as entitled to act as a trustee in bankruptcy since 15 October 2025.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-019", "src-001" ], "entity_ids": [ "lentsius", "bbte" ] }, { "id": "c-crisis-first-meeting", "kind": "attributed", "text": "Polish press reported that the first meeting of creditors, held on 17 September 2026 at Harju County Court in Tallinn, kept the court-appointed trustee Margus Lentsius and unanimously elected a three-member creditors' committee: Damian Przybyłowski of Krajowe Centrum Obsługi Długów, Marek Keiman of the Estonian Magnusson law office and Robert Nogacki, a Warsaw legal adviser nominated by an Estonian advocate.", "qualification": "Press account; the minutes of the meeting are not in the retained record. The register lists the same three committee members from 1 October 2026.", "response": "", "outcome": "", "source_ids": [ "src-089" ], "entity_ids": [ "bbte", "lentsius", "przybylowski", "keiman", "nogacki", "kcod", "magnusson" ] }, { "id": "c-crisis-committee-register", "kind": "fact", "text": "Register data reproduced by Estonian business-information services list Damian Przybyłowski, Marek Keiman and Robert Nogacki as members of BB Trade Estonia's bankruptcy committee (pankrotitoimkond) from 1 October 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-024", "src-042" ], "entity_ids": [ "bbte", "przybylowski", "keiman", "nogacki" ] }, { "id": "c-crisis-auditor-register", "kind": "fact", "text": "Estonian register data reproduced by a business-information service list Assertum Audit OÜ as BB Trade Estonia's auditor from 20 June 2023.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-024" ], "entity_ids": [ "bbte", "assertum" ] }, { "id": "c-crisis-keiman", "kind": "fact", "text": "The Estonian Bar Association lists Marek Keiman as a member since 2 October 2020 and a sworn advocate (vandeadvokaat) since 10 February 2023 at Advokaadibüroo Magnusson, a partner (osanik) of Advokaadibüroo Magnusson OÜ, and a member of the bankruptcy committees of other Estonian companies, including CoinLoan OÜ, Envestio SI OÜ and Kuetzal OÜ. An Estonian business-information service shows him holding 25% of Advokaadibüroo Magnusson OÜ from 12 August 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-078", "src-042" ], "entity_ids": [ "keiman", "magnusson" ] }, { "id": "c-crisis-petitioner", "kind": "attributed", "text": "Polish press reported that the Magnusson law office, to which committee member Marek Keiman belongs, had represented a client from Vienna on whose petition the court in Tallinn declared the exchange bankrupt.", "qualification": "Press account; the bankruptcy petition and the ruling are not in the retained record, and the client is not named.", "response": "", "outcome": "", "source_ids": [ "src-089" ], "entity_ids": [ "bbte", "magnusson", "keiman" ] }, { "id": "c-crisis-estate-figures", "kind": "attributed", "text": "Figures reported around the first creditors' meeting differ. A Polish news report said that trustee Margus Lentsius had EUR 167,000 to distribute against the exchange's liabilities of EUR 432 million and that claims filed by 17 September amounted to EUR 20–30 million. A law firm acting for a group of claimants gave the same EUR 167,000 and EUR 432 million figures, citing an Estonian news report and the interim trustee's report, and said just under 2,000 creditors had filed claims. In late August another Polish news report quoted the trustee as saying total claims could exceed EUR 700 million.", "qualification": "The figures measure different things: book liabilities, claims filed by a given date and the trustee's projection of total claims. They come from press and claimants' counsel; the trustee's reports are not in the retained record.", "response": "", "outcome": "", "source_ids": [ "src-089", "src-075", "src-108", "src-043" ], "entity_ids": [ "bbte", "lentsius" ] }, { "id": "c-crisis-books", "kind": "attributed", "text": "The same law firm, citing the trustee's findings, states that on the day of the freeze the operator's balance sheet showed EUR 476 million of assets (EUR 347 million in cryptocurrency and EUR 129 million in loans and shareholdings), of which the trustee could confirm EUR 167,000 in cash on accounts abroad, the rest being book entries without source documents prepared from aggregate data that management passed to the bookkeeper; that liabilities to customers of EUR 429 million were booked on several aggregate accounts without a breakdown by customer; that 77% of the assets in the 2024 financial statements was a single bitcoin address holding 4,503 coins, to which according to the chief executive, Przemysław Kral, there is no key, although in a notarised statement in June 2025 he had said access existed; and that the company had thirteen employees and its bookkeeping ended on 22 April 2026.", "qualification": "Account of claimants' counsel; the trustee's report and the June 2025 statement are not in the retained record.", "response": "", "outcome": "", "source_ids": [ "src-075", "src-108" ], "entity_ids": [ "bbte", "kral" ] }, { "id": "c-crisis-claims-count", "kind": "attributed", "text": "An Estonian business daily reported on 17 September 2026 that more than 2,000 people had come forward in the bankruptcy, showing advocate Marek Keiman, who represents claims of EUR 2 million, with Polish lawyers representing claims of EUR 2.3 million.", "qualification": "Headline and photo caption only; the article text is not in the retained record.", "response": "", "outcome": "", "source_ids": [ "src-122" ], "entity_ids": [ "bbte", "keiman" ] }, { "id": "c-crisis-kcod", "kind": "attributed", "text": "Krajowe Centrum Obsługi Długów (KCOD), a Polish receivables-management firm led by licensed restructuring adviser Damian Przybyłowski, invites clients of the exchange to file claims in the Estonian bankruptcy of the Zonda operator; a Polish news report notes that KCOD represents affected clients for a fee and so has a commercial interest. KCOD's website, citing a Polish news report, says Przybyłowski represented more than 230 people with claims exceeding PLN 25 million in August 2026, and Przybyłowski told the press that KCOD's own estimate of the potential asset pool was PLN 550–600 million.", "qualification": "Self-description and estimates of a claimants' representative; the news report itself describes the PLN 550–600 million figure as the representative's estimate, not assets found or secured by the trustee.", "response": "", "outcome": "", "source_ids": [ "src-043", "src-108" ], "entity_ids": [ "kcod", "przybylowski" ] }, { "id": "c-crisis-segregation", "kind": "attributed", "text": "KCOD also files, for each client, a separate application to exclude crypto-assets from BB Trade Estonia's bankruptcy estate and return them in kind under the Estonian rules on third-party property. A Polish news report notes that the outcome depends on whether specific crypto-assets can be treated as a client's property, identified and attributed to that client; Przybyłowski argues that cryptocurrency on a user's account was the client's asset held by the operator, not the exchange's property.", "qualification": "Legal position of a claimants' representative; no court or trustee decision on segregation is in the retained record.", "response": "", "outcome": "", "source_ids": [ "src-108" ], "entity_ids": [ "kcod", "przybylowski", "bbte" ] }, { "id": "c-crisis-assets-secured", "kind": "attributed", "text": "Roman Giertych, who said on 25 August 2026 that he had been Przemysław Kral's defence counsel since May, stated that his client had placed \"huge assets\" at the prosecutors' disposal, in his view enough to satisfy all injured persons who had reported to the prosecutors; two days later Justice Minister Waldemar Żurek said prosecutors had already secured more than PLN 100 million towards future compensation.", "qualification": "A Polish news report notes that it is not known whether the two statements concern the same assets, what was secured, to whom it belongs or how it relates to BB Trade Estonia's bankruptcy in Estonia; the National Prosecutor's Office told the newspaper it could give no details because of investigative secrecy.", "response": "", "outcome": "", "source_ids": [ "src-108" ], "entity_ids": [ "kral", "bbte" ] }, { "id": "c-crisis-debt-listing", "kind": "attributed", "text": "A listing posted on a Polish debt-collection agency's website on 2 April 2026 (updated 8 April) advertised a debt of PLN 173,000 owed by \"ZONDACRYPTO\", identified as BB Trade Estonia OÜ (registration number 14814864) and BB Trade IT in Milan (registration number PSV48).", "qualification": "The listing names no creditor and cites no judgment; it records an unverified claim by an unnamed party.", "response": "", "outcome": "", "source_ids": [ "src-115" ], "entity_ids": [ "bbte", "bb-trade-it" ] }, { "id": "c-crisis-sponsorship", "kind": "attributed", "text": "A law firm acting for claimants, citing the contracts, states that zondacrypto's advertising and promotion agreement with Juventus F.C. S.p.A. of 12 January 2024, signed by Kral and running to 30 June 2026, provided fees of EUR 500,000 for 2023/24 and EUR 1,100,000 for each of 2024/25 and 2025/26 plus bonuses; that an annex of 25 January 2024 added EUR 1,200,000 for additional branding in the rest of 2023/24; and that a 6 June 2023 agreement made zondacrypto a strategic sponsor of RKS Raków Częstochowa for EUR 320,000 (2023/24) and EUR 352,000 (2024/25), about EUR 4.6 million of marketing commitments in all.", "qualification": "The contracts are not in the retained record, and the retained passage names the brand rather than the contracting legal entity.", "response": "", "outcome": "In April 2026 Raków Częstochowa's spokesman said the club had sent a statement starting the termination of its sponsorship agreement with Zondacrypto, which had two more years to run, citing what was happening around the exchange.", "source_ids": [ "src-083", "src-025" ], "entity_ids": [ "juventus", "kral" ] }, { "id": "c-crisis-fc-flora", "kind": "attributed", "text": "Among news items listed on BB Trade Estonia OÜ's page of an Estonian business-information service, an Estonian business daily wrote on 22 April 2026 that Tallinn-headquartered Zondacrypto was the main sponsor of FC Flora under a contract due to run until the end of 2028; the article's headline said that a crypto business with an Estonian licence faced a criminal case and that 30,000 clients had lost more than EUR 80 million.", "qualification": "Caption and headline only; the article text, the sponsorship contract and the basis of the loss figure are not in the retained record.", "response": "", "outcome": "", "source_ids": [ "src-122" ], "entity_ids": [ "bbte", "fc-flora" ] }, { "id": "c-crisis-ee-criminal", "kind": "attributed", "text": "Estonian business-press headlines listed for the company reported on 11 May 2026 that victims were trying to have the firm declared bankrupt in Estonia and that the Prosecutor's Office was considering opening criminal proceedings.", "qualification": "Headlines and captions only; no act or statement of the Estonian Prosecutor's Office is in the retained record.", "response": "", "outcome": "On 19 May 2026 the same business daily reported that criminal proceedings had been opened in Estonia and that prosecutors were investigating possible money laundering connected with the platform.", "source_ids": [ "src-122" ], "entity_ids": [ "bbte" ] }, { "id": "c-rpt-results-2021", "kind": "fact", "text": "According to its 2021 annual report, BB Trade Estonia OÜ had sales revenue of 23,819,262 EUR in 2021 (2020: 9,117,007 EUR as corrected in that report; the first annual report had shown 8,837,007 EUR), of which 17,937,221 EUR came from Poland (2020: 4,451,443 EUR); in 2020 a further 2,824,086 EUR of revenue was attributed to Malta. Fees paid to payment intermediaries were 1,444,421 EUR in 2021 (2020: 611,358 EUR) and licence fees and platform use cost 2,189,404 EUR (2020: 1,300,000 EUR).", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003" ], "entity_ids": [ "bbte" ] }, { "id": "c-rpt-results-2022", "kind": "fact", "text": "BB Trade Estonia's consolidated balance sheet at 31 December 2022 showed cash of 9,959,948 EUR (2021: 33,234,865 EUR), crypto-asset inventories of 155,252,930 EUR (2021: 485,227,763 EUR), total assets of 196,559,328 EUR, a 5,000,000 EUR loan liability, payables and prepayments received of 166,762,446 EUR and equity of 24,796,882 EUR; the consolidated profit for 2022 was 1,142,183 EUR. The parent company's unconsolidated balance sheet, given as an annex to the same report, showed total assets of 195,248,100 EUR, equity of 25,896,838 EUR and a 2022 profit of 1,735,279 EUR; the two profit figures differ because one covers the group and the other the company alone.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028" ], "entity_ids": [ "bbte" ] }, { "id": "c-rpt-results-2023", "kind": "fact", "text": "BB Trade Estonia's consolidated balance sheet at 31 December 2023 showed cash of 13,495,534 EUR, crypto-asset inventories of 309,948,409 EUR, investments in subsidiaries and associates of 4,924,500 EUR, total assets of 375,965,919 EUR, a 10,000,000 EUR loan liability, payables and prepayments received of 339,741,835 EUR and equity of 26,223,954 EUR; the consolidated profit for 2023 was 1,040,294 EUR. Its consolidated cash-flow statement records 4,132,500 EUR paid for associates and 7,572,711 EUR of loans granted in 2023.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-027" ], "entity_ids": [ "bbte" ] }, { "id": "c-rpt-results-2024", "kind": "fact", "text": "BB Trade Estonia's consolidated balance sheet at 31 December 2024 showed cash of 9,726,239 EUR, receivables and prepayments of 121,226,865 EUR, crypto-asset inventories of 594,127,140 EUR, total assets of 768,208,697 EUR, total liabilities of 733,210,694 EUR, no loan liability (2023: 10,000,000 EUR) and equity of 34,998,003 EUR. Consolidated sales revenue was 6,076,753 EUR, other operating income 20,552,305 EUR and the profit for 2024 8,443,567 EUR; the parent company's unconsolidated profit, given in an annex, was 10,601,975 EUR.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte" ] }, { "id": "c-rpt-znd-income-2024", "kind": "fact", "text": "In the 2024 consolidated report, 19,545,016 EUR of the 20,552,305 EUR of other operating income related to the ZND token, which the company issued in 2024: a 4,018,309 EUR gain on the change in the token's value, 13,696,115 EUR booked as a ZND token receivable (tokens that moved under smart contracts into wallets controlled by the company from October 2024), and 522,386 EUR and 1,308,206 EUR from token sales before the token generation event. Liabilities related to the ZND token were 9,861,091 EUR at 31 December 2024.", "qualification": "The report does not compare the result with and without the token items; a law firm acting for claimants in the bankruptcy states that without them the 2024 result would have been a loss.", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte" ] }, { "id": "c-rpt-znd-issue", "kind": "fact", "text": "According to the 2024 annual report, BB Trade Estonia issued the ZND utility token in 2024: at the token generation event on 18 October 2024 a total of 700,000,000 ZND were created, of which up to 183,400,000 had been offered in sale rounds between June and October 2024; 5,600,000 tokens from a launchpad round that could not be completed were burnt, and the presale raised 11,706,800 EUR in total. The report lists trading of ZND on the zondacrypto exchange from 24 October 2024.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte" ] }, { "id": "c-rpt-related-2020", "kind": "fact", "text": "BB Trade Estonia's first annual report, for 30 September 2019 to 31 December 2020, named LuxBay S.A. of Luxembourg as its parent. In that period it bought goods and services for 1,300,000 EUR from, and sold services for 2,824,085 EUR to, members of management and owners holding significant interests and companies under their control; at 31 December 2020 it had receivables of 6,801,077 EUR from and liabilities of 1,300,000 EUR to that group, and loans of 114,760 EUR and 1,175,696 EUR (2–3%, EUR and PLN, due 2030) were outstanding to it.", "qualification": "The report groups these counterparties by category and does not name them.", "response": "", "outcome": "", "source_ids": [ "src-006" ], "entity_ids": [ "bbte", "luxbay" ] }, { "id": "c-rpt-divisio-loan", "kind": "fact", "text": "In 2021 BB Trade Estonia lent 2,700,000 EUR to its new parent company Divisio Holding AG (2%, EUR, due 2041). The 2021 annual report states that the loan was repaid with interest after the balance-sheet date, and the 2022 and 2023 reports show the parent-company receivable at zero at 31 December 2022, the loan having been repaid during 2022.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003", "src-028", "src-027" ], "entity_ids": [ "bbte", "divisio" ] }, { "id": "c-rpt-related-2021", "kind": "fact", "text": "At 31 December 2021, besides the parent-company loan, BB Trade Estonia had a long-term receivable of 688,390 EUR from legal-entity owners with significant holdings and companies under their control and owed 1,300,000 EUR to the same category; in 2021 it bought services for 1,728,059 EUR from members of management, owners with significant holdings and their companies (2020: 1,300,000 EUR).", "qualification": "The report identifies these counterparties only by category.", "response": "", "outcome": "", "source_ids": [ "src-003" ], "entity_ids": [ "bbte" ] }, { "id": "c-rpt-related-2022-2023", "kind": "fact", "text": "BB Trade Estonia's 2022 and 2023 reports show it buying services from legal-entity owners with significant holdings and companies under their control for 2,656,173 EUR in 2022 and 2,264,154 EUR in 2023, and from management and private owners for 42,819 EUR and 384,491 EUR. A loan to the legal-entity owner category stood at 647,051 EUR (2022) and 660,157 EUR (2023); at 31 December 2022 the company owed 2,275,612 EUR to management and private owners with significant holdings and their companies, and had a long-term receivable of 371,987 EUR from them.", "qualification": "The reports identify the counterparties only by category; Divisio Holding A.G. is named as the parent.", "response": "", "outcome": "", "source_ids": [ "src-028", "src-027" ], "entity_ids": [ "bbte" ] }, { "id": "c-rpt-related-2024", "kind": "fact", "text": "At 31 December 2024 BB Trade Estonia had short-term receivables and prepayments of 30,509,787 EUR (2023: 8,339,160 EUR) from legal-entity owners with significant holdings and companies under their control; the report adds that 30,451,398 EUR of other receivables (2023: 8,294,907 EUR) were prepayments made to a related party. In 2024 the group bought services for 5,457,011 EUR from that category (2023: 2,264,154 EUR) and for 332,100 EUR from management and private owners; management remuneration for the whole group was 815,129 EUR (2023: 168,986 EUR).", "qualification": "The annual report does not name the related party that received the prepayments.", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte" ] }, { "id": "c-rpt-expofer-receivable", "kind": "attributed", "text": "A law firm acting for claimants states that 30,451,398 EUR of the 30,509,787 EUR owner-related receivable at the end of 2024 was owed by EXPOFÉR SERVIS HOUSE s.r.o. of Ostrava, which the exchange's management had described in its 2023 related-party statement as Przemysław Kral's company, and that the remaining 58,389 EUR was interest on loans to S.B. Bay FZE, Sylwester Suszek's company in the United Arab Emirates. According to the firm, the Expofer receivable grew from 8,293,987 EUR to 30,451,398 EUR in 2024 while the exchange bought services from Expofer for 2,046,754 EUR in 2023 and 5,041,151 EUR in 2024.", "qualification": "The annual report does not name Expofer; the identification comes from the law firm's reading of a related-party statement that is not in the retained record. This is the account of a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements; those documents are not in the retained record and no reply by the persons concerned is recorded.", "response": "", "outcome": "", "source_ids": [ "src-010" ], "entity_ids": [ "bbte", "expofer", "kral", "sb-bay", "suszek" ] }, { "id": "c-rpt-kral-loan", "kind": "attributed", "text": "The 2024 annual report lists a 407,297 EUR loan (Laen 4, 2%, PLN, due 2025) and a long-term receivable of the same amount from management and private owners with significant holdings. A law firm acting for claimants states that this amount was lent to Przemysław Kral personally.", "qualification": "The annual report does not name the borrower; the identification is the law firm's. This is the account of a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements; those documents are not in the retained record and no reply by the persons concerned is recorded.", "response": "", "outcome": "", "source_ids": [ "src-013", "src-010" ], "entity_ids": [ "bbte", "kral" ] }, { "id": "c-rpt-loans-2021-2022", "kind": "fact", "text": "BB Trade Estonia's loans receivable were 6,559,687 EUR at 31 December 2021 and 5,936,522 EUR at 31 December 2022. The 2022 report describes them as EUR and PLN loans at 2–3% maturing between January and August 2030, partly unsecured and partly granted to related parties; a loan with a remaining balance of 2,878,500 EUR was secured by a mortgage valued at 10 million EUR, and one of 334,136 EUR (1,500,000 PLN) by 18 ETH.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028", "src-003" ], "entity_ids": [ "bbte" ] }, { "id": "c-rpt-loans-2023", "kind": "fact", "text": "At 31 December 2023 BB Trade Estonia's loans receivable totalled 12,297,900 EUR across eight loans that the report identifies only by number, including Loan 2 of 2,878,500 EUR (2%, due 2041), Loan 6 of 3,441,429 EUR denominated in crypto-assets (2%, due 2024), Loan 7 of 2,728,068 EUR (EUR and PLN, due 2024) and Loan 8 of 20,214 EUR in Swiss francs.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-027" ], "entity_ids": [ "bbte" ] }, { "id": "c-rpt-loans-2024", "kind": "fact", "text": "At 31 December 2024 BB Trade Estonia's loans receivable had risen to 93,620,229 EUR. Two loans maturing in 2025 accounted for most of it: Laen 6 of 14,448,098 EUR (EUR, PLN and USD, variable interest) and Laen 7 of 75,016,307 EUR denominated in crypto-assets (variable interest). The report, signed in July 2025, states that 58,264 thousand EUR of loans 6 and 7 had been returned as at 28 July 2025; it does not name the borrowers.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte" ] }, { "id": "c-rpt-admitrade-line", "kind": "attributed", "text": "A law firm acting for claimants states that on 12 September 2022 BB Trade Estonia concluded a credit-line agreement with AdmiTrade OÜ, an Estonian company of Wojciech Sroka, providing fiat financing \"with the possibility of further trading on the client's side\". According to the firm, Annex 1 of 4 December 2023, signed by Przemysław Kral and Sroka, called AdmiTrade a \"strategic liquidity provider\", set the limit at 100,000,000 EUR and allowed the funds to be used on other exchanges and platforms, for arbitrage, market making, staking, secured loans, loans to related entities, investment in the ZND token and platform and general crypto trading, with the borrower to keep at least 40% of the drawn amount on its exchange account.", "qualification": "This is the account of a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements; those documents are not in the retained record and no reply by the persons concerned is recorded.", "response": "", "outcome": "The 2024 annual report records that 58,264 thousand EUR of loans 6 and 7 had been returned as at 28 July 2025; according to the same law firm, the credit line was ended by a termination agreement of that date.", "source_ids": [ "src-083", "src-013" ], "entity_ids": [ "bbte", "admitrade", "sroka", "kral" ] }, { "id": "c-rpt-admitrade-termination", "kind": "attributed", "text": "According to the same law firm, at 1 January 2025 the company's accounts \"Admitrade EARN fiat\" and \"Admitrade EARN crypto\" showed 14,448,098 EUR and 75,016,307 EUR, the amounts reported as Laen 6 and Laen 7 in the 2024 annual report. A termination agreement of 28 July 2025, signed by Sroka and Kral, gave as its reason the company's application for a MiCA licence; an annex listed 245 transfers between 23 and 26 July 2025 worth 58,264,534 EUR in crypto-assets returned by AdmiTrade. The firm states that by 22 April 2026 both AdmiTrade accounts stood at zero in the books without any loss being recorded.", "qualification": "The match with Laen 6 and Laen 7 is exact to the euro and the returned amount matches the 58,264 thousand EUR in the annual report, but the annual report does not name AdmiTrade. This is the account of a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements; those documents are not in the retained record and no reply by the persons concerned is recorded.", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte", "admitrade", "sroka", "kral" ] }, { "id": "c-rpt-orion-investment-2020", "kind": "attributed", "text": "A law firm acting for claimants states that on 2 March 2020 in Katowice BB Trade Estonia, then represented by Sylwester Suszek, undertook to recapitalise Orion Software sp. z o.o., at the time a private company of Przemysław Kral with 5,000 PLN of share capital, up to 100,000,000 PLN in monthly payments convertible into share capital, and that on the same day Orion, represented by Kral, undertook to recapitalise EXPOFÉR SERVIS HOUSE s.r.o. of Ostrava up to 100,000,000 PLN on the same pattern, with Suszek signing for Expofer as its executive (jednatel).", "qualification": "This is the account of a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements; those documents are not in the retained record and no reply by the persons concerned is recorded.", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte", "orion", "expofer", "kral", "suszek" ] }, { "id": "c-rpt-orion-advances", "kind": "fact", "text": "BB Trade Estonia's 2021 annual report records prepayments under an investment agreement of 5,498,608 EUR in 2020 and a further 8,923,511 EUR in 2021, shown as financial investments of 14,422,121 EUR at the end of 2021. On 22 July 2022 the company acquired 100% of Orion Software sp. z o.o. and resolved to increase Orion's share capital by 1,000,000 PLN and to pay a share premium of 60,636,679 PLN; both contributions were made in kind because it had already made payments under the investment agreement.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003", "src-028" ], "entity_ids": [ "bbte", "orion" ] }, { "id": "c-rpt-orion-acquisition", "kind": "fact", "text": "The 2022 annual report states that the July 2022 acquisition of the subsidiary was a transaction between related parties and resulted in a loss of 540,825 EUR, recognised as a change in retained earnings of prior periods rather than in the income statement. The 2024 report gives the carrying amount of the Orion holding as 12,975,010 EUR at the end of 2023 and 19,272,407 EUR at the end of 2024, after increases of Orion's share capital and reserve capital during 2024.", "qualification": "A law firm acting for claimants states that the nominal acquisition price was 1,052 EUR and that Orion was bought from a related party; the reports do not name the seller.", "response": "", "outcome": "", "source_ids": [ "src-028", "src-013" ], "entity_ids": [ "bbte", "orion" ] }, { "id": "c-rpt-orion-loan", "kind": "attributed", "text": "A law firm acting for claimants states that under a loan agreement of 4 August 2022, signed by Przemysław Kral for BB Trade Estonia and by a proxy for Orion, the exchange operator agreed to lend Orion 50,000,000 EUR in tranches, each repayable within ten years, at 10% a year, without security and with an option to settle repayment by converting the claim into Orion's share capital; Annex 2 of 1 January 2024 cut the rate to 4.6% payable at the end of the agreement. According to the firm, the general-ledger loan account had more than 170 entries, the last tranche was paid on 16 March 2026 and the balance was 75,084,120.12 EUR.", "qualification": "This is the account of a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements; those documents are not in the retained record and no reply by the persons concerned is recorded.", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte", "orion", "kral" ] }, { "id": "c-rpt-orion-exposure", "kind": "attributed", "text": "The same law firm puts the bankruptcy estate's exposure to Orion Software at about 105 million EUR: 80.6 million EUR of loans with interest and 24.7 million EUR of capital and contributions under the investment agreement, transferred until 16 March 2026. It states that Orion's 2025 financial statements, unfiled when it wrote, show related-party loan liabilities rising from 161,432,192 PLN to 334,795,058 PLN, about 254 million PLN of receivables from EXPOFÉR SERVIS HOUSE s.r.o. booked as a \"Loan and investment agreement Expofer\", 115 million PLN of prepayments for intangible assets and 188,701 PLN of cash at the end of 2025, when Orion had 47 employees and held the exchange's servers, code and customer database.", "qualification": "This is the account of a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements; those documents are not in the retained record and no reply by the persons concerned is recorded. Orion's 2025 statements were not on the public register when the firm wrote.", "response": "", "outcome": "", "source_ids": [ "src-075", "src-083" ], "entity_ids": [ "bbte", "orion", "expofer" ] }, { "id": "c-rpt-expofer-guarantee", "kind": "fact", "text": "Under a contract of 28 December 2020 between UAB ZEN, BB Trade Estonia OÜ and EXPOFÉR SERVIS HOUSE s.r.o. and a further arrangement of 23 September 2022, BB Trade Estonia issued a guarantee of Expofer's obligations of up to 567,240 EUR, valid until 31 December 2025 or until the obligation was performed. The 2022 annual report states that the guaranteed obligations were fulfilled in 2022 and no guarantee obligation remained at 31 December 2022.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003", "src-028" ], "entity_ids": [ "bbte", "expofer", "zen" ] }, { "id": "c-rpt-znd-ventures", "kind": "attributed", "text": "BB Trade Estonia's 2022 cash-flow statement records 792,000 EUR paid for associates, its interest in ZND Ventures OÜ (then 50%). A law firm acting for claimants states that an investment agreement of 10 August 2022 with ICEO RED Venture Builder OÜ provided for a jointly owned company financed with 1.5–2 million EUR of interest-free convertible loans, that an annex of 24 May 2023 renamed it ZND Ventures OÜ and raised the limit to 4–5 million EUR, and that the general ledger shows payments to ZND Ventures totalling 18,574,553 EUR, monthly in 2024 and 2025 and in smaller amounts until 6 March 2026, with conversions to reserve capital of 2,500,000 EUR (December 2024) and 2,414,500 EUR (May 2025) and a balance of 13,660,053 EUR.", "qualification": "This is the account of a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements; those documents are not in the retained record and no reply by the persons concerned is recorded.", "response": "", "outcome": "", "source_ids": [ "src-028", "src-083" ], "entity_ids": [ "bbte", "znd-ventures", "iceo-red-0" ] }, { "id": "c-rpt-sb-bay-loans", "kind": "attributed", "text": "A law firm acting for claimants states that in summer 2020 S.B. Bay FZE, a free-zone company in Umm Al Quwain whose director and owner was Sylwester Suszek, borrowed three times from the exchange operator: 500,000 EUR (31 July 2020), 495,000 PLN (26 August 2020) and 200,000 PLN (31 August 2020), at 2% until 2030, with Suszek signing for both lender and borrower and with crypto-assets in a wallet on bitbay.net pledged as security. According to the firm, the management's 2023 related-party statement shows nothing repaid at 31 December 2023 (500,000 EUR plus 34,219 EUR interest and 695,000 PLN plus 46,520 PLN interest).", "qualification": "This is the account of a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements; those documents are not in the retained record and no reply by the persons concerned is recorded.", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte", "sb-bay", "suszek" ] }, { "id": "c-rpt-suszek-receipts-2023", "kind": "attributed", "text": "The same law firm states that BB Trade Estonia's accounts at SEBA Bank AG in Zug received 1,041,826.22 EUR on 6 June 2023 and 1,323,493.15 PLN on 12 June 2023 from a sender named \"Sylwester Jan Suszek\" with an address in Zug, about fifteen months after his disappearance, and that the company's lawyer explained them to the accountant in December 2023 as repayments of four personal loans to Suszek at 15%. The firm notes that two of those four loan agreements repeat the dates and amounts of the S.B. Bay FZE loans with different terms, and treats the question of who controlled the sending account as open.", "qualification": "This is the account of a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements; those documents are not in the retained record and no reply by the persons concerned is recorded. The firm itself calls its reading of these payments a hypothesis that only prosecutors can resolve.", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte", "suszek", "amina" ] }, { "id": "c-rpt-credit-line-2021", "kind": "attributed", "text": "BB Trade Estonia's 2021 and 2022 reports list a 2,878,500 EUR loan (2%, due 2041) secured by a mortgage over property valued at 10 million EUR. A law firm acting for claimants identifies it as a 2,910,000 EUR credit line that Sylwester Suszek signed for the company on 24 May 2021 with a private individual, Jaromira W., \"for the purchase of real estate\", for 20 years at 2%; it states that 2,878,500 EUR was transferred on 2 June 2021 to a notary's escrow account in Nice, that one repayment of 162,594 EUR followed in November 2024, and that it is not known whether the promised mortgage over Polish property was ever created.", "qualification": "The annual reports do not name the borrower and state that the loan is secured by a mortgage; the law firm, relying on the agreement and ledger, says it is not known whether the mortgage was created. This is the account of a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements; those documents are not in the retained record and no reply by the persons concerned is recorded.", "response": "", "outcome": "In September 2026 Polish prosecutors charged Jaromira W. with, among other things, obtaining a confirmation of repayment of a 2.9 million EUR loan that had in fact not been repaid (see the investigations section); she did not plead guilty.", "source_ids": [ "src-083", "src-003", "src-103" ], "entity_ids": [ "bbte", "suszek" ] }, { "id": "c-rpt-znd-exchange", "kind": "attributed", "text": "According to the same law firm, a \"ZND Token Exchange Agreement\" between Jaromira W. and BB Trade Estonia, concluded for the company by Przemysław Kral and dated \"on or before January 1, 2025\", gave her the right to exchange 13,352,871.75 ZND for 7,993,000 EUR at 0.5986 EUR per token, described as the average closing price of 31 December 2024. The exercise order is dated 9 October 2025; the day before, a notary in Villefranche-sur-Mer had issued her a settlement for a property purchase of 7,992,480 EUR.", "qualification": "This is the account of a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements; those documents are not in the retained record and no reply by the persons concerned is recorded.", "response": "", "outcome": "On 2 September 2026 prosecutors charged Jaromira W. with causing large-scale damage to the exchange operator, including by receiving almost 8 million EUR from its account on 9 October 2025 to buy real estate in France; she did not plead guilty and was remanded in custody for three months on 4 September 2026.", "source_ids": [ "src-083", "src-103" ], "entity_ids": [ "bbte", "kral" ] }, { "id": "c-rpt-bahamas-balances", "kind": "attributed", "text": "A law firm acting for claimants cites an internal exchange memo stating that between 18 June and 8 September 2025, 400,000 USDT and 4,900,000 USDC were credited \"via balance adjustment\" to BB Trade Bahamas Ltd's technical account in the zondacrypto system, with the note \"formally a loan or investment of BB Trade Estonia in BB Trade Bahamas; we do not have an agreement for it\". According to the memo as described, the funds were withdrawn to the Bahamian company's account on Gate.com and used to buy 18,250,092 ZND, which were sold on 12 September 2025 to one user over the counter for 997.6 ETH; part of the ether was sold through AdmiTrade's account at Kraken for 2,314,325 EUR and the euros were returned to the Bahamian account and \"removed via balance adjustment\".", "qualification": "This is the account of a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements; those documents are not in the retained record and no reply by the persons concerned is recorded. The memo is not in the retained record.", "response": "", "outcome": "", "source_ids": [ "src-083", "src-075" ], "entity_ids": [ "bbte", "bb-bahamas", "admitrade", "payward" ] }, { "id": "c-rpt-bahamas-arrangements", "kind": "attributed", "text": "According to the same law firm, BB Trade Bahamas Ltd (company no. 213148 B, Nassau) traded as \"Coin Accepted\", provided outsourcing services to the exchange from June 2024 and from 21 February 2025 rented its infrastructure, equipment, software and virtual addresses for 5% of gross profit a month; its Nassau accounting was invoiced to Orion Software, it kept 200,000 USD of capital on deposit for the Securities Commission of The Bahamas, and in March 2025 it signed a payment-gateway agreement with a currency-exchange office from Wadowice.", "qualification": "This is the account of a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements; those documents are not in the retained record and no reply by the persons concerned is recorded.", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bb-bahamas", "bbte", "orion" ] }, { "id": "c-rpt-march-2026-outflows", "kind": "attributed", "text": "A law firm acting for claimants states that between 2 and 24 March 2026, in the last weeks before withdrawals stopped, fourteen payments totalling 501,037.80 EUR went from the company's accounts to Przemysław Kral's account, and that the March 2026 bank statements also show 105,410.79 EUR of VAT paid and 330,000 EUR transferred to Sygnum Bank on 27 March, with four external recipients receiving 848,163.42 EUR that month. Customer withdrawals stopped in the first days of April 2026.", "qualification": "This is the account of a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements; those documents are not in the retained record and no reply by the persons concerned is recorded. One of the firm's pieces describes the fourteen transfers as ordered by the chairman and lists several recipients; who ordered and approved them and what they covered is, in its words, still to be established.", "response": "", "outcome": "", "source_ids": [ "src-075", "src-083" ], "entity_ids": [ "bbte", "kral", "sygnum" ] }, { "id": "c-rpt-kral-trustee-replies", "kind": "attributed", "text": "According to the same law firm, citing the trustee's report, Przemysław Kral replied to the trustee on 15 June 2026 without information on the composition of the assets or source documents, explaining that he had no access to the servers, cloud, databases and backups because they were under the control of the Polish authorities, that part of the information was covered by the secrecy of the investigation and that the accountant held the books. To a demand of 5 August he replied on 12 August 2026 with an unaudited management balance sheet as of the end of 2025 and a list of the company's accounts from memory; the trustee stated that he could not confirm any asset beyond the cash on the accounts.", "qualification": "This is the account of a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements; those documents are not in the retained record and no reply by the persons concerned is recorded. The trustee's report itself is not in the retained record.", "response": "Kral's explanation, as relayed, was that the systems were under the Polish authorities' control and that the accountant and prosecutors held the information.", "outcome": "", "source_ids": [ "src-075" ], "entity_ids": [ "kral", "bbte" ] }, { "id": "c-crim-katowice-opened", "kind": "fact", "text": "On 17 April 2026 the Regional Prosecutor's Office in Katowice opened an investigation concerning Zondacrypto into the misleading of many people as to the possibility of buying and storing fiat currencies and crypto-currencies on the Zondacrypto exchange, causing them to dispose of their property disadvantageously (fraud of large value, Article 286 §1 with Articles 294 §1 and 12 §1 of the Polish Penal Code), and into the handling of funds in ways that could conceal their criminal origin (money laundering, Article 299 §1 and §5). The investigation covers conduct across Poland since 2022, was opened on the basis of victims' complaints and media reports about withdrawal problems, put the damage at no less than 350 million PLN and was entrusted to the Wrocław office of the Central Cybercrime Bureau (CBZC).", "qualification": "The release names the Zondacrypto brand, not the company operating it; later releases of the National Prosecutor's Office identify BB Trade Estonia OÜ as the operator. An investigation opened 'in the case' does not itself name suspects or establish an offence.", "response": "", "outcome": "", "source_ids": [ "src-065" ], "entity_ids": [ "bbte" ], "adverse_subject_ids": [ "bbte" ] }, { "id": "c-crim-cold-wallet-statement", "kind": "attributed", "text": "The prosecutors' release of 17 April 2026 stated that the owner of the exchange had indicated that since 2022 the exchange had had no access to a so-called cold wallet said to hold about 4,500 BTC, and that this information had been concealed from clients.", "qualification": "This is the prosecutors' summary of a statement by the exchange's owner at the opening of the investigation; it is not a finding, and the release does not say how or when access was lost.", "response": "In early April 2026 Przemysław Kral had said in a statement that Zondacrypto was stable, solvent and safe and called a press analysis of a 99% fall in its bitcoin reserves erroneous, untrue and harmful; on 16 April 2026 he said publicly that the keys to the roughly 4,500-bitcoin wallet were held by Sylwester Suszek, the founder of the predecessor exchange BitBay, who has been missing since March 2022.", "outcome": "", "source_ids": [ "src-065", "src-112" ], "entity_ids": [ "bbte", "kral", "suszek" ] }, { "id": "c-crim-may-update", "kind": "fact", "text": "In an update of 12 May 2026 the Katowice prosecutors reported that 104 electronic devices and more than 13 TB of files from ZondaCrypto's production servers had been secured across Poland, that more than 100 of the world's largest crypto exchanges had been asked to secure funds and data, that several hundred injured persons had been questioned and almost 2,000 complaints received, that a European Investigation Order had been sent to the Czech Republic and requests for legal assistance to Italy and Switzerland were being prepared, and that CBZC officers were tracing blockchain flows between ZondaCrypto and other exchanges and analysing wallets set up by ZondaCrypto.", "qualification": "The update names the ZondaCrypto brand; the National Prosecutor's Office later identified BB Trade Estonia OÜ as the exchange's operator.", "response": "", "outcome": "", "source_ids": [ "src-109" ], "entity_ids": [ "bbte" ] }, { "id": "c-crim-june-update", "kind": "fact", "text": "In an update of 22 June 2026 the Katowice prosecutors reported that a joint investigation team (JIT) with the Estonian side had been set up on 28 May 2026 to exchange evidence and coordinate operations; that Polish prosecutors had also coordinated with Monaco's judicial authorities; and that more than 3,600 criminal complaints from injured persons had been registered, nearly 1,000 of them and 40 other persons questioned, 162 electronic devices and more than 250 TB of files from ZondaCrypto's production servers secured, 63 search and production orders executed, and a European Investigation Order and a request for legal assistance sent to Italy and Switzerland.", "qualification": "The update names the ZondaCrypto brand; the National Prosecutor's Office later identified BB Trade Estonia OÜ as the exchange's operator.", "response": "", "outcome": "", "source_ids": [ "src-029", "src-110", "src-112" ], "entity_ids": [ "bbte" ] }, { "id": "c-crim-july-update", "kind": "attributed", "text": "According to a Polish news-agency report, the Katowice prosecutors' spokesman said on 27 July 2026 that the investigation had been extended by six months to 17 January 2027; that investigators had examined Telegram and Slack correspondence between Zondacrypto employees and sought an expert opinion on the exchange's financial position; and that a freeze had been ordered on a bank account at a French branch of a bank that received 4 million EUR (over 17.3 million PLN) from the transfer of ownership of a Monaco-registered company whose shareholders are suspects, on the suspicion that the transaction was a stage in laundering money taken from the exchange's clients. A judge of the Paris Court of Appeal ordered the funds seized under the EU regulation on mutual recognition of freezing and confiscation orders. The agency identified BB Trade Estonia OU as the operator of zondacrypto.com.", "qualification": "Reported by a news agency from the spokesman's statement; the French court decision and the prosecutors' order are not in the retained record, and the release does not name the suspects.", "response": "", "outcome": "", "source_ids": [ "src-112" ], "entity_ids": [ "bbte" ] }, { "id": "c-crim-merger", "kind": "fact", "text": "The National Prosecutor's Office has stated that an investigation into the unlawful deprivation of liberty of Sylwester Suszek, founder of the BitBay exchange, was opened on 18 March 2022 by the District Prosecutor's Office in Sosnowiec and taken over by the Katowice branch of its Department for Organised Crime and Corruption (case 1001-109.Ds.77.2022), and that the Katowice regional investigation into ZondaCrypto (2003-2.Ds.14.2026) was merged into it. The Prosecutor General explained that both cases examine the founding and activity of the BitBay (later ZondaCrypto) exchange, which may matter for establishing what happened to Suszek.", "qualification": "The two official texts give different merger dates: the release of 28 August 2026 says 19 July 2026, while the Prosecutor General's statement of 25 August 2026 refers to a decision of 30 July 2026.", "response": "", "outcome": "", "source_ids": [ "src-094", "src-102" ], "entity_ids": [ "suszek", "bbte" ] }, { "id": "c-crim-pg-statement", "kind": "fact", "text": "In a statement of 25 August 2026 Prosecutor General Waldemar Żurek said that prosecutors could not disclose the identities of the suspects or the charges, and that on the basis of the evidence secured they were verifying information on possible offences connected with ZondaCrypto's funding of: the foundation of former Justice Minister and Prosecutor General Zbigniew Ziobro; the foundation of Przemysław Wipler and others acting with him, in connection with the legislative process on the crypto market; Telewizja Republika and its president Tomasz Sakiewicz; the conservative CPAC conference; a possible financial benefit given to Radosław Piesiewicz, president of the Polish Olympic Committee; and actions of persons helping former deputy justice minister Marcin Romanowski, whom the statement describes as having fled. He said the investigation's priority was to secure as much potentially criminal money as possible for the injured parties.", "qualification": "The statement describes lines of inquiry, not findings, and says prosecutors cannot comment on the evidence for them. It refers to the ZondaCrypto brand and does not say which legal entity, such as the operator BB Trade Estonia OÜ, made any payment.", "response": "", "outcome": "", "source_ids": [ "src-102" ], "entity_ids": [ "bbte" ] }, { "id": "c-crim-donations-press", "kind": "attributed", "text": "A Polish news report of April 2026 stated that in May 2025 Zondacrypto was the main sponsor of the CPAC Polska conference in Rzeszów, that at the turn of October and November 2025 Przemysław Kral paid 450,000 PLN to the Instytut Polski Suwerennej foundation of Zbigniew Ziobro, and that EXPOFÉR SERVIS HOUSE s.r.o., described as a company from Kral's network, transferred 70,000 EUR to Przemysław Wipler's Fundacja Dobry Rząd.", "qualification": "Reported by a news site from what it describes as publicly available data; the payment records are not in the retained material. The Prosecutor General later said prosecutors were verifying information on such funding without stating any finding.", "response": "", "outcome": "", "source_ids": [ "src-091" ], "entity_ids": [ "kral", "expofer" ] }, { "id": "c-crim-radoslaw-p", "kind": "fact", "text": "On 27 August 2026 Central Cybercrime Bureau officers detained Radosław P. in investigation 1001-109.Ds.77.2022. Prosecutors charged him with (1) invoking, in 2025, influence in the competition and consumer-protection office UOKiK, said to stem from acquaintance with a former Polish prime minister, and in return for a watch worth 169,476 PLN undertaking to settle the UOKiK proceedings against ZondaCrypto and its operator BB Trade Estonia OU; and (2) inducing, in April 2026 in Warsaw and Monaco, an identified member of BB Trade Estonia OU's management board, when the company faced insolvency or bankruptcy, to pay out 194,420.15 PLN on 7 April 2026 and 100,000 EUR on 8 April 2026 from the exchange to the detriment of its other creditors, the exchange's users.", "qualification": "These are charges, not findings of guilt.", "response": "Radosław P., questioned as a suspect, did not admit the charges and gave extensive explanations; he is represented by defence counsel.", "outcome": "The prosecutor applied to the court for three months' pre-trial detention; the court's decision is not recorded in the retained official releases.", "source_ids": [ "src-094" ], "entity_ids": [ "bbte" ] }, { "id": "c-crim-anna-p", "kind": "fact", "text": "On 2 September 2026 prosecutors detained three people and charged Anna P. with participating in 2020–2026 in an organised criminal group aimed at taking over the assets of Sylwester Suszek; with causing, jointly with other identified persons, large-scale property damage to the operator of ZondaCrypto (BB Trade Estonia OU), in that an identified person disposed of the company's property without any economic justification, including by transferring to her a property in Katowice worth 700,000 PLN without payment; and with obstructing the proceedings on Suszek's deprivation of liberty by removing the disk of a fuel station's CCTV recorder and inducing false testimony.", "qualification": "These are charges, not findings of guilt.", "response": "The suspects did not admit the charges and gave explanations.", "outcome": "On 4 September 2026 the court remanded Anna P. in custody for three months; a legal news site reported that the regional court in Katowice upheld the custody decisions.", "source_ids": [ "src-103", "src-095" ], "entity_ids": [ "bbte", "suszek" ] }, { "id": "c-crim-jaromira-w", "kind": "fact", "text": "Jaromira W., detained on 2 September 2026, was charged with participating in the same organised group; with causing large-scale damage to the operator of ZondaCrypto, including by receiving almost 8 million EUR from the operator's account on 9 October 2025 to buy real estate in France, obtaining a confirmation of repayment of a 2.9 million EUR loan that in fact had not been repaid, and accepting a property in Katowice worth 800,000 PLN without payment; and with laundering 7.5 million PLN of proceeds connected with the operator's activity through a fictitious property purchase.", "qualification": "These are charges, not findings of guilt.", "response": "The suspects did not admit the charges and gave explanations.", "outcome": "On 4 September 2026 the court remanded her in custody for three months.", "source_ids": [ "src-103" ], "entity_ids": [ "bbte", "suszek" ] }, { "id": "c-crim-rafal-z", "kind": "fact", "text": "Rafał Z., detained on 2 September 2026, was charged with misappropriating 1.7 million PLN of the ZondaCrypto operator's money entrusted to him.", "qualification": "This is a charge, not a finding of guilt; the same release identifies the operator of ZondaCrypto as BB Trade Estonia OU.", "response": "He did not admit the charge and gave explanations.", "outcome": "On 4 September 2026 the court remanded him in custody for three months.", "source_ids": [ "src-103" ], "entity_ids": [ "bbte" ] }, { "id": "c-crim-roman-z", "kind": "attributed", "text": "A legal news site reported that on 7 September 2026 the Prosecutor General's spokesperson announced charges against Roman Ż., detained two days earlier: participation in an organised criminal group aimed at computer fraud to the detriment of the exchange's users of at least 7.8 million PLN, and misappropriation, jointly with identified persons, of 7.8 million PLN invested on the exchange by its users by altering, deleting and entering IT data without authorisation.", "qualification": "The prosecutors' own release on these charges is not in the retained record; these are charges, not findings of guilt. The report concerns the investigation into the Zondacrypto exchange operated by BB Trade Estonia OÜ.", "response": "According to the same report, Roman Ż. did not admit the charges and gave explanations.", "outcome": "The report states that a court ordered his pre-trial detention and that on 18 September 2026 the regional court in Katowice upheld it.", "source_ids": [ "src-095" ], "entity_ids": [ "bbte" ] }, { "id": "c-crim-artur-k", "kind": "fact", "text": "Artur K., detained on 22 September 2026, was charged with participating in an organised criminal group aimed at unauthorised interference with data in the exchange's IT system, creating fictitious receivables and misappropriating users' funds of at least 7.8 million PLN, misappropriating 3,900 bitcoins by handing them to a third party as collateral for a loan, and laundering the proceeds; and with failing in his duties as security director of the BitBay, later ZondaCrypto, exchange regarding identity verification, the legality of fund flows and anti-money-laundering procedures, by tolerating unlawful transactions known to him and so facilitating offences by others.", "qualification": "These are charges, not findings of guilt. The release names the exchange, not its operator; other releases in the same investigation identify the operator as BB Trade Estonia OU.", "response": "He did not admit the charges and gave extensive explanations.", "outcome": "The prosecutor applied to the Katowice-Wschód District Court for pre-trial detention; the decision is not recorded in the retained release.", "source_ids": [ "src-066" ], "entity_ids": [ "bbte" ] }, { "id": "c-crim-marian-w", "kind": "attributed", "text": "A legal news site, citing a television report, stated that Marian W. faces charges of unlawfully depriving Sylwester Suszek of his liberty (a charge first brought on 15 March 2022); of acting to the detriment of BB Trade Estonia OÜ, including by instructing withdrawals of company funds such as the transfer of nearly 8 million EUR to buy real estate in France; of leading an organised criminal group intended to take over the assets of Suszek and companies he controlled, including Luxbay S.A., S&B Investment S.A. and BB Trade Estonia OÜ; and of money laundering.", "qualification": "The charges are reported second-hand; the prosecutors' releases in the retained record do not list them. They are charges, not findings, and no plea is recorded. A Polish news agency separately reported that Marian W. was charged with depriving Suszek of his liberty.", "response": "", "outcome": "", "source_ids": [ "src-095", "src-112" ], "entity_ids": [ "suszek", "bbte", "luxbay", "sb-investment" ] }, { "id": "c-crim-kral-status", "kind": "unresolved", "text": "Prosecutors have not officially disclosed the procedural status of Przemysław Kral, the chief executive of Zondacrypto. The Prosecutor General's spokesperson Anna Adamiak said she could not disclose it, as it was the decision of the prosecutor in charge. Ewa Wrzosek, a prosecutor serving as general counsel at the Ministry of Justice, said in a radio interview that Kral had begun cooperating and was giving explanations as a suspect and, in her view, had been charged with, among other things, fraud against Zondacrypto's clients. Justice Minister Waldemar Żurek said Kral \"is not a crown witness and is not a witness\".", "qualification": "The accounts differ and none is an official record of charges. In late July 2026 a Polish daily reported that Kral was then not a suspect and not subject to an arrest warrant and that Polish officials had met him to discuss cooperation; the National Prosecutor's Office said it did not comment on those reports.", "response": "Kral's defence counsel Roman Giertych said on 25 August 2026 that he had represented Kral since May and that his client had placed \"huge assets\" at the prosecutors' disposal, enough in his view to satisfy all the injured persons who had come forward; two days later the justice minister said prosecutors had secured more than 100 million PLN for future compensation. It is not known whether both statements concern the same assets.", "outcome": "", "source_ids": [ "src-095", "src-112", "src-108" ], "entity_ids": [ "kral" ], "adverse_subject_ids": [ "kral" ] }, { "id": "c-crim-first-investigation-2024", "kind": "attributed", "text": "A law firm acting for claimants states that when the Regional Prosecutor's Office in Katowice discontinued an earlier investigation into blocked withdrawals on the exchange in April 2024, its reasoning noted, among other things, that the exchange was still operating and was sponsoring Juventus.", "qualification": "The discontinuance decision is not in the retained record; this is the law firm's description of it, and no official release on that investigation is retained.", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte", "juventus" ] }, { "id": "c-crim-estonia", "kind": "attributed", "text": "An Estonian business daily reported on 19 May 2026 that, in addition to the criminal investigation in Poland, the Estonian state prosecutor's office was investigating possible money laundering in connection with the Zondacrypto platform, which operated through an Estonian company.", "qualification": "Known only from press captions retained on a business-information card for BB Trade Estonia OÜ; no act of the Estonian prosecutor's office is in the retained record, and its scope and status are not known.", "response": "", "outcome": "", "source_ids": [ "src-067" ], "entity_ids": [ "bbte" ] }, { "id": "c-id-bbts-identifiers", "kind": "fact", "text": "BB Trade Switzerland AG is also registered as BB Trade Switzerland SA and BB Trade Switzerland Ltd.; its Swiss enterprise identifier (UID) is CHE-254.348.698 and its commercial-register number CH-170.3.044.963-8.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-079", "src-014" ], "entity_ids": [ "bb-switzerland" ] }, { "id": "c-id-zonda-token-uid", "kind": "fact", "text": "Zonda Token AG's Swiss enterprise identifier (UID) is CHE-221.704.071.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-062" ], "entity_ids": [ "zonda-token" ] }, { "id": "c-id-polish-identifiers", "kind": "fact", "text": "Polish National Court Register data reproduced by a commercial aggregator give Orion Software sp. z o.o. the tax number (NIP) 9542811828 and statistical number (REGON) 385348160, TryPay S.A. the KRS number 0000412103 and NIP 8971781665, and Femion Technology S.A. the KRS number 0000377784 and NIP 8943016705.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-055", "src-033", "src-034" ], "entity_ids": [ "orion", "trypay", "femion" ] }, { "id": "c-id-auditor-codes", "kind": "fact", "text": "In the Estonian e-Business Register, Assertum Audit OÜ has registry code 10990446 and Crowe DNW OÜ registry code 14299250.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-119", "src-120" ], "entity_ids": [ "assertum", "crowe-dnw" ] }, { "id": "display-claim-6296b3e8b7c7fd96231f242c", "kind": "analysis", "text": "The Estonian Commercial Register lists BB Trade Estonia OÜ as a private limited company (osaühing) entered on 30 September 2019 under registry code 14814864 (EUID EEARIREG.14814864), with the legal entity identifier 984500L05A5D0E66Q610. The register card records it as registered for value added tax under number EE102200164 from 22 October 2019, with no end date, and gives its current status as bankrupt (pankrotis).", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-001" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-575e6259527ef54ef545085e", "kind": "analysis", "text": "The company was registered as Pinewood Estonia OÜ. According to its first annual report, covering 30 September 2019 to 31 December 2020, it carried that name until 13 February 2020 and has been called BB Trade Estonia OÜ since then; the register card keeps Pinewood Estonia OÜ as a former name.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-001", "src-006" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-06e9b24937160c19de0ac06c", "kind": "analysis", "text": "The registered address has changed several times within Tallinn. The first annual report records a move in April 2020 from Lõõtsa tn 5 to Lõõtsa tn 8a; the 2021 report gives Rävala pst 2, and the 2022 report gives Tähesaju tee 9 in the Lasnamäe district, the address still on the register card. The 2022 report dates the move to Tähesaju tee 9 to 13 September 2023, whereas the register's publication history, as reproduced by a registry-data aggregator, lists address changes on 1 March and 13 September 2022; the retained records do not settle which year is right.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003", "src-006", "src-028", "src-104" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-dd040131547820d7490cfe0d", "kind": "analysis", "text": "The company was registered with share capital of EUR 2,500. The register's publication history shows increases to EUR 50,000 published on 22 May 2020 and to EUR 100,000 on 24 September 2020, which the first annual report confirms as fully paid. The 2021 report states that the capital was then raised to EUR 350,000, fully paid, and the 2022 cash-flow statement shows EUR 250,000 received from the issue of shares that year. The 2021 report dates the registration of the EUR 350,000 capital to 21 February 2022, while the publication history reproduced by an aggregator lists it on 31 March 2022.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028", "src-104", "src-006", "src-003" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-fc6b852023b85d0d6c8c58f4", "kind": "analysis", "text": "The register's summary of the filed annual reports gives revenue and profit of EUR 8,837,007 and EUR 6,491,835 for 2020, EUR 23,819,262 and EUR 17,205,468 for 2021, EUR 6,215,330 and EUR 1,735,279 for 2022, EUR 4,679,522 and EUR 2,645,524 for 2023, and EUR 6,076,753 and EUR 10,601,975 for 2024. The summary does not say whether each figure is the company-only or the consolidated result: the consolidated balance sheet in the 2022 report, for example, shows a 2022 profit of EUR 1,142,183. For 2020 the summary keeps the figures of the first annual report; the 2021 report corrected 2020 revenue to EUR 9,117,007.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-001", "src-028", "src-003" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-aae01bd413c3eba51279061e", "kind": "analysis", "text": "European Union trademark data reproduced by an aggregator list applications filed in the company's name: 9 in 2023, including ZONDACRYPTO, ZONDACRYPTO ACADEMY, ZONDACRYPTO PAY, TRADE TOMORROW TODAY and zondacrypto token; 8 in 2024, including ZND and ZND VENTURES; 17 in 2025, including TMPL and Token TeamPL; and 7 in 2026. The listing gives counts and sample names only, not each mark's registration status or present owner.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-104" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-4dd3d9d2bd19fdfe20414a7b", "kind": "analysis", "text": "An Estonian business-information service drawing on national registers reported in October 2026 that no real-estate register units (kinnistud) were registered to BB Trade Estonia OÜ. That summary does not cover assets held through subsidiaries or outside Estonia, and the land-register extract itself was not retained.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-067" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-424051ec925e54ebf77b700e", "kind": "analysis", "text": "From mid-2026 the register lists official notices published for the company in Ametlikud Teadaanded, the Estonian official gazette: notices of service of procedural documents in labour dispute committee proceedings (24 July 2026), a notice making a disposal ban known (28 July 2026) and the declaration of bankruptcy (27 August 2026, notice 2641740). A business-information service's list of the same notices also shows labour dispute committee summonses served on 22 June 2026. The notices' content was not retained, so the parties, number and subject of the labour disputes are not known.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-001", "src-067" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-5c0cdf9326bfe080ebc9ad5d", "kind": "analysis", "text": "As of 19 October 2026 the register showed a tax debt of EUR 1,997.12 dating from 20 April 2026, made up of VAT of EUR 1,112.12, a penalty payment of EUR 800 and EUR 85 of interest. VAT returns due from 20 May 2026 and income and social tax returns due from 11 May 2026 had not been filed, the 2025 annual report due by 30 June 2026 had not been submitted, and the company reported no taxable turnover and no employees for the third quarter of 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-001" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-096bd8f2aa8d5039188c0c06", "kind": "analysis", "text": "BB Trade Estonia OÜ's own annual reports follow the exchange through three names. The first report, for 30 September 2019 to 31 December 2020, describes the company as operator of the BitBay.net web platform, a fiat-to-crypto exchange on which buyers and sellers of crypto-currencies place orders. The 2021 report gives its main activity as running the Zonda trading platform, rebranded Zonda Global in November 2021. The reports for 2022, 2023 and 2024 describe it as operator of the zondacrypto online exchange at zondacrypto.com, formerly BitBay.net and zondaglobal.com, holding virtual-currency licence FVT000209 under the Estonian Financial Intelligence Unit (Rahapesu Andmebüroo).", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006", "src-003", "src-028", "src-027", "src-013" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-08f74537d2078a2bd469f7a7", "kind": "analysis", "text": "The exchange's terms of service in force from 3 October 2025 name BB Trade Estonia OÜ, with its Tallinn address, registry code 14814864 and licence FVT000209, as provider of the services and operator of the zondacrypto exchange at zondacrypto.com and its subdomains. Section 11 of the same terms allows the provider to be replaced by another entity related to zondacrypto, the previous provider then leaving the agreement with the user, on conditions that may not become less favourable to users. The ZND platform's website, archived in January 2026, likewise named BB Trade Estonia OÜ as offeror of the ZND Token and operator of the exchange.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-039", "src-114" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-cfcf4c9c8896f07c9ef0fb55", "kind": "analysis", "text": "Authorities identify the company in the same way. Finantsinspektsioon, the Estonian Financial Supervision and Resolution Authority, listed zondacrypto.com as the company's webpage in its warning of 6 May 2026, and a release of Poland's National Prosecutor's Office (Prokuratura Krajowa) of 28 August 2026 refers to the ZondaCrypto exchange \"and its operator, BB Trade Estonia OU\". Swiss specialist press in May 2026 also described BB Trade Estonia OÜ as the operating company behind Zondacrypto.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-004", "src-094", "src-096" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-e1928cf54b0dbe52a790f845", "kind": "analysis", "text": "The brand's own documents separate the trademark from the companies that use it. A press release issued for the brand with Incore Bank in January 2025 states that \"zondacrypto\" identifies the services of various group entities, does not in itself refer to any single legal entity and implies no single corporate identity, ownership structure or legal responsibility; it calls the Estonian entity the exchange licensed in Estonia and BB Trade Switzerland AG the brand's Swiss entity. The zondacrypto.com contact page of December 2025 names BB Trade Estonia OÜ as the contracting party for users in the European Economic Area other than Italy, and BB Trade IT in Milan, registered under PSV48 with an Italian VAT number, for Italian users and users outside the European Economic Area.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-113", "src-086" ], "entity_ids": [ "bbte", "bb-switzerland", "incore", "bb-trade-it" ] }, { "id": "display-claim-144da504c4a07e5b3bcefc52", "kind": "analysis", "text": "For Swiss clients the roles were divided by contract. Under the zondacrypto Swiss terms in force from 30 June 2025 each client entered a tripartite agreement with BB Trade Switzerland AG and BB Trade Estonia OÜ: the Swiss company processed the order and was responsible for the fiat part, accepting the client's money and transferring it on the client's behalf to BB Trade Estonia OÜ to close the transaction, or returning it, after holding it for no longer than 30 days without interest or investment; BB Trade Estonia OÜ executed the digital-asset part, including delivering purchased assets and accepting crypto-assets for exchange into fiat. The contact page added that on the Swiss platform funds went directly to the client's wallet or bank account.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-107", "src-086" ], "entity_ids": [ "bbte", "bb-switzerland" ] }, { "id": "display-claim-0d05e9d28e99498eb1be266f", "kind": "analysis", "text": "A press release of 2 July 2025 presented zondacrypto Swiss as a regulated crypto on- and off-ramp operated by BB Trade Switzerland and part of a \"zondacrypto Group\", which it said also operated the zondacrypto exchange, the zondacrypto pay crypto-fiat payment gateway and the ZND platform.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-052" ], "entity_ids": [ "bb-switzerland" ] }, { "id": "display-claim-58eb2e470e3e81221c58baa1", "kind": "analysis", "text": "A law firm acting for claimants in the bankruptcy reconstructs an earlier chain. In its account the exchange was run by BitBay sp. z o.o. in Katowice, by Pinewood Holdings Limited in Malta from May 2018, by Pinewood Estonia OÜ, the subject's former name, from 1 November 2019, and from 2021 by BB Trade Estonia OÜ under the Zonda brand, renamed zondacrypto in 2023. It quotes BitBay's 2019 management report as saying that from November 2019 the Polish company \"has subsisted on fees for the licensing of the operation of the cryptocurrency exchange 'BitBay'\" to BB Trade Estonia OÜ, and says operations moved that month from Pinewood Holdings. The management report is not in the retained record, and no record shows a legal succession between these companies; BB Trade Estonia's own reports describe it as operator of BitBay.net in 2019–2020, of Zonda in 2021 and of zondacrypto from 2022.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-008", "src-088" ], "entity_ids": [ "bbte", "bitbay", "pinewood-holdings" ] }, { "id": "display-claim-d62cd9e34de2bad427193003", "kind": "analysis", "text": "Polish National Court Register (KRS) data reproduced by an aggregator show BitBay sp. z o.o. (KRS 0000373405) registered in Warsaw on 16 December 2010, based in Katowice from 14 March 2014 and with share capital of PLN 105,000 from 26 July 2018. Sylwester Jan Suszek was its commercial proxy (prokurent) from 28 May 2014 and its chief executive from 21 September 2017 until the company was struck off on 17 February 2026. From 26 July 2018 its shareholders were three Dubai companies, Arial Investment, Central Bay Investment and Skybay Investment in Commercial Enterprises; changes in Arial's holding were published in November 2018 and May 2020, and the three ceased to be shareholders at the striking-off.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-023", "src-015" ], "entity_ids": [ "bitbay", "suszek", "arial", "central-bay", "skybay" ] }, { "id": "display-claim-e5c78a6fc37b5a88ac3aedf6", "kind": "analysis", "text": "The claimants' law firm says it obtained Dubai Department of Economy register printouts showing Suszek as partner (49%) and manager of Skybay, while Arial had a different individual as partner and manager and moved to Skybay's office on 9 May 2018; a local sponsor held the other 51% of each. Citing BitBay's accounts, the firm puts Skybay's stake at 47% in December 2017 and 44.8% (940 of 2,100 shares) in 2019, Arial's at 38.5% and 41.4%, and Central Bay's at 13.8%, and says BitBay's largest shareholder has had no active manager since Suszek disappeared in March 2022. The firm calls the earlier press thesis that all three Dubai companies were Suszek's a simplification and holds no documents on Central Bay; the printouts, accounts and court files it cites are not in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-074" ], "entity_ids": [ "suszek", "skybay", "arial", "central-bay", "bitbay" ] }, { "id": "display-claim-9e0d5570afa91546f9c6a63b", "kind": "analysis", "text": "The public-warning list of the Polish Financial Supervision Authority (KNF) includes BitBay sp. z o.o., entered on a notification of suspected crime made by the KNF Office under Article 150(1) of the Act on payment services, with the Regional Prosecutor's Office in Katowice as competent prosecutor. The Provincial Prosecutor's Office in Katowice discontinued that investigation on 15 June 2022, and the decision became final and binding on 12 May 2023.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-077" ], "entity_ids": [ "bitbay" ] }, { "id": "display-claim-2c7e8fcf084220250883dba2", "kind": "analysis", "text": "Malta Business Registry data reproduced by commercial aggregators show Pinewood Holdings Limited (C 86244) incorporated on 10 May 2018 with 1,200 issued shares (EUR 1,200) at an address in Mosta; a snapshot updated in February 2025 lists Paweł Sobków and Sylwester Suszek as directors and Luxbay S.A. as shareholder. Reading the Maltese registry file, the claimants' firm states that Sobków was the first and sole shareholder and first director, that the capital was paid on 7 May 2018 by a transfer from a Polish payment institution, that Sobków resigned on 22 June 2021 leaving Suszek as sole director, that the company never filed financial statements and that its corporate-service provider ended its services on 26 June 2022; the registry documents themselves are not in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-058", "src-021", "src-088" ], "entity_ids": [ "pinewood-holdings", "sobkow", "suszek", "luxbay" ] }, { "id": "display-claim-19c10bf9e65b4421d6bb3a91", "kind": "analysis", "text": "The same firm states that Pinewood Holdings never applied to the Malta Financial Services Authority for a virtual financial assets licence and appears on none of the regulator's lists of applicants, and concludes that the brand's Maltese entity held no Maltese licence; the regulator's lists are not in the retained record. The firm recalls that in 2018 Suszek publicly announced BitBay's relocation to Malta, citing friendly regulation and a forward-looking licensing framework, and called the KNF's public warning on BitBay an act of repression rather than consumer protection. No reply by Pinewood, Suszek or BB Trade Estonia to the registry findings is in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-088" ], "entity_ids": [ "pinewood-holdings", "suszek" ] }, { "id": "display-claim-aa7576b5db8e991e692c76a9", "kind": "analysis", "text": "Two other companies link the earlier owners. Creative Invest Int OÜ, registered in Tallinn on 19 February 2018 with Suszek as sole shareholder and management board member, has as its registered address Lõõtsa tn 5, which BB Trade Estonia OÜ used until April 2020, and the contact e-mail address given in BB Trade Estonia's 2019–2020 annual report; the register shows unpaid fines imposed by the registration department of Tartu County Court and no annual report filed for 2018 to 2025.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-056", "src-006" ], "entity_ids": [ "suszek", "creative-invest", "bbte" ] }, { "id": "display-claim-883f6f1d56490d42de13726d", "kind": "analysis", "text": "ICO HOUSE S.A. in Warsaw, registered on 6 July 2018 with PLN 100,000 of share capital, has had Paweł Sobków as sole shareholder and beneficial owner since that day, and its supervisory board appointed the same day consisted of Sobków, Sylwester Suszek and Wojciech Sroka. The KRS data do not show the company's business or any dealings with BitBay sp. z o.o. or BB Trade Estonia OÜ.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-101" ], "entity_ids": [ "ico-house", "sobkow", "suszek", "sroka" ] }, { "id": "display-claim-20ecbd2474fd448f42edfc7d", "kind": "analysis", "text": "According to the company's first annual report, Paweł Sobków was its sole participant and chief executive until 13 February 2020, when he transferred the entire holding to LUXBAY S.A., a Luxembourg company at Place de Strasbourg 2; Sylwester Jan Suszek thereby became the ultimate beneficial owner, and the report names LuxBay S.A. as parent undertaking. Luxembourg register data reproduced by an aggregator show Luxbay SA (RCS B237593) registered on 4 September 2019 with capital of EUR 30,000 and terminated on 31 December 2025, with Suszek among its directors from 9 July 2021 until the termination.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006", "src-047" ], "entity_ids": [ "bbte", "sobkow", "luxbay", "suszek" ] }, { "id": "display-claim-13867d75300d3cbda02ac673", "kind": "analysis", "text": "The register's publication history, as reproduced by an aggregator, records the steps: the previous shareholder left and Luxbay SA was entered on 27 April 2020; Luxbay's holding changed with the capital increases of 22 May and 24 September 2020; and on 14 July 2021 Divisio Holding AG was entered as shareholder and Luxbay left. Beneficial-owner updates follow on 28 April 2020, 16 July 2021 and 8 March 2022, and a change in Divisio's holding on 30 March 2022. These entries, which follow the transfers described in the annual reports, show Luxbay as shareholder of BB Trade Estonia, as the reports do.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-104" ], "entity_ids": [ "bbte", "luxbay", "divisio" ] }, { "id": "display-claim-bcab537cfa4d2618a076dee7", "kind": "analysis", "text": "The 2021 annual report states that in July 2021 a share-transfer agreement gave a Swiss company the shares and made Przemysław Kral the ultimate beneficial owner, a change published in the Estonian register on 15 July 2021, and that the parent undertaking from that month was DIVISIO HOLDING AG; the 2024 report still names Divisio Holding A.G. as parent. The current register card lists Divisio (CHE-161.370.248) as sole owner of the EUR 350,000 holding with the date 30 March 2022, and Kral as beneficial owner through an indirect holding from 8 March 2022, updated on 29 July 2025, noting that these data are informative. The card's dates differ from the July 2021 change in the annual reports and from the publication history, which lists Divisio's entry on 14 July 2021 and updates on 8 and 30 March 2022; the retained records do not explain the difference.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003", "src-013", "src-001" ], "entity_ids": [ "bbte", "divisio", "kral" ] }, { "id": "display-claim-82cf9908210cdbdc6bb4f29a", "kind": "analysis", "text": "The Swiss register publications do not disclose who owns Divisio. A law firm acting for claimants quotes the ZND token white paper of 27 June 2024 (page 11) as stating that \"the sole shareholder of DIVISIO HOLDING AG is Przemysław Kral, CEO of zondacrypto\", describes Divisio as a holding company without a business of its own, and says the group had a single ultimate beneficiary, Kral, with no outside investors holding voting rights; the white paper itself is not in the retained record, while the Estonian register separately records Kral as beneficial owner through an indirect holding. The firm adds that only in March 2025 was a three-member supervisory board of Guido Bühler, Georgi Džaniašvili and Giorgio Chiellini announced, and the 2024 annual report confirms that such a board was formed then to prepare an application under the EU Markets in Crypto-Assets Regulation (MiCA).", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-008", "src-013" ], "entity_ids": [ "divisio", "kral", "bbte", "buhler", "dzaniasvili", "chiellini" ] }, { "id": "display-claim-f37fe62067bd849d023921ed", "kind": "analysis", "text": "Divisio Holding AG (also Divisio Holding SA and Divisio Holding Ltd.; register number CH-170.3.045.992-5) was entered in the commercial register of the canton of Zug on 24 June 2021, as published in the Swiss Official Gazette of Commerce (SHAB) on 29 June 2021. Its articles are dated 14 June 2021, its purpose is holding and managing participations and allows loans to its direct or indirect shareholders or subsidiaries, and its CHF 100,000 of capital is divided into 1,000 registered shares with restricted transferability whose holders are kept in a share register the publication does not disclose. It opted out of a limited audit.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-005", "src-099" ], "entity_ids": [ "divisio" ] }, { "id": "display-claim-a18b7026c48735943b23d2cd", "kind": "analysis", "text": "André Terlinden was entered at incorporation as Divisio's only board member, with sole signature. The company's domicile moved from c/o Afrag AG, Chamerstrasse 14, to c/o Dr. André Terlinden, Baarerstrasse 78, Zug, in July 2022. SHAB published Terlinden's departure from the board on 27 April 2026, and a register summary retrieved in October 2026 shows no registered managers and no information on the ownership structure. The same kind of summary counts 119 other active companies at the Baarerstrasse 78 address, which by itself does not link them, and an aggregator lists the legal entity identifier 506700IIY4O9G6R2AS52 for Divisio.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-005", "src-099", "src-002", "src-063" ], "entity_ids": [ "divisio", "terlinden" ] }, { "id": "display-claim-6a80898481a2bd303283eb55", "kind": "analysis", "text": "Divisio also holds a company of the brand directly: Slovak commercial-register publications of 13 January and 7 April 2026, as indexed by an aggregator, list it as a partner (shareholder) of zondacrypto SK s.r.o. A Polish news report of 27 April 2026 described Terlinden as Divisio's only director and as a partner and shareholder of the law firm Neupert Vuille Partners AG, at whose premises it reported several hundred entities to be registered; that list is not in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-063", "src-091" ], "entity_ids": [ "divisio", "zondacrypto-sk", "terlinden", "nvp" ] }, { "id": "display-claim-83b5dc58fcc6e38da95eb687", "kind": "analysis", "text": "The claimants' law firm, citing the company's records, says Luxbay held BB Trade Estonia until 12 July 2021, a day the annual reports do not give, and that Divisio, which it says belongs to Kral, invoiced BB Trade Estonia for services of EUR 200,000 in 2023 and EUR 400,000 in 2024. It adds that BB Trade Switzerland invoiced EUR 200,000 in 2023 and that Terlinden received EUR 100,200 from the exchange in 2023 while his advisory firm billed domicile and directorship fees. The invoices are not in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-010" ], "entity_ids": [ "bbte", "divisio", "kral", "luxbay", "bb-switzerland", "terlinden" ] }, { "id": "display-claim-1bb35af1804de3ae641f185e", "kind": "analysis", "text": "In the company's first financial period the management board consisted, until 13 February 2020, of Dawid Grzegorz Sendecki, Sylwester Jan Suszek and Paweł Łukasz Sobków. Sobków resigned in spring 2020, leaving Suszek as chairman and Sendecki, and Suszek signed that period's annual report on 24 September 2021. The 2021 report gives Sendecki as a board member from June 2021 and the chief executive, Przemysław Kral, as the second member from November 2021; both signed it on 30 November 2022. The retained records do not explain why the 2021 report dates Sendecki's membership from June 2021 when the earlier report already lists him on the board in 2020.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006", "src-003" ], "entity_ids": [ "bbte", "sendecki", "suszek", "sobkow", "kral" ] }, { "id": "display-claim-096c39ac308de4649c728188", "kind": "analysis", "text": "According to the 2022 report, the board from 10 December 2023 had three members, Kral, Sendecki and Guido Bühler, all of whom signed that report on 12 January 2024; the 2023 report, signed by Kral alone on 30 June 2024, lists the same board at the end of 2023. The 2022 report also records that a new money laundering reporting officer, Reet Jurik, was appointed and approved by the Estonian Financial Intelligence Unit (FIU) in 2023.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028", "src-027" ], "entity_ids": [ "bbte", "kral", "sendecki", "buhler", "jurik" ] }, { "id": "display-claim-511d46e1f7aef15b37418be1", "kind": "analysis", "text": "The register card records a rule from 8 November 2021 under which BB Trade Estonia OÜ is represented by Kral alone or by two board members jointly, one of whom must be Kral. The Polish National Court Register (KRS) entry of the company's Polish branch, made on 16 December 2024, repeats that rule, lists the parent's board as Kral, Sendecki and Bühler and enters Kral as branch director. The same section of the Estonian card also states that no special representation rules are currently in force, without showing when the rule ceased to apply; since 28 August 2026 the trustee in bankruptcy disposes of the estate.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-001", "src-009" ], "entity_ids": [ "bbte", "kral", "bbte-pl-branch", "sendecki", "buhler" ] }, { "id": "display-claim-3f8c7066537b8296b2208d6e", "kind": "analysis", "text": "Retrieved on 19 October 2026, the card lists Przemysław Janusz Kral as a management board member since 8 November 2021 and Margus Lentsius as trustee in bankruptcy (pankrotihaldur) since 28 August 2026, noting that the trustee disposes of the bankruptcy estate; it shows no current supervisory board members.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-001" ], "entity_ids": [ "bbte", "kral", "lentsius" ] }, { "id": "display-claim-d80a9cd8a231526544ed6806", "kind": "analysis", "text": "The 2024 annual report, signed by Kral alone on 29 July 2025 and approved by the shareholders' meeting, states that the board at the end of 2024 was Kral, Sendecki and Bühler, and that in March 2025, while preparing an application under the EU Markets in Crypto-Assets Regulation (MiCA), the company changed its structure: a management board of Kral and Sendecki, and a supervisory board (nõukogu) of Guido Bühler, Georgi Džaniašvili and Giorgio Chiellini. Register publications listed by an aggregator show a supervisory-board chair and two members entered on 17 March 2025, a management board member leaving on 24 March 2025 and a change of chair on 10 September 2025. Those entries name the persons only as \"N.N.\"; the names come from the annual report and the board's later statement.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013", "src-104" ], "entity_ids": [ "bbte", "kral", "sendecki", "buhler", "dzaniasvili", "chiellini" ] }, { "id": "display-claim-54bb670339e6a065e13904a1", "kind": "analysis", "text": "Records describe Bühler's capacity before March 2025 differently. The 2022 and 2023 annual reports list him as a management board member from 10 December 2023, and he signed the 2022 report in that capacity; Swiss financial press reported in October 2023, citing a press release, that he would be a non-executive director in the management of Zondacrypto; a law firm acting for claimants says he joined the supervisory board that October as a non-executive director. The 2024 report places him on the management board until March 2025 and on the new supervisory board afterwards, and no register entry for a supervisory board before March 2025 was retained.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-098", "src-028" ], "entity_ids": [ "bbte", "buhler" ] }, { "id": "display-claim-b74f5498901e55fc12aad69a", "kind": "analysis", "text": "The same law firm states that the company's 2023 related-party statement lists Bühler as a director of BB Trade Estonia and of BB Trade Switzerland, and his company Giloca AG of Zug as a supplier of services worth EUR 101,316 in 2023 and EUR 244,100 in 2024. Swiss register data show Giloca AG, formerly Giloca Real Estate AG, registered in Zug on 30 April 2015, with Bühler among the three members of its management. The amounts are the firm's reading of the company's accounts; the related-party note itself was not retained, and the Swiss register shows nothing about Giloca's owners.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-010", "src-069" ], "entity_ids": [ "bbte", "buhler", "giloca", "bb-switzerland" ] }, { "id": "display-claim-d20e2f56766c3f855f561dcd", "kind": "analysis", "text": "A Polish news report of 20 April 2026 said that Dawid Sendecki, management board member and director of risk and compliance, had announced his departure a few days earlier; according to his professional profile as cited in the report, he was money laundering reporting officer from January 2020 to April 2024 and then director of risk and compliance. As the report relayed his post, which itself was not retained, Sendecki said he had no involvement with client funds other than in his anti-money-laundering role, that managing them and liquidity had always been the chief executive's role, and that he learned only that week, together with everyone else, that there were no private keys to the funds declared as the company's reserve. Register publications record that his board membership ended on 28 August 2026, when bankruptcy proceedings opened.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-025", "src-104" ], "entity_ids": [ "bbte", "sendecki" ] }, { "id": "display-claim-0520cecba6284a61e52d554e", "kind": "analysis", "text": "In a statement published on 20 April 2026, the supervisory board members, Veronika Tugo as chair (spelled Togo in the statement), Guido Bühler and Georgi Džaniašvili, said that each had resigned independently that week; that the board learned of the situation only from public sources after it escalated in the Polish media; that material inconsistencies had emerged between certain public statements, operational realities and the information previously given to the board; and that in a structure where ownership and executive management were concentrated in one individual, whom they did not name, the trust needed for oversight had been materially undermined. They added that all their decisions as board members had been taken in good faith on the information then available, including auditor reports and the MiCA-related regulatory process. Register publications record members and the chair leaving on 15 and 17 April 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-044", "src-025", "src-104" ], "entity_ids": [ "bbte", "tugo", "buhler", "dzaniasvili" ] }, { "id": "display-claim-8b02bb85cd102eb566337b6a", "kind": "analysis", "text": "On 6 May 2026 Finantsinspektsioon, the Estonian Financial Supervision and Resolution Authority, still listed Dawid Grzegorz Sendecki and Przemysław Janusz Kral as the management board in its public warning about the company.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-004" ], "entity_ids": [ "bbte", "sendecki", "kral" ] }, { "id": "display-claim-e95529c8739ef450a0926d27", "kind": "analysis", "text": "The court's registration department handled filings for the company during the crisis. In file Ä 50129412 it ordered deficiencies in an application to be remedied on 29 April 2026 and refused the requested entry on 15 May 2026 because they had not been remedied, then issued a procedural order on 10 July 2026, made an entry on 28 July 2026 to implement another court decision and an ex officio entry on 28 August 2026. The listing does not say what the applications or entries concerned.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-024" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-1c30f5964231baef4edf016b", "kind": "analysis", "text": "Divisio Holding AG (Swiss identifier CHE-161.370.248) was entered in the Zug commercial register on 24 June 2021 with CHF 100,000 of capital in 1,000 registered shares with restricted transferability. Its purpose is holding and managing participations, including loans to its shareholders or subsidiaries; it opted out of a limited audit, and its shareholders are kept in a share register that the SHAB publication does not disclose. It is registered at Baarerstrasse 78 in Zug, an address shared with 119 other active companies, which by itself does not link them, and an aggregator lists the legal entity identifier 506700IIY4O9G6R2AS52 for it.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-005", "src-099", "src-002", "src-063" ], "entity_ids": [ "divisio" ] }, { "id": "display-claim-732fb315156fd67fe5d219a0", "kind": "analysis", "text": "Its board has had one member: André Terlinden, with sole signature, from incorporation until SHAB published his departure on 27 April 2026, after which a register summary showed no registered managers. A Polish news report described Terlinden as a partner and shareholder of the law firm Neupert Vuille Partners AG. Swiss financial press reported in April 2026 that one partner of that firm sat alone on Divisio's board and another on the board of BB Trade Switzerland; the article named neither, the registers show Terlinden and Timo Fenner in those seats, and the report said both left the outlet's requests unanswered.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-005", "src-099", "src-091", "src-106", "src-080" ], "entity_ids": [ "divisio", "terlinden", "nvp", "bb-switzerland", "bbte", "fenner" ] }, { "id": "display-claim-06c97f51c951a1ca71daab82", "kind": "analysis", "text": "Divisio became BB Trade Estonia OÜ's parent in July 2021, according to the annual reports, in place of Luxbay SA. The current register card shows it as sole owner of the EUR 350,000 holding with the date 30 March 2022, a date that differs from the July 2021 change in the annual reports and from the register's publication history, which lists Divisio's entry on 14 July 2021; the retained records do not explain the difference.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003", "src-013", "src-001" ], "entity_ids": [ "bbte", "divisio", "kral" ] }, { "id": "display-claim-e6bcafc157f515951c0e2596", "kind": "analysis", "text": "Divisio also holds companies of the brand directly, making them sister companies of BB Trade Estonia rather than its subsidiaries. The Slovak commercial register extract shows it as sole shareholder of zondacrypto SK, s. r. o. since 22 April 2023 with a EUR 5,000 contribution, and register publications of 2026 also list it as a partner there. KRS data list it as sole shareholder of BB Trade Poland sp. z o.o., which an extraordinary meeting dissolved on 15 September 2025 and which has since been in liquidation with Kral as liquidator, its 2024 accounts showing assets of PLN 5 thousand and no revenue.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-051", "src-063", "src-007", "src-059", "src-002" ], "entity_ids": [ "zondacrypto-sk", "divisio", "bbte", "bb-poland", "kral", "orion" ] }, { "id": "display-claim-9993615f7cf4f9503fd3789b", "kind": "analysis", "text": "An aggregator's network view also shows Divisio as current 100% shareholder of EXPOFÉR SERVIS HOUSE s.r.o. in Ostrava, with Luxbay SA as a former one, and its summary of a Czech register publication of 23 April 2024 names Divisio, Luxbay and ADMI BUSINESS SERVIS s.r.o. in a change of shareholdings. The aggregator states that the direction and identity of these links are not verified, and the Czech register extract was not retained, so the sequence and dates of the holdings are not shown.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-007", "src-063", "src-002" ], "entity_ids": [ "expofer", "divisio", "luxbay", "admi-business" ] }, { "id": "display-claim-07731da413111ef984b31a91", "kind": "analysis", "text": "No retained register shows who owns Divisio. A law firm acting for claimants quotes the ZND token white paper of 27 June 2024 as naming Przemysław Kral, chief executive of zondacrypto, as its sole shareholder; the white paper is not in the retained record, while the Estonian register records Kral as BB Trade Estonia's beneficial owner through an indirect holding.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-008" ], "entity_ids": [ "divisio", "kral" ] }, { "id": "display-claim-3182854e2f3b7e62e224a6c9", "kind": "analysis", "text": "The same firm, citing the company's records, reports that Divisio invoiced BB Trade Estonia for services of EUR 200,000 in 2023 and EUR 400,000 in 2024 and that Terlinden received EUR 100,200 from the exchange in 2023 while his advisory firm billed domicile and directorship fees; it dates Divisio's takeover from Luxbay to 12 July 2021. The invoices are not in the retained record. BB Trade Estonia's own annual reports show that it lent Divisio EUR 2,700,000 in 2021 at 2%, due 2041, and that the loan was repaid with interest during 2022.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-010", "src-003", "src-028", "src-027" ], "entity_ids": [ "bbte", "divisio", "kral", "luxbay", "bb-switzerland", "terlinden" ] }, { "id": "display-claim-b5da2ab6132594f1a14650c0", "kind": "analysis", "text": "Polish register publications reproduced by an aggregator record Suszek as commercial proxy (prokurent) of BitBay sp. z o.o. in Katowice from 28 May 2014 and as its chief executive from 21 September 2017 until the company was struck off on 17 February 2026. Dubai register printouts described by a law firm acting for claimants show him as partner (49%) and manager of Skybay Investment in Commercial Enterprises L.L.C., the largest of BitBay's three Dubai shareholders, but not of Arial; the firm calls the earlier press thesis that all three companies were his a simplification, and the printouts are not in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-015", "src-074" ], "entity_ids": [ "suszek", "bitbay", "skybay", "arial", "central-bay" ] }, { "id": "display-claim-02ca403916aa5d5bb5c89c23", "kind": "analysis", "text": "Maltese register data list him, with Paweł Sobków, as a director of Pinewood Holdings Limited, whose shareholder they show as Luxbay S.A. The claimants' firm states that Pinewood never applied for a Maltese licence, relying on regulator lists that were not retained, and recalls that in 2018 Suszek announced BitBay's relocation to Malta, citing friendly regulation and a forward-looking licensing framework, and called the KNF's public warning on BitBay an act of repression rather than consumer protection; no reply by Pinewood, Suszek or BB Trade Estonia to the registry findings is in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-058", "src-021", "src-088" ], "entity_ids": [ "pinewood-holdings", "sobkow", "suszek", "luxbay" ] }, { "id": "display-claim-58a33f73b11e94bf165c8447", "kind": "analysis", "text": "According to BB Trade Estonia OÜ's first annual report, Suszek became its ultimate beneficial owner when Paweł Sobków transferred all its shares to LUXBAY S.A. after 13 February 2020. He sat on the management board, chaired it from spring 2020 and signed the 2020 report on 24 September 2021. Luxembourg register publications reproduced by an aggregator list him as a director of Luxbay SA in July 2021 and of S&B Investment SA from 9 July 2021 to 14 November 2023, when Przemysław Kral became one of its directors; the company has had further directors who are not named here.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006", "src-015", "src-022", "src-007" ], "entity_ids": [ "bbte", "sobkow", "luxbay", "suszek", "sendecki", "sb-investment", "kral" ] }, { "id": "display-claim-09b0590a422230f5b20cedf5", "kind": "analysis", "text": "The claimants' law firm describes an 80-page statement of 18 June 2021, signed by Suszek as chairman, certifying the exchange's wallets at 31 December 2020: 4,513.93 BTC in the cold wallet, 308.48 BTC in the hot wallet and 51,646.73 ETH in the cold ether wallet, the bitcoin figures taken from the exchange's internal Funds Monitor system. The statement was not retained and, according to the firm, gives no bitcoin address, so it cannot be matched to the 4,503 BTC address cited in 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte", "suszek" ] }, { "id": "display-claim-46e1788435618d66f3d4bf19", "kind": "analysis", "text": "In Tallinn he is sole shareholder and board member of Creative Invest Int OÜ, whose registered address and contact e-mail are those BB Trade Estonia OÜ used in 2019–2020; the register shows unpaid fines and no annual report filed for 2018 to 2025. Swiss register publications record him on the board of BB Trade Switzerland AG until 24 March 2022, and in 2018 he joined the supervisory board of ICO HOUSE S.A. in Warsaw with Paweł Sobków and Wojciech Sroka; the KRS data show no dealings of that company with BitBay or BB Trade Estonia.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-056", "src-006", "src-016", "src-101" ], "entity_ids": [ "suszek", "creative-invest", "bbte", "bb-switzerland", "terlinden", "fenner", "ico-house", "sobkow", "sroka" ] }, { "id": "display-claim-65b7d7805810af3cb4a68e58", "kind": "analysis", "text": "Reading the exchange's contracts and ledger, the claimants' firm says that in summer 2020 S.B. Bay FZE, a free-zone company in Umm Al Quwain owned and directed by Suszek, borrowed EUR 500,000, PLN 495,000 and PLN 200,000 from the exchange operator at 2% until 2030, with Suszek signing for both sides and crypto-assets on bitbay.net pledged, and that nothing had been repaid by the end of 2023. It also reports EUR 1,041,826.22 and PLN 1,323,493.15 received in June 2023 from a sender named \"Sylwester Jan Suszek\" with a Zug address, about fifteen months after his disappearance, which the company's lawyer explained to its accountant as repayments of four personal loans; the firm calls its reading of who controlled that account a hypothesis that only prosecutors can resolve. The documents are not in the retained record and no reply by the persons concerned is recorded.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte", "sb-bay", "suszek", "amina" ] }, { "id": "display-claim-160a7e8454de2644f7f5364a", "kind": "analysis", "text": "The same firm identifies a EUR 2,878,500 loan in the 2021 and 2022 annual reports, which do not name the borrower and describe the loan as secured by a mortgage, as a credit line of EUR 2,910,000 that Suszek signed for the company on 24 May 2021 with a private individual, Jaromira W., for the purchase of real estate. Relying on the agreement and the ledger, which are not in the retained record, the firm says it is not known whether the mortgage was created; no reply by the persons concerned is recorded. In September 2026 Polish prosecutors charged Jaromira W. with, among other things, obtaining a confirmation of repayment of a 2.9 million EUR loan that had in fact not been repaid; she did not plead guilty.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083", "src-003", "src-103" ], "entity_ids": [ "bbte", "suszek" ] }, { "id": "display-claim-ad8b3a6ae9f3e98b9adef596", "kind": "analysis", "text": "The National Prosecutor's Office states that an investigation into the unlawful deprivation of liberty of Sylwester Suszek, founder of the BitBay exchange, was opened on 18 March 2022 by the District Prosecutor's Office in Sosnowiec and taken over by its Katowice branch for organised crime and corruption (case 1001-109.Ds.77.2022), and that the Katowice investigation into ZondaCrypto was merged into it because both examine the founding and activity of BitBay, later ZondaCrypto. The two official texts give different merger dates, 19 July and 30 July 2026. When the Katowice investigation was opened on 17 April 2026, prosecutors summarised a statement by the exchange's owner that the exchange had had no access to its cold wallet since 2022 and had concealed this from clients; that is a summary, not a finding, and the release does not say how or when access was lost. Przemysław Kral, who earlier in April had called the exchange stable, solvent and safe and rejected a press analysis of a 99% fall in its bitcoin reserves, said publicly on 16 April that the keys to the roughly 4,500-bitcoin wallet were held by Suszek, who has been missing since March 2022.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-094", "src-102", "src-065", "src-112" ], "entity_ids": [ "suszek", "bbte", "kral" ] }, { "id": "display-claim-d09ad52b85c128e5dab7c5ec", "kind": "analysis", "text": "Charges brought since then name Suszek as a target, not as a suspect. Prosecutors charged Anna P. in September 2026 with taking part in 2020–2026 in an organised group aimed at taking over his assets and with obstructing the deprivation-of-liberty proceedings, and Jaromira W. with membership of the same group; neither admitted the charges, and both were remanded in custody for three months on 4 September 2026; a legal news site reported that the regional court in Katowice upheld the custody decisions. These are charges, not findings of guilt.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-103", "src-095" ], "entity_ids": [ "bbte", "suszek" ] }, { "id": "display-claim-d36b4998789c90cfdee5aba3", "kind": "analysis", "text": "A legal news site, citing a television report, stated that Marian W. faces charges of depriving Suszek of his liberty, first brought on 15 March 2022, of acting to the detriment of BB Trade Estonia OÜ, of leading an organised group intended to take over the assets of Suszek and companies he controlled, including Luxbay S.A., S&B Investment S.A. and BB Trade Estonia OÜ, and of money laundering. These charges are reported second-hand, the prosecutors' retained releases do not list them, and no plea is recorded.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-095", "src-112" ], "entity_ids": [ "suszek", "bbte", "luxbay", "sb-investment" ] }, { "id": "display-claim-80b99c510e495cb9a1b8f405", "kind": "analysis", "text": "BB Trade Estonia OÜ's consolidated annual report for 2024 names five members of its consolidation group: ZND Ventures OÜ (Estonia, from 2024), Zonda Token AG (Switzerland, from 2022), Orion Software sp. z o.o. (Poland, from 2022), BB Trade Estonia Italian Branch (Italy, from 2024) and BB Trade Bahamas Ltd (Bahamas, from 2024).", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte", "znd-ventures", "zonda-token", "orion", "bb-trade-it", "bb-bahamas" ] }, { "id": "display-claim-6d142b1b998c08e32ca2a0c8", "kind": "analysis", "text": "The notes to the same report list three subsidiaries and one associate. Zonda Token AG (consulting services) and Orion Software (IT services) were held at 100% at the end of both 2023 and 2024; the stake in ZND Ventures OÜ (programming) was 50% at the end of 2023 and 100% at the end of 2024; ZND.CO OÜ was an associate held at 50% at both dates. During 2024 the carrying amount of the Orion Software shares rose from EUR 12,975,010 to EUR 19,272,407 and that of ZND Ventures from EUR 1,250 to EUR 2,510,000.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte", "zonda-token", "orion", "znd-ventures", "znd-co" ] }, { "id": "display-claim-e921566f987c2bfb6c13d8f6", "kind": "analysis", "text": "According to BB Trade Estonia OÜ's 2021 annual report, the company acquired 100% of Zonda Token AG, a Swiss company in crypto services, on 7 December 2021 at a cost of EUR 105,627, and Zonda Token AG did not operate actively in the 2021 financial year. Swiss commercial register publications of 14 December 2021 record its incorporation in Zug, with articles dated 30 November 2021, an address c/o Afrag AG, Chamerstrasse 14, Zug, and share capital of CHF 100,000 in 1,000 registered shares. Its stated purpose includes holding participations and, to finance group companies, issuing tokens carrying rights to services or products of parent, subsidiary or affiliated companies. André Marcel Terlinden was entered as president of the board with sole signature, and Karolina Ewa Gwóźdź and Przemysław Janusz Kral as board members without signing authority. Its Swiss enterprise identifier (UID) is CHE-221.704.071.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003", "src-026", "src-062" ], "entity_ids": [ "bbte", "zonda-token", "terlinden", "gwozdz", "kral" ] }, { "id": "display-claim-48f5ee8ef7561f9b866ede65", "kind": "analysis", "text": "The records do not agree on when Zonda Token AG joined the group. The 2021 report's acquisition date of 7 December 2021 falls two days before the company's entry in the Swiss commercial register on 9 December 2021; the 2024 report lists it in the consolidation group from 2022; and a law firm acting for claimants in the bankruptcy states that it was brought into the group in January 2022, the month of a domicile change, describing it as wholly owned by BB Trade Estonia, with Kral and Karolina Gwóźdź on its board and an obscure operational role. The retained records do not explain the sequence: a company can be subscribed before it is registered, and none of the records contains the share transfer itself. The company was itself dissolved by a Zug court on 6 August 2026, and its bankruptcy proceedings were suspended for lack of assets on 29 September 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-008", "src-013", "src-062" ], "entity_ids": [ "zonda-token", "bbte", "kral", "gwozdz" ] }, { "id": "display-claim-0e2eaf98ee9e303f82a2d782", "kind": "analysis", "text": "A publication of 2 September 2026 in the Swiss Official Gazette of Commerce (SHAB) records that on 6 August 2026 a single judge of the Cantonal Court of Zug dissolved Zonda Token AG under Article 731b of the Swiss Code of Obligations, the provision on deficiencies in a company's legally required organisation, and ordered its liquidation under bankruptcy rules; the company was renamed Zonda Token AG in Liquidation. André M. Terlinden had ceased to chair its board on 11 May 2026, and the board members remaining on the register are Karolina Ewa Gwóźdź and Przemysław Janusz Kral. The bankruptcy office of the Canton of Zug published a preliminary bankruptcy notice on 3 September 2026 and, on 1 October 2026, a notice suspending the proceedings as of 29 September 2026 for lack of assets: they would be closed unless a creditor requested their continuation and advanced CHF 5,000 by 21 October 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-062", "src-016" ], "entity_ids": [ "zonda-token", "terlinden", "gwozdz", "kral" ] }, { "id": "display-claim-c08295bf751a269f3758dbec", "kind": "analysis", "text": "Orion Software sp. z o.o. is a Polish limited company (KRS 0000827257, tax number NIP 9542811828, statistical number REGON 385348160) registered on 7 February 2020 at Aleja Wojciecha Korfantego 141B, Katowice, with share capital of PLN 3 million. Polish National Court Register (KRS) data reproduced by a commercial aggregator, current after entry no. 18 of 21 September 2026, list BB Trade Estonia OÜ as its sole shareholder with 60,100 shares worth PLN 3 million, and Przemysław Janusz Kral as president of the management board since 26 March 2020 and as its beneficial owner. The beneficial-owner entry describes Kral as the company's president; the KRS data do not show him holding shares in Orion directly.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-055", "src-033", "src-034" ], "entity_ids": [ "orion", "bbte", "kral", "trypay", "femion" ] }, { "id": "display-claim-0236ed68fa647f6def83bf46", "kind": "analysis", "text": "A commercial aggregator's rounded summary of Orion Software's own filed financial statements for 2024 gives total assets of PLN 258.1 million, revenue of PLN 19.7 million, costs of PLN 18.4 million and a profit of PLN 1.1 million; the statements themselves and any audit report were not retained. Under the company's articles as recorded in the KRS, each management board member may represent the company alone.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-055" ], "entity_ids": [ "orion" ] }, { "id": "display-claim-5aa632887c6543a044eda343", "kind": "analysis", "text": "ZND Ventures OÜ (registry code 16382854) was registered in Estonia on 6 December 2021 under earlier names Norion OÜ and Stenotype OÜ, with share capital of EUR 10,000 and the address Tähesaju tee 9, Tallinn. Its register card, retrieved on 19 October 2026, shows BB Trade Estonia OÜ as sole shareholder from 10 January 2024, and Przemysław Janusz Kral as procurator (prokurist) from 28 June 2023, management board member from 20 April 2026 and beneficial owner through indirect holding from 20 September 2022. BB Trade Estonia OÜ's 2022 annual report states that it held 50% of the company at the end of 2022, carried at EUR 792,000 because payments had been made under an investment agreement, and that after the balance-sheet date, on 10 January 2024, it acquired a 100% holding.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-045", "src-028" ], "entity_ids": [ "znd-ventures", "bbte", "kral" ] }, { "id": "display-claim-20ecf1d3af69bd3178f1bdb4", "kind": "analysis", "text": "A law firm acting for claimants in the bankruptcy, reading BB Trade Estonia's accounts and general ledger, states that ZND Ventures first appeared in 2022 as an associate owned half by BB Trade Estonia and half by ICEO RED Venture Builder OÜ, a company of Wojciech Sroka, at a nominal value of EUR 1,250 against an investment cost of EUR 792,000; that the investment was shown at EUR 4,914,500 in the 2023 notes and EUR 4,924,500 in the balance sheet; that conversions of the investment agreement into reserve capital of EUR 2,500,000 (December 2024) and EUR 2,414,500 (May 2025) followed; and that once the stake became 100% in 2024 at a book value of EUR 2,510,000 the rest of the funding was carried as intercompany loans and receivables. This is the firm's reading of accounting records obtained in the bankruptcy; the general ledger is not in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-010" ], "entity_ids": [ "bbte", "znd-ventures", "iceo-red-0", "sroka" ] }, { "id": "display-claim-4d7bde7bea80a6623048c81f", "kind": "analysis", "text": "ZND Ventures OÜ's annual reports filed in the Estonian register show revenue of EUR 5,597 and a profit of EUR 2,588 for 2021–2022, revenue of EUR 41,196 and a loss of EUR 241,635 for 2023, and revenue of EUR 28,000 and a loss of EUR 885,590 for 2024. Its 2025 report, due on 30 June 2026, had not been filed by 19 October 2026; on that date the company had no tax debt but had not filed its VAT returns due from May 2026, and five document-delivery notices of the Tax and Customs Board had been published for it between 3 August and 7 October 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-045" ], "entity_ids": [ "znd-ventures" ] }, { "id": "display-claim-2832f6a3d6edf1979bf0acba", "kind": "analysis", "text": "ZND.CO OÜ (registry code 16874675) was registered in Estonia on 6 December 2023 with share capital of EUR 10,000, also at Tähesaju tee 9, Tallinn. Its register card, retrieved on 19 October 2026, lists Wojciech Piotr Sroka as management board member from 6 December 2023, ZND Ventures OÜ as sole shareholder from 14 May 2025 and Przemysław Janusz Kral as beneficial owner through indirect holding from 6 December 2023; BB Trade Estonia OÜ's 2024 annual report lists ZND.CO OÜ as an associate held at 50% at the end of 2023 and 2024. A law firm acting for claimants in the bankruptcy states that ZND.CO was owned 50% by ZND Ventures OÜ and 50% by ICEO RED 0 OÜ until 14 May 2025, when ZND Ventures bought out the ICEO stake; it quotes the ZND token white paper as naming ZND.CO OÜ as the entity responsible for developing the software licensed to the issuer and used to operate the platform, and describes Sroka as also running ICEO Group. The white paper itself is not in the retained record, and the Estonian register shows ZND Ventures as sole shareholder only from 14 May 2025 without showing earlier shareholders.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-046", "src-008", "src-013" ], "entity_ids": [ "znd-co", "sroka", "znd-ventures", "kral", "iceo-red-0", "bbte" ] }, { "id": "display-claim-26cabdab9aacef27ae0b5d56", "kind": "analysis", "text": "ZND.CO OÜ's annual report for 6 December 2023 to 31 December 2024, filed on 28 June 2025, shows no revenue and a loss of EUR 954; its 2025 report, due on 30 June 2026, had not been filed by 19 October 2026. On that date the company owed EUR 600 in a coercive payment (sunniraha) outstanding since 23 August 2026, had not filed its VAT returns due from May 2026, and five document-delivery notices of the Tax and Customs Board had been published for it between 3 August and 8 October 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-046" ], "entity_ids": [ "znd-co" ] }, { "id": "display-claim-11d1894797bde761e5e56b60", "kind": "analysis", "text": "The Italian member of the 2024 consolidation group, listed as \"BB Trade Estonia Italian Branch (Italy)\", is a branch of BB Trade Estonia OÜ rather than a separate company: the Italian register of virtual-currency service providers kept by the Organismo Agenti e Mediatori enters BB TRADE ESTONIA OU itself, with an Italian tax code and a Milan address, under number PSV48.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013", "src-100" ], "entity_ids": [ "bb-trade-it", "bbte" ] }, { "id": "display-claim-e37206a92b21217a260149eb", "kind": "analysis", "text": "The Polish branch was entered in the KRS on 16 December 2024 as \"BB TRADE ESTONIA OÜ PRYWATNA SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ ODDZIAŁ W POLSCE\" (KRS 0001144319; legal form: branch of a foreign entrepreneur), with its seat at Ligocka 103, Katowice. The KRS entry, read through a commercial aggregator's reproduction, names Przemysław Janusz Kral as branch director (dyrektor oddziału) from 16 December 2024 and identifies the foreign entrepreneur as BB Trade Estonia OÜ of Tähesaju tee 9, Tallinn.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-009" ], "entity_ids": [ "bbte-pl-branch", "bbte", "kral" ] }, { "id": "display-claim-a8ae9b787a7b9ebe05e6c3c8", "kind": "analysis", "text": "BB Trade Bahamas Ltd holds legal entity identifier (LEI) 894500Q6B8UQVD0BXY93; its LEI record gives the Bahamian registration number 213148B, a creation date of 10 June 2024 and an active status, and a list of registered VAT taxpayers published by the Bahamas Department of Inland Revenue includes BB Trade Bahamas Ltd. of New Providence under tax identification number 131-213-434. The register of digital asset businesses of the Securities Commission of The Bahamas, with information as at 30 November 2025, lists the company at 201 Church Street, Sandyport, West Bay Street, Nassau, and names Przemyslaw Kral as principal; Przemyslaw Kral, Dawid Sendecki, Guido Buhler and Reece Chipman as directors; Reece Chipman as chief executive officer; and Samuel Wilkinson as compliance officer and money laundering reporting officer.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-092", "src-048", "src-020" ], "entity_ids": [ "bb-bahamas", "kral", "sendecki", "buhler", "chipman", "wilkinson" ] }, { "id": "display-claim-dccb505415b21231c3165347", "kind": "analysis", "text": "The records disagree on how BB Trade Bahamas Ltd relates to BB Trade Estonia OÜ. The 2024 consolidated report lists it in the consolidation group from 2024, but its LEI record reports no direct or ultimate parent, giving the reason code NATURAL_PERSONS. A law firm acting for claimants in the bankruptcy notes that the 2024 report names the Bahamian company only in its consolidation-policy note and not in the note on subsidiaries, so no acquisition date, ownership percentage or book value is given, although the auditor's opinion on that report was unqualified. No Bahamian share register or acquisition document was retained, and the Securities Commission register names Przemyslaw Kral as the company's principal; who owns BB Trade Bahamas Ltd therefore remains unresolved in the retained material.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-048", "src-010", "src-013" ], "entity_ids": [ "bb-bahamas", "bbte" ] }, { "id": "display-claim-4e2d943bd61dcc79e9b8db0a", "kind": "analysis", "text": "BB Trade (Cyprus) Limited (registration number HE 468498) was registered in Cyprus on 4 December 2024 as a limited company with its address at Thasou 3, Nicosia. Cypriot register data reproduced by commercial aggregators record two individual directors, one of whom is also company secretary; one aggregator snapshot gives its status as active, and a later one, updated on 13 October 2026, gives the register status \"Three month notice published\". The retained pages show neither the company's members nor its share capital and do not include the Registrar of Companies' own record or the notice itself, so the reason for the notice is not shown. Its LEI record (984500FBK7072B5C0944), first registered on 17 September 2025 and last updated on 21 July 2026, reports no direct or ultimate parent, giving the reason code NON_CONSOLIDATING for both.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-036", "src-053", "src-054" ], "entity_ids": [ "bb-cyprus" ] }, { "id": "display-claim-a0c1ef15b8b261dc32220d3a", "kind": "analysis", "text": "BB Trade Lithuania, UAB (company code 305790188) was founded on 7 June 2021, has share capital of EUR 125,000 and is located at A. Goštauto g. 8-224, Vilnius. A Lithuanian business directory records one corporate shareholder, whose name it does not give, computers and software as its main activity, and for 2025 revenue of EUR 0 and a net loss of EUR 6,312.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-037" ], "entity_ids": [ "bb-lithuania" ] }, { "id": "display-claim-9d9982c141ea5f10ff5a99dd", "kind": "analysis", "text": "According to a law firm acting for claimants in BB Trade Estonia OÜ's bankruptcy, which says it reviewed the exchange's records, BB Trade (Cyprus) Limited and BB Trade Lithuania UAB belong to the group below BB Trade Estonia OÜ, but no financial statement of either had yet reached the firm. It says the exchange lent the Cypriot company EUR 100,000 on 25 April 2025, EUR 50,000 on 26 September 2025 and EUR 150,000 on 10 October 2025 at ten per cent, repayable in 2030, and lent BB Trade Lithuania UAB, whose director it names as Przemysław Kral, EUR 10,000 on 5 May 2025 for one year at ten per cent. The loan agreements and the share registers were not retained; with the Cypriot LEI record reporting no parent and the Lithuanian directory naming only an unnamed corporate shareholder, the retained records do not confirm who owns either company.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-010" ], "entity_ids": [ "bb-cyprus", "bb-lithuania", "bbte", "kral" ] }, { "id": "display-claim-b2e43136d3e4ceea56a07502", "kind": "analysis", "text": "In the events after the reporting date of its 2021 annual report, BB Trade Estonia OÜ states that Zonda Gibraltar Ltd was also established in 2022 and that an operating licence was registered and obtained in Italy. The report gives no shareholding, registration number or later status for Zonda Gibraltar Ltd, and no Gibraltar register record was retained.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003" ], "entity_ids": [ "bbte", "zonda-gibraltar" ] }, { "id": "display-claim-fd9c15e5c93c77816a7c21ee", "kind": "analysis", "text": "BB Trade Switzerland AG, also registered as BB Trade Switzerland SA and BB Trade Switzerland Ltd. (Swiss enterprise identifier CHE-254.348.698, commercial-register number CH-170.3.044.963-8), was entered in the Zug commercial register on 30 September 2020 with share capital of CHF 100,000. Register publications list André Terlinden as chair of the board at registration and a second board member identified only by the initials S. S. A publication of 24 January 2022 records Terlinden as chair; on 24 March 2022 Sylwester Jan Suszek left the board and Terlinden was entered as a member, and on 29 June 2022 Timo Fenner joined the board and Terlinden left it.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-079", "src-014", "src-016" ], "entity_ids": [ "bb-switzerland", "terlinden", "suszek", "fenner" ] }, { "id": "display-claim-ec55c36c53aed18ce7da12ae", "kind": "analysis", "text": "A publication of 10 January 2024 in the Swiss Official Gazette of Commerce (SHAB) entered Przemyslaw Kral as president of the board without signing authority, with Guido Bühler and Timo Fenner as board members signing jointly by two; Fenner previously had sole signature, and the company's address was then c/o Dr. André Terlinden, Baarerstrasse 78, Zug. A SHAB publication of 6 May 2026 records that Bühler left the board and that Dr. Timo Fabian Fenner was given sole signature, with the company's address at Dammstrasse 16, Zug. A SHAB publication of 15 July 2026 records that Bühler also left the executive board (Vorstand) of the Swiss Blockchain Federation, an association registered in Bern.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-026", "src-079", "src-014", "src-018", "src-080", "src-017" ], "entity_ids": [ "bb-switzerland", "kral", "buhler", "fenner", "terlinden", "swiss-blockchain-federation" ] }, { "id": "display-claim-96699b340ab9e2edec422a24", "kind": "analysis", "text": "The ownership of BB Trade Switzerland AG, which its general meeting dissolved on 16 July 2026, is not shown in the retained register data, which state that no information on its ownership structure is known; shareholders of a Swiss AG are recorded in its private share register, and none of the retained records shows who holds the shares. A law firm acting for claimants in the bankruptcy describes it as a wholly owned subsidiary of the exchange, registered at Baarerstrasse 78 in Zug with Timo Fenner and Guido Bühler as directors, and states that it invoiced BB Trade Estonia EUR 200,000 in 2023. BB Trade Estonia OÜ's 2024 consolidated report does not list BB Trade Switzerland AG among the companies in its consolidation group.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-010", "src-014", "src-013", "src-082" ], "entity_ids": [ "bb-switzerland", "bbte", "fenner", "buhler" ] }, { "id": "display-claim-b1fde42e9f6c9cb215cd66f4", "kind": "analysis", "text": "Swiss financial press reported on 27 April 2026 that two senior lawyers of the Zollikon law firm Neupert Vuille Partners sat on important boards around the crypto platform: one partner on the board of BB Trade Switzerland, which the report called apparently the operator of the Swiss ZondaCrypto platform, and another as the sole board member of Divisio Holding in Zug, described in media reports as the owner of the operator BB Trade Estonia. The article does not name the two lawyers; register entries show Timo Fenner on the board of BB Trade Switzerland and André Marcel Terlinden as the board member of Divisio Holding AG. According to the report, both lawyers left the outlet's requests of the previous week unanswered. Lawyer-directory profiles describe Fenner as a lawyer and, since 2021, a partner of Neupert Vuille Partners, where he was a senior associate from 2018 to 2020.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-106", "src-080", "src-105", "src-116", "src-082" ], "entity_ids": [ "nvp", "bb-switzerland", "divisio", "bbte", "fenner", "terlinden" ] }, { "id": "display-claim-6362d72ccb605abe117f8cf6", "kind": "analysis", "text": "A SHAB publication of 29 July 2026 records that BB Trade Switzerland AG was dissolved by resolution of its general meeting of 16 July 2026, renamed BB Trade Switzerland AG in Liquidation and moved from Zug to Zollikon, c/o NEUPERT, VUILLE & PARTNER, Dufourstrasse 58, the firm's postal address in the lawyer-directory profiles. Dr. Timo Fabian Fenner was entered as board member and liquidator with sole signature. The same entry replaced the company's purpose with services related to trading and transferring digital assets, including fiduciary services, and developing and operating trading and IT platforms, allowing loans to direct or indirect shareholders and subsidiaries, and lifted the restriction on transferring its registered shares. Register data last changed on 29 July 2026 list Fenner and Przemyslaw Janusz Kral as board members, Fenner as liquidator and sole authorised signatory, and 32 other active companies registered at the Zollikon address.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-014", "src-082", "src-105", "src-116" ], "entity_ids": [ "bb-switzerland", "fenner", "nvp", "kral" ] }, { "id": "display-claim-f579051b99e05d344b176b7b", "kind": "analysis", "text": "zondacrypto SK, s. r. o. (IČO 55157157) came into existence on 26 January 2023 under the name TRJK CO s.r.o., registered with the Commercial Register of the Prešov District Court; it bore that name until 24 April 2023 and had its seat in Prešov until 12 May 2023. It is now seated at Odborárska 21, Bratislava, with registered capital of EUR 5,000, fully paid, and for 2025 it reported no revenue and a loss of EUR 370. These details are read through a Slovak business-information service reproducing the commercial register and the company's accounts.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-049", "src-050" ], "entity_ids": [ "zondacrypto-sk" ] }, { "id": "display-claim-439fce9c44697136d884dd42", "kind": "analysis", "text": "The full extract of the Slovak Commercial Register (ORSR) shows Divisio Holding AG of Baarerstrasse 78, Zug (CHE-161.370.248) as sole shareholder of zondacrypto SK since 22 April 2023, with a fully paid cash contribution of EUR 5,000; from 26 January to 21 April 2023 the shareholders were an individual and TRJK s. r. o. The Slovak company is therefore held by BB Trade Estonia OÜ's parent company, not by BB Trade Estonia OÜ. The extract records Przemysław Kral as its sole statutory director (konateľ), with his function beginning on 25 March 2023 (entry effective from 22 April 2023) and authority to act for the company alone; a different individual was director from 26 January to 24 March 2023.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-051" ], "entity_ids": [ "zondacrypto-sk", "divisio", "bbte", "kral" ] }, { "id": "display-claim-3bd912de865d9131e54bae7e", "kind": "analysis", "text": "Since 12 May 2023 the registered business activities of zondacrypto SK have included the provision of virtual-currency exchange services and of virtual-currency wallet services (poskytovanie služieb zmenárne virtuálnej meny; poskytovanie služieb peňaženky virtuálnej meny), alongside activities registered on 26 January 2023. These are entries in the list of business activities reproduced from the commercial register by a Slovak business-information service; they are not a licence decision of a financial supervisor.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-050" ], "entity_ids": [ "zondacrypto-sk" ] }, { "id": "display-claim-641ad26eff6edf54543ee1e4", "kind": "analysis", "text": "BB Trade Poland sp. z o.o. (KRS 0000847033) was registered on 23 June 2020 under the name KP Immobiliare sp. z o.o., with Przemysław Janusz Kral as chief executive and share capital of PLN 5,000. Its seat, Aleja Wojciecha Korfantego 141B in Katowice, is also Orion Software's registered address. Polish National Court Register (KRS) data reproduced by a commercial aggregator, current after entry no. 16 of 13 October 2025, list Divisio Holding AG, the parent company of BB Trade Estonia OÜ, as sole shareholder (10 shares, PLN 5,000) and Kral as beneficial owner; BB Trade Estonia OÜ itself is not a shareholder. An extraordinary shareholders' meeting on 15 September 2025 resolved to dissolve the company, which has been in liquidation since that date with Kral as liquidator; its 2024 accounts show assets of PLN 5 thousand and no revenue.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-007", "src-059", "src-002" ], "entity_ids": [ "bb-poland", "kral", "orion", "divisio", "bbte" ] }, { "id": "display-claim-b3f0f837f571c992e526d35f", "kind": "analysis", "text": "In Czechia, Przemysław Janusz Kral has been a statutory director (jednatel) of EXPOFÉR SERVIS HOUSE s.r.o., V Zátiší 810/1, Ostrava, since 3 January 2022, an entry made in the commercial register on 2 February 2022; Czech register data reproduced by a commercial aggregator list it as the only Czech company in which he has held a position. The company was registered on 11 May 2017. The aggregator's summary of a Czech register publication of 23 April 2024 records a change of shareholdings naming Divisio Holding AG, Luxbay SA and ADMI BUSINESS SERVIS s.r.o., and its network view shows Divisio Holding AG as current 100% shareholder and Luxbay SA as a former 100% shareholder. That rests on an automated summary and network graph whose links the aggregator says are not verified as to direction and identity, and the Czech register extract itself was not retained, so the sequence and dates of the earlier holdings are not shown.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-012", "src-002", "src-007", "src-063" ], "entity_ids": [ "expofer", "kral", "divisio", "luxbay", "admi-business" ] }, { "id": "display-claim-cdb9f4f19fcc2bf2aae7eb1e", "kind": "analysis", "text": "Fundacja Zondacrypto (KRS 0001103797) is a Polish foundation registered on 9 May 2024 with its seat at Ligocka 103, Katowice, the same address as BB Trade Estonia OÜ's Polish branch. KRS data reproduced by a commercial aggregator, current after entry no. 4 of 5 October 2026, list Przemysław Janusz Kral as president of its management board since 9 May 2024 and as its beneficial owner. Its stated objectives include social, educational, charitable and health activities and the promotion of modern technologies.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-011", "src-007", "src-009" ], "entity_ids": [ "fundacja-zondacrypto", "kral", "bbte-pl-branch", "bbte" ] }, { "id": "display-claim-d14f33b7609856f43e967c6b", "kind": "analysis", "text": "According to KRS data and Polish register publications reproduced by a commercial aggregator, Przemysław Janusz Kral has been sole shareholder (100 shares, PLN 5,000) and beneficial owner of Seed Investments sp. z o.o. (KRS 0000498898, Warsaw) since 9 April 2020; he became its chief executive in the publication of 9 April 2020 and ceased to be chief executive on 5 January 2026, when the company went into liquidation with Karolina Ewa Gwóźdź as liquidator. He has been sole shareholder (100 shares, PLN 5,000) and beneficial owner of Digesta Pro sp. z o.o. (KRS 0000563616, Katowice, registered 1 July 2015) since 11 February 2021, and was its chief executive until 15 January 2026, when another person became president of the management board. He was a member of the management board of Decori sp. z o.o. (KRS 0000462946, Pszczyna) from 10 July 2020 to 3 June 2024; current KRS data for Decori list another person as sole shareholder since 11 October 2019 and do not list Kral in its governing bodies. He was also one of four partners of Duraj, Reck & Kral Adwokaci, Doradcy Podatkowi sp.p., a Katowice partnership of advocates and tax advisers registered on 14 March 2011 and terminated on 9 September 2020.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-035", "src-007", "src-071", "src-072" ], "entity_ids": [ "seed-investments", "kral", "gwozdz", "digesta-pro", "decori", "duraj-reck-kral" ] }, { "id": "display-claim-c369670681dd6d43793e9313", "kind": "analysis", "text": "In Luxembourg, Przemysław Janusz Kral has been a director of S&B Investment SA (trade register B237594) since 13 November 2023. The company, whose registered purpose is acquiring and managing shareholdings, was registered on 4 September 2019 with capital of EUR 30,000, and Sylwester Jan Suszek was one of its directors from 9 July 2021 until 14 November 2023; the publication of 14 November 2023 records Kral's appointment, Suszek's departure and a change of auditor. Suszek was also a director of Luxbay SA, Luxembourg, in a publication of 21 July 2021. These details are read through a commercial aggregator's reproduction of Luxembourg register publications; the company has had further directors, who are not named here.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-015", "src-022", "src-007" ], "entity_ids": [ "suszek", "luxbay", "sb-investment", "kral" ] }, { "id": "display-claim-c6b231342463845dcb5bfc03", "kind": "analysis", "text": "BB TRADE FLORIDA INC. is a Florida profit corporation (document number P24000070168, FEI/EIN 33-1989108) filed on 14 November 2024 and recorded as active by the Florida Division of Corporations, with Przemyslaw Kral as chief executive officer. Its principal address has been 200 South Biscayne Boulevard, 20th floor, Miami since an amendment of 28 April 2026, and the record shows a reinstatement on 6 October 2025 and annual reports for 2025 and 2026. The state record lists officers and a registered agent but not shareholders, so it does not show whether BB Trade Estonia OÜ, another group company or Kral owns the corporation.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-118" ], "entity_ids": [ "bb-florida", "kral" ] }, { "id": "display-claim-4bdeec4cf642e13d5ffd4b45", "kind": "analysis", "text": "At 31 December 2024 BB Trade Estonia's loans receivable had risen to EUR 93,620,229. Two loans maturing in 2025 accounted for most of it: Laen 6 of EUR 14,448,098, in euro, zloty and US dollars at variable interest, and Laen 7 of EUR 75,016,307, denominated in crypto-assets at variable interest. The report, signed in July 2025, states that EUR 58,264 thousand of loans 6 and 7 had been returned as at 28 July 2025; it does not name the borrowers.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-29b86a9969a516b0f55fad19", "kind": "analysis", "text": "A law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements, states that on 12 September 2022 BB Trade Estonia concluded a credit-line agreement with AdmiTrade OÜ, an Estonian company of Wojciech Sroka, providing fiat financing \"with the possibility of further trading on the client's side\". According to the firm, Annex 1 of 4 December 2023, signed by Przemysław Kral and Sroka, called AdmiTrade a \"strategic liquidity provider\", set the limit at EUR 100,000,000 and allowed the funds to be used on other exchanges and platforms, for arbitrage, market making, staking, secured loans, loans to related entities, investment in the ZND token and platform and general crypto trading, with the borrower to keep at least 40% of the drawn amount on its exchange account. The firm says the line was ended by a termination agreement of 28 July 2025, the date by which the 2024 annual report records EUR 58,264 thousand of loans 6 and 7 as returned. Those documents are not in the retained record, and no reply by the persons concerned is recorded.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083", "src-013" ], "entity_ids": [ "bbte", "admitrade", "sroka", "kral" ] }, { "id": "display-claim-4712ba535adb62d7606a3871", "kind": "analysis", "text": "The same firm says that at 1 January 2025 the company's accounts \"Admitrade EARN fiat\" and \"Admitrade EARN crypto\" showed EUR 14,448,098 and EUR 75,016,307, the amounts reported as Laen 6 and Laen 7 in the 2024 annual report; the match is exact to the euro, but the annual report does not name AdmiTrade. According to the firm, a termination agreement of 28 July 2025, signed by Sroka and Kral, gave the company's application for a licence under the EU Markets in Crypto-Assets Regulation (MiCA) as its reason, and an annex listed 245 transfers between 23 and 26 July 2025 worth EUR 58,264,534 in crypto-assets returned by AdmiTrade, matching the EUR 58,264 thousand that the annual report records as returned on loans 6 and 7 by that date. The firm states that by 22 April 2026 both AdmiTrade accounts stood at zero in the books without any loss being recorded. Its account rests on contracts, a general ledger and bank statements that are not in the retained record, and no reply by the persons concerned is recorded.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083", "src-013" ], "entity_ids": [ "bbte", "admitrade", "sroka", "kral" ] }, { "id": "display-claim-b074664e0673b58db948421c", "kind": "analysis", "text": "AdmiTrade OÜ (registry code 16309521, earlier names ICEO CAPITAL EST-1 OÜ and Norion OÜ) was registered in Estonia on 7 September 2021 with share capital of EUR 2,500 at Tähesaju tee 9, Tallinn, the same address as BB Trade Estonia OÜ. Its register card lists ICEO RED 0 OÜ as sole shareholder from 2 September 2023, Wojciech Piotr Sroka as management board member from 7 September 2021, and Dawid Mateusz Duniec and Sroka as beneficial owners through indirect holding from 12 September 2022, the same date as the credit-line agreement described above. The card shows no licences in the Register of Economic Activities, and the 2025 annual report, due on 30 June 2026, had not been filed by 19 October 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-093" ], "entity_ids": [ "admitrade", "iceo-red-0", "sroka", "duniec", "bbte" ] }, { "id": "display-claim-b0b5b76e5c5ce31c778f2952", "kind": "analysis", "text": "AdmiTrade OÜ's annual reports filed in the Estonian register show revenue of EUR 655,875 and a profit of EUR 360,369 for 2021–2022, no revenue and a profit of EUR 7,577 for 2023, and revenue of EUR 1,690,941 and a profit of EUR 4,048,044 for 2024; its main activity is recorded as other software publishing (EMTAK 58291).", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-093" ], "entity_ids": [ "admitrade" ] }, { "id": "display-claim-3dc9a2fe8d2d80c6345566eb", "kind": "analysis", "text": "ICEO RED 0 OÜ (registry code 16536033, formerly ICEO Red Venture Builder OÜ) was registered in Estonia on 14 July 2022 with share capital of EUR 2,500, also at Tähesaju tee 9, Tallinn. Its register card lists Sroka and Duniec as shareholders with 50% each (entered on 1 September 2023) and as beneficial owners through direct holding from 14 July 2022, and Sroka as its sole management board member from 14 July 2022. According to the law firm acting for claimants, the same company held half of ZND Ventures OÜ, BB Trade Estonia's associate, in 2022 and half of ZND.CO OÜ until 14 May 2025, when ZND Ventures bought out its stake. The Estonian register shows ZND Ventures as ZND.CO's sole shareholder only from 14 May 2025 and does not show earlier shareholders. The firm's account of ZND Ventures is its reading of accounting records obtained in the bankruptcy; the general ledger is not in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-057", "src-010", "src-008", "src-013" ], "entity_ids": [ "iceo-red-0", "sroka", "duniec", "bbte", "znd-ventures", "znd-co" ] }, { "id": "display-claim-1b03b6e858ab114a3412f8ea", "kind": "analysis", "text": "Swiss register data show BeOne Group AG (UID CHE-169.308.129) entered in the Zug commercial register on 17 September 2024 with share capital of CHF 100,000, at c/o AT Advisory Services AG, Baarerstrasse 78, Zug, with two board members including Wojciech Piotr Sroka. Publications in the Swiss Official Gazette of Commerce record Sroka moving from no signing authority to sole signature in July 2025 and then to joint signature in September 2025, and a third board member who joined on 4 September 2025 and left on 1 May 2026. The register data show no information on its owners.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-061" ], "entity_ids": [ "beone-group", "sroka" ] }, { "id": "display-claim-183f105422fc5edf1065333b", "kind": "analysis", "text": "A law firm acting for claimants in the bankruptcy states that BeOne Group AG is owned half by ZND Ventures OÜ, whose sole shareholder has been BB Trade Estonia OÜ since 10 January 2024, and half by Iceo group AG, the company of Sroka and Duniec, and that it is the sole owner of BeOne Europe SIA of Riga, incorporated on 27 January 2025 with EUR 500,000 of capital paid in June 2025 and described in the group's own structure chart as the holder of an electronic money institution licence. The structure chart is not in the retained record, the Swiss register does not show BeOne Group AG's shareholders, and no Latvian regulator's record of an electronic money licence was retrieved.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-010", "src-045" ], "entity_ids": [ "beone-group", "znd-ventures", "iceo-group", "sroka", "duniec", "beone-europe", "bbte", "kral" ] }, { "id": "display-claim-e75d9fea317ca82835cb5d6f", "kind": "analysis", "text": "Latvian Register of Enterprises data reproduced by an aggregator show BeOne Europe SIA (registration number 50203620371), registered in Riga on 27 January 2025 in other financial service activities, with paid-up capital of EUR 500,000 registered on 25 June 2025 and BeOne Group AG of Baarerstrasse 78, Zug, as sole shareholder of all 500,000 shares from 19 June 2025. The company reports beneficial owners and a two-member board, whose names are not shown in the retained data. As of 2 October 2026 it had a tax debt of EUR 58,949.72 and registered restrictions, with no liquidation or insolvency entry.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-060" ], "entity_ids": [ "beone-europe", "beone-group" ] }, { "id": "display-claim-999741d18aab1ec371eb758f", "kind": "analysis", "text": "According to BB Trade Estonia OÜ's annual report for 2019–2020, the company obtained two operating licences, numbered FRK001037 and FVR0011, in October 2020; after a change in Estonian legislation the two were combined into a single licence for providing virtual currency services, numbered FVT000209. The Estonian Financial Intelligence Unit (Rahapesu Andmebüroo, FIU), in the revocation decision described below, gives the licence's validity as starting on 5 October 2020.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-4660bac56523d6b19edfa885", "kind": "analysis", "text": "The FIU lists in its register of precepts a compliance notice issued on 1 February 2023 to BB Trade Estonia OÜ as holder of licence FVT000209. The entry gives only the company, licence, area of activity and date, not the content of the precept, and several other virtual-currency providers are listed with notices dated 1 or 2 February 2023. In its annual report for 2023 the company stated that it had gone through a two-year audit covering several business areas and that in July 2023 it received the FIU's permission to continue operating under the new rules; its 2022 annual report similarly describes the end of a regulatory review with positive feedback and the grant of an operating licence under the new rules. That is the company's own account: no FIU decision of July 2023 was retained, and the FIU's register lists the precept of 1 February 2023.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-111", "src-027", "src-028" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-83d3c25ddac0c07d8ffcd496", "kind": "analysis", "text": "On 16 July 2025 the FIU issued precept No. 6-2/102 to BB Trade Estonia OÜ (licence FVT000209, virtual currency services) under § 72(1)(7) and § 72³(4) of the Money Laundering and Terrorist Financing Prevention Act because the company had not submitted an auditor's report on its own funds. Other virtual-currency providers received precepts with the same cause on the same day.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-111" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-bef4eb982d9586dc125daeb2", "kind": "analysis", "text": "On 18 May 2026 the FIU partially suspended operating licence FVT000209 (Zondacrypto brand): the company was prohibited from accepting any additional assets, including fiat funds and crypto-assets, from existing clients and from entering into business relationships with new clients, while the return or withdrawal of assets by existing clients was not affected. By the same decision the FIU ordered the company to bring its operations into compliance with the licence conditions within 30 days, citing among other grounds § 75(1)(4) of the Money Laundering and Terrorist Financing Prevention Act and § 43 of the General Part of the Economic Activities Code Act. The company neither responded to nor complied with that precept, and the FIU revoked the licence on 29 June 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-081", "src-030" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-5ed821b368cde6dd89d52ef6", "kind": "analysis", "text": "The FIU revoked licence No. FVT000209 on 29 June 2026 under § 75(1)(4) of the Money Laundering and Terrorist Financing Prevention Act, stating that the company had not responded to or complied with the precept of 18 May 2026 requiring it to bring its activities into line with the licence conditions; according to the FIU the licence had been valid from 5 October 2020 until 29 June 2026. No reply, statement or appeal by the company on the suspension or the revocation is in the retained record. The FIU also stated that its supervision mainly assesses whether a company's documentation complies with the anti-money laundering law and that it has no mandate for prudential supervision, including the safekeeping and protection of clients' assets, their physical existence or liquidity.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-030" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-eee2323c618f46374248994f", "kind": "analysis", "text": "On 6 May 2026 Finantsinspektsioon, the Estonian Financial Supervision and Resolution Authority, issued a public warning about BB Trade Estonia OÜ: the white paper of the crypto-asset \"TeamPL Token\" (TMPL) offered by the company was not available on its official website, which the authority described as a violation of Article 9(1) of Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), under which a white paper must remain available on the offeror's website for as long as the crypto-assets are held by the public.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-004" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-8f10897e3cc62d3dd45a8071", "kind": "analysis", "text": "Registry data compiled by a commercial aggregator from the interim MiCA register of the European Securities and Markets Authority (ESMA) and the Estonian supervisor's register, in a snapshot of 16 October 2026, list BB Trade Estonia OÜ as a crypto-asset offeror that notified one white paper, dated 16 February 2026 and hosted under a TMPL-token address, to the Estonian Financial Supervision Authority, with the offer notified for 27 EU member states and no crypto-asset service provider named. A white paper under MiCA is notified to the authority, not approved by it. The ESMA register itself was not retained; the aggregator first recorded the entry in its snapshot of 23 February 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-038" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-e9114efa91c56d6494e438f5", "kind": "analysis", "text": "The register of virtual-currency service providers kept by the Italian Organismo Agenti e Mediatori (OAM) lists \"BB TRADE ESTONIA OU\" as a legal person with Italian tax code 12490930968 and a seat at Via Fatebenefratelli 20, Milan, registered under No. PSV48 on 22 July 2022 with the status \"ISCRITTO\" (registered). The export shows no suspension or cancellation, but it does not state when it was generated.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-100" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-5e0a7e16bc3c8e7ffcf53280", "kind": "analysis", "text": "The Cyprus Securities and Exchange Commission (CySEC) lists BB Trade Estonia OU, with its Tallinn address, in its register of crypto-asset service providers from the European Economic Area under Cyprus's national crypto-asset regime, with a registration date of 2 September 2024 and the brand as its approved trade name. The entry lists a provider from another EEA state under Cyprus's pre-MiCA national regime, relying on the company's Estonian status; it is not a Cypriot licence or a MiCA authorisation, and the register page was retained only as an archived copy of December 2025. In October 2024 a crypto-industry news report said that CySEC had licensed the Zondacrypto exchange, its \"7th license\", quoting a social-media post by chief executive Przemysław Kral, and that the brand had obtained an over-the-counter licence in Switzerland the previous year. The report names no legal entity; no Swiss licensing record was retained, and a January 2025 release for the brand states that its Swiss entity is not licensed or supervised by the Swiss Financial Market Supervisory Authority (FINMA).", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-085", "src-084", "src-113" ], "entity_ids": [ "bbte", "kral" ] }, { "id": "display-claim-eed40da9f2273e2ec5ca5f69", "kind": "analysis", "text": "According to the Securities Commission of The Bahamas register of digital asset businesses as at 30 November 2025, BB Trade Bahamas Ltd is registered as a digital asset exchange and digital asset business for operating a digital asset exchange, exchanging digital assets for fiat currency or other digital assets, payment services involving digital assets and executing orders. The registration is marked \"Approved on Condition\", with no sanctions and no registrations or licences held outside The Bahamas.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-020" ], "entity_ids": [ "bb-bahamas" ] }, { "id": "display-claim-aef2674fd580849052a19a17", "kind": "analysis", "text": "For Switzerland, a January 2025 press release issued for the zondacrypto brand together with Incore Bank states that BB Trade Switzerland AG is affiliated with VQF, a Swiss self-regulatory organisation for anti-money-laundering purposes, and is permitted to offer payment transaction services, and that the brand's Swiss entity is a member of the Swiss Blockchain Federation; the same release states that in Switzerland the brand is not licensed or supervised by FINMA. This is a self-statement of the brand and its banking partner, and no VQF membership record was retained; a Swiss consultancy's April 2026 publication repeats the VQF membership.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-113", "src-087" ], "entity_ids": [ "bb-switzerland", "incore", "swiss-blockchain-federation" ] }, { "id": "display-claim-1f7cc59ea2ca39ec76cee2fc", "kind": "analysis", "text": "In November 2025 a news report based on the company's announcement said that BB Trade Florida Inc., described as the U.S. entity of zondacrypto, had been granted a money services business licence by the Florida Office of Financial Regulation under Chapter 560 of the Florida Statutes, covering money transmission including virtual currencies, and quoted Przemysław Kral as chief executive of zondacrypto. No record from the Florida regulator's licence portal was retained, so the licence number and its later status are not established.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-117" ], "entity_ids": [ "bb-florida", "kral" ] }, { "id": "display-claim-144719665675c99c4205e94b", "kind": "analysis", "text": "Press releases issued for the zondacrypto brand claimed broad regulatory coverage. A January 2025 release said the brand's local entities held operating licences or self-regulatory memberships in Estonia, Italy, Cyprus, Canada, Switzerland, Slovakia, Poland and Lithuania, and a July 2025 release said the exchange operator had operating licences, virtual-asset service provider (VASP) registrations or self-regulatory organisation (SRO) memberships in Italy, Switzerland, Cyprus, Poland, Estonia, Slovakia and Canada. These self-statements do not say which legal entity holds which authorisation. Retained official records cover the Estonian FIU licence, the Italian OAM registration and the Cypriot national-regime listing of BB Trade Estonia OÜ; no Polish, Canadian or Lithuanian authorisation record was retained, and the January release itself states that the Swiss entity is not licensed or supervised by FINMA.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-052", "src-113" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-8d0133d11535270dffdb5c96", "kind": "analysis", "text": "According to Polish legal press quoting the Office of Competition and Consumer Protection (UOKiK), UOKiK opened proceedings concerning BB Trade Estonia OÜ in January 2025 on its rules for concluding, performing and terminating contracts, examining possible infringements and unfair contract clauses, and the proceedings were still under way. The press reported this from UOKiK's answer; no UOKiK decision was retained and the outcome is not known.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-095" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-d8c5534497c2c7295ebdcf57", "kind": "analysis", "text": "BB Trade Switzerland AG, also registered as BB Trade Switzerland SA and BB Trade Switzerland Ltd. (UID CHE-254.348.698), was entered in the Zug commercial register on 30 September 2020 with share capital of CHF 100,000 and André Terlinden as chair of the board. Terlinden, who had also been entered at incorporation as Divisio Holding AG's only board member, left the Swiss company's board on 29 June 2022, when Timo Fenner joined it.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-079", "src-014", "src-016", "src-005", "src-099" ], "entity_ids": [ "bb-switzerland", "terlinden", "suszek", "fenner", "divisio" ] }, { "id": "display-claim-76e8ba06586b034335b06767", "kind": "analysis", "text": "A publication of 10 January 2024 in the Swiss Official Gazette of Commerce (SHAB) entered Przemyslaw Kral as president of the board without signing authority, with Guido Bühler and Fenner signing jointly by two. Bühler left the board according to a SHAB publication of 6 May 2026, which gave Dr. Timo Fabian Fenner sole signature. After the company went into liquidation, register data list Fenner and Przemyslaw Janusz Kral as its board members and Fenner as liquidator and sole authorised signatory.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-026", "src-079", "src-014", "src-018", "src-080" ], "entity_ids": [ "bb-switzerland", "kral", "buhler", "fenner", "terlinden" ] }, { "id": "display-claim-e23c5b936a14b04e89c47521", "kind": "analysis", "text": "The terms of the zondacrypto Swiss platform, in force from 30 June 2025, make each client a party to a tripartite agreement with BB Trade Switzerland AG and BB Trade Estonia OÜ. BB Trade Switzerland processes the client's order and transmits it to BB Trade Estonia for execution; it is responsible for the fiat-currency part of each transaction and BB Trade Estonia for the digital-asset part, including transfers of purchased digital assets to customers and acceptance of customers' digital-asset payments for exchange into fiat. BB Trade Switzerland accepts customers' fiat payments and transfers them on the customer's behalf to BB Trade Estonia to close the transaction, or returns them; customer fiat it holds bears no interest, is not invested or converted and is held for no longer than 30 days. The brand's contact page states that on the zondacrypto Swiss platform funds are sent directly to the customer's wallet or bank account and are not stored on the platform.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-107", "src-086" ], "entity_ids": [ "bbte", "bb-switzerland" ] }, { "id": "display-claim-b54a09c8aee82099adb728f4", "kind": "analysis", "text": "A press release issued for the brand on 2 July 2025 describes zondacrypto Swiss as a regulated crypto on- and off-ramp operated by BB Trade Switzerland and part of the \"zondacrypto Group\", which it says operates the zondacrypto exchange, the zondacrypto pay crypto-fiat payment gateway and the ZND platform. A January 2025 release issued for the brand with Incore Bank calls BB Trade Switzerland AG the brand's Swiss entity and states that \"zondacrypto\" is a trademark identifying the services of various entities within the group, does not in itself refer to any single legal entity and does not imply a single corporate identity, ownership structure or legal responsibility.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-052", "src-113" ], "entity_ids": [ "bb-switzerland", "bbte", "incore" ] }, { "id": "display-claim-fc552c2b67004ce588dc8692", "kind": "analysis", "text": "A press release issued for the zondacrypto brand together with Incore Bank on 14 January 2025 announced that the brand was opening an office in Zug for BB Trade Switzerland AG and entering a collaboration with the bank; Swiss financial press reported the partnership the same day, quoting Przemysław Kral as chief executive of Zondacrypto. This is the partners' announcement, and no account or service agreement is in the retained record. The same release also states that BB Trade Switzerland AG is affiliated with VQF, a Swiss self-regulatory organisation for anti-money-laundering purposes, may offer payment transaction services and, as the brand's Swiss entity, is a member of the Swiss Blockchain Federation, but that in Switzerland the brand is not licensed or supervised by the Swiss Financial Market Supervisory Authority (FINMA). That is a self-statement of the brand and its banking partner, and no VQF membership record was retained; a Swiss consultancy's April 2026 publication repeats the VQF membership.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-113", "src-073", "src-087" ], "entity_ids": [ "bb-switzerland", "incore", "kral", "swiss-blockchain-federation" ] }, { "id": "display-claim-0a334a3f83f1a4759558d8be", "kind": "analysis", "text": "None of the retained records shows who held the shares of BB Trade Switzerland AG before its general meeting dissolved it on 16 July 2026: the register data state that no information on its ownership structure is known, and a Swiss AG's shareholders are recorded in its private share register. BB Trade Estonia OÜ's 2024 consolidated report does not list it in its consolidation group, while a law firm acting for claimants in the bankruptcy describes it as a wholly owned subsidiary of the exchange with Timo Fenner and Guido Bühler as directors. Citing the company's records, the same firm reports that BB Trade Switzerland invoiced BB Trade Estonia EUR 200,000 in 2023, and that Divisio Holding AG invoiced it EUR 200,000 in 2023 and EUR 400,000 in 2024; the underlying invoices are not in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-010", "src-014", "src-013", "src-082" ], "entity_ids": [ "bb-switzerland", "bbte", "fenner", "buhler", "divisio", "kral", "luxbay", "terlinden" ] }, { "id": "display-claim-7c44d455feff28cb1e4bcc2b", "kind": "analysis", "text": "BB Trade Switzerland AG was dissolved by resolution of its general meeting of 16 July 2026; a SHAB publication of 29 July 2026 records its new name, BB Trade Switzerland AG in Liquidation, its move from Zug to Zollikon, c/o NEUPERT, VUILLE & PARTNER, Dufourstrasse 58, and Fenner's entry as liquidator with sole signature. Lawyer-directory profiles describe Fenner as a partner of Neupert Vuille Partners since 2021, with the firm's postal address at that Zollikon address. Swiss financial press had reported on 27 April 2026 that one partner of the firm sat on the board of BB Trade Switzerland, which the report called apparently the operator of the Swiss ZondaCrypto platform, and another was the sole board member of Divisio Holding in Zug. The article did not name the two lawyers; register entries show Fenner on the board of BB Trade Switzerland and André Marcel Terlinden as the board member of Divisio Holding AG. According to the report, both lawyers left the outlet's requests of the previous week unanswered.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-014", "src-082", "src-105", "src-116", "src-106", "src-080" ], "entity_ids": [ "bb-switzerland", "fenner", "nvp", "divisio", "bbte", "terlinden" ] }, { "id": "display-claim-4c226ef34a6df7f24e392506", "kind": "analysis", "text": "In 2021 BB Trade Estonia OÜ's sales revenue was EUR 23,819,262, against EUR 9,117,007 in 2020 as corrected in that report (the first annual report had shown EUR 8,837,007). Poland supplied EUR 17,937,221 of it (2020: EUR 4,451,443), and in 2020 a further EUR 2,824,086 was attributed to Malta. Fees paid to payment intermediaries rose to EUR 1,444,421 (2020: EUR 611,358) and the cost of licence fees and platform use to EUR 2,189,404 (2020: EUR 1,300,000).", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-190566ec7b222757bb35f7de", "kind": "analysis", "text": "The consolidated balance sheet at 31 December 2022 showed total assets of EUR 196,559,328, made up mainly of EUR 155,252,930 of crypto-asset inventories and EUR 9,959,948 of cash, against payables and prepayments received of EUR 166,762,446, a EUR 5,000,000 loan and equity of EUR 24,796,882. The group's profit for 2022 was EUR 1,142,183; the company's own profit, shown in an annex, was EUR 1,735,279, the difference being the scope of the two statements. At 31 December 2023 consolidated total assets were EUR 375,965,919, including EUR 309,948,409 of crypto-asset inventories and EUR 4,924,500 invested in subsidiaries and associates, with a EUR 10,000,000 loan, equity of EUR 26,223,954 and a 2023 profit of EUR 1,040,294; during 2023 the group paid EUR 4,132,500 for associates and granted EUR 7,572,711 of loans.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028", "src-027" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-a6cc57335f1641a85f240b10", "kind": "analysis", "text": "In 2024 the company issued its own utility token, ZND. At the token generation event on 18 October 2024 a total of 700,000,000 ZND were created, of which up to 183,400,000 had been offered in sale rounds between June and October; 5,600,000 tokens from a launchpad round that could not be completed were burnt, the presale raised EUR 11,706,800 and trading on the zondacrypto exchange began on 24 October 2024.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-ffa9120aed7be6102363cbab", "kind": "analysis", "text": "The 2024 consolidated accounts show sales revenue of EUR 6,076,753 and other operating income of EUR 20,552,305, of which EUR 19,545,016 related to the ZND token: a EUR 4,018,309 gain on the change in the token's value, EUR 13,696,115 booked as a ZND token receivable for tokens that moved under smart contracts into company-controlled wallets from October 2024, and EUR 522,386 and EUR 1,308,206 from token sales before the token generation event. The group's 2024 profit was EUR 8,443,567 and the company's own profit EUR 10,601,975. Total assets reached EUR 768,208,697, including EUR 594,127,140 of crypto-asset inventories and EUR 121,226,865 of receivables and prepayments, against liabilities of EUR 733,210,694, of which EUR 9,861,091 related to the ZND token, and equity of EUR 34,998,003; there was no loan liability. The report does not compare the result with and without the token items; a law firm acting for claimants in the bankruptcy says that without them the 2024 result would have been a loss.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-a10ac340fbd7f8d3a54c0372", "kind": "analysis", "text": "The company's first annual report, covering 30 September 2019 to 31 December 2020, said it held crypto-assets on behalf of clients, with no responsibility for holding them and no economic benefit from them, and reported EUR 192,688,141 of obligations relating to clients' crypto-assets off the balance sheet at 31 December 2020. From the 2021 report onward clients' crypto-assets were recognised on the balance sheet as client assets within inventories, with matching liabilities to clients: at 31 December 2021 clients owned virtual currencies worth EUR 482,676,641 and the company EUR 132,683, mostly bitcoin (36%) and ether (31.5%). The 2021 report restated the end-2020 holdings at EUR 191,758,642, all belonging to clients, and the two reports do not reconcile that figure with the EUR 192,688,141 given a year earlier.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006", "src-003" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-becae0b25e979a42dbe9283e", "kind": "analysis", "text": "Client money stood at EUR 31,750,893 at the end of 2021 (EUR 48,390,205 a year earlier). The 2021 report says it was kept separate from the company's working capital and partly held by payment service providers, and that under the client agreement the company had the right to use funds in client accounts and had done so in 2020, recording EUR 906,184 as a debt to clients at 31 December 2020. Of all cash at the end of 2021, EUR 5,648,135 was in bank accounts and EUR 27,586,730 with payment service providers; the company's own cash was EUR 1,483,972, after none a year earlier.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-b164c8166ee623aa04fc3824", "kind": "analysis", "text": "At 31 December 2022 clients owned virtual currencies worth EUR 154,384,891 and the company EUR 868,039. Liabilities to clients totalled EUR 164,207,285: a client cash balance of EUR 34,206,833, made up of deposits awaiting confirmation or rejection and funds awaiting withdrawal, and EUR 130,000,453 owed to clients in crypto-assets. The company's own cash was nil. The 2022 report says the company holds part of clients' funds in crypto-assets and that it used its contractual right to use client funds in 2022, recording the amount used, EUR 26,220,117, as a debt to clients; the note dates that figure \"as at 31.12.2023\".", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028", "src-027" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-f4204a99c97107747e430a2f", "kind": "analysis", "text": "In the 2023 consolidated report client money was EUR 30,851,817 at the end of the year. The company again used client funds under the client agreement, recording EUR 18,939,269 as a debt to clients, and held its fiat obligations to clients in crypto-assets. Of the EUR 308,223,793 it owed clients in crypto-assets, EUR 289,189,285 was the liability for virtual currencies and EUR 19,034,508 the liability arising from the use of client funds.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-027" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-2de2b0b6745a357749b2dd8f", "kind": "analysis", "text": "At 31 December 2024 clients owned virtual currencies worth EUR 565,415,120 and the company EUR 28,712,020, of which EUR 7,886,423 was its own ZND token; bitcoin made up 71% of the holdings, ZND 5% and ether 4%. The client assets and liabilities line stood at EUR 722,356,044 (2023: EUR 338,875,597), including a client cash balance of EUR 74,195,735. Of EUR 648,160,309 owed to clients in crypto-assets, EUR 565,415,120 was the liability for clients' crypto-assets and EUR 82,745,189 the liability from the use of client funds, in fiat and crypto. The report states that the company holds part of client funds in crypto rather than money, may use funds in client accounts under the client agreement and has reinvested client funds both short- and long-term.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-ab9d19a015d86fb3db6ab70f", "kind": "analysis", "text": "The reports do not give one consistent figure for 2022. The 2022 report records EUR 26,220,117 of client money used and owed to clients, while the 2023 report shows EUR 1,835,679 as the 2022 comparative for liabilities arising from the use of client funds. A law firm acting for claimants cites the balance sheets as showing customer-fund use of EUR 26.2 million in 2022, EUR 19 million in 2023 and EUR 82.7 million in 2024. The two notes may measure different items, fiat client money used against a crypto-denominated liability, but the reports do not reconcile them.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-008", "src-028", "src-027" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-0f0e7e4216f17fb41477327e", "kind": "analysis", "text": "According to the same law firm, which read successive versions of the exchange's terms of service that are not in the retained record, the terms of the Zonda period (2021–2024) let the exchange hold clients' fiat and crypto funds with external operators in its own name but on the client's behalf, and the version of 30 December 2024 was the first to contain the client's consent to zondacrypto using funds and crypto-assets in client accounts in its own name without paying interest. The company's own annual reports from 2021 onward state that the client agreement in force gave it the right to use funds held in client accounts, and report the amounts used. The firm says the version of 19 July 2025 dropped the clause on using client funds on the exchange's own account and added that the exchange does not speculate on prices and is not a market maker, while separate ZND Earn and ZND Farming terms that took effect at the same time allow Earn customers' funds to be used for operations of zondacrypto or related entities, including secured loans; the July 2025 exchange terms were not retained, but the retained version of 3 October 2025 contains the market-maker statement.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-008", "src-003", "src-039" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-c5a72565c341fbd1cd4aa026", "kind": "analysis", "text": "The terms valid from 3 October 2025 say that zondacrypto itself does not provide payment services: licensed payment operators handle deposits and withdrawals and safekeep clients' fiat on dedicated accounts, where it remains at the clients' disposal. By accepting them the client agrees that zondacrypto may hold the client's fiat and crypto-assets with various external operators in its own name but for the client, without paying interest; the same terms state that zondacrypto does not speculate on prices and is not a market maker.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-039" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-0e3b31fc78d50fbe678db34d", "kind": "analysis", "text": "The exchange's marketing said more. Its \"safety of funds\" page, archived in January 2026, told clients that all crypto-assets were kept in cold wallets not directly connected to the exchange's servers and that \"a bank\" guaranteed clients' fiat funds. That is the operator's own statement: the October 2025 terms say fiat is safekept by payment operators, and the auditors of the 2021–2023 statements could not verify control of large crypto balances. The ZND platform's website, archived the same month, advertised digital assets \"securely stored offline\" and an Earn service paying weekly rewards on 34 crypto-assets, tokens and stablecoins at up to 23% a year, while according to the claimants' law firm the ZND Earn terms allowed Earn customers' funds to be used for operations of zondacrypto or related entities. The 2022 annual report also lists a migration to BitGo V2, a custody platform, among the IT department's plans for 2024.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-041", "src-114", "src-028" ], "entity_ids": [ "bbte", "bitgo" ] }, { "id": "display-claim-24b87ff35a06b84bb748e634", "kind": "analysis", "text": "Audit Advisory OÜ, through sworn auditor Liina Tamm, qualified its opinion of 24 September 2021 on the 2020 statements: it found revenue understated by about EUR 280,000 and expenses by about EUR 146,000 because of the accounting system used, and could not assess whether about EUR 1,302,000 of loan and interest receivables needed impairment. In its 2021 annual report the company stated that it had corrected its 2020 revenue and expenses: 2020 revenue rose by EUR 280,000 to EUR 9,117,007, costs of goods, materials and services by EUR 144,845, and the 2020 profit from EUR 6,491,835 to EUR 6,626,090. Tamm has been the firm's sole management board member since 1 December 2008 and holds all of its share capital.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006", "src-003", "src-121" ], "entity_ids": [ "bbte", "audit-advisory", "tamm" ] }, { "id": "display-claim-4d90b9196a58f034c16f2026", "kind": "analysis", "text": "For 2021 Crowe DNW OÜ (formerly DNW Audit OÜ, registry code 14299250), through sworn auditor Anton Mullo, a procurator of the firm since 8 October 2021, disclaimed an opinion in a report of 30 November 2022. Its main ground was the EUR 482.8 million of virtual currencies in inventories: bitcoin worth about EUR 145.7 million was, according to the company, held in a wallet to which management had restricted access citing security measures, so the auditor could not verify its existence or ownership. It also cited about EUR 9.5 million of other virtual currencies without wallet statements or addresses, unverifiable LUNA (about EUR 13.1 million) and litecoin (about EUR 2.4 million) balances, about EUR 1.9 million of tokens valued at prices from the company's own platform, about EUR 34.2 million of client liabilities that the accounting system could not attribute to individual clients, and about EUR 2.4 million of investments not tested for impairment. It further cited about EUR 3.9 million of loans not repaid by the time of the report, whose borrowers' intention and ability to repay it could not assess, as the previous auditor had noted for 2020; about EUR 0.9 million of revenue without detailed transaction statements; a gain of about EUR 0.6 million on crypto-currency values without underlying data; and an opening balance of about EUR 182.4 million of virtual currencies and EUR 241.4 million of client liabilities that had never been audited.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003", "src-120", "src-119" ], "entity_ids": [ "bbte", "crowe-dnw", "mullo", "assertum" ] }, { "id": "display-claim-53d370cdd3b2a2bb78fb1fbb", "kind": "analysis", "text": "Assertum Audit OÜ (registry code 10990446), registered as the company's auditor from 20 June 2023, audited the 2022 to 2024 consolidated statements through sworn auditor Sergei Tšistjakov, a management board member of the firm since 6 May 2015. Its opinion of 12 January 2024 on 2022 was qualified: because the previous auditor had disclaimed an opinion on 2021 it gave no assurance on opening balances and comparatives, and crypto-assets of EUR 155,252,930 were partly held by third-party service providers that do not confirm the assets they hold. The opinion of 30 June 2024 on 2023 was qualified too: crypto-assets of EUR 172 million (2022: EUR 155 million) sat in the \"wallet\" of the group's own platform and the auditor could not test that the group had substantive control over them; instead of testing, management proposed a notarial confirmation of control. The auditor also gave no opinion on EUR 1.8 million of fee revenue it could not test.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028", "src-027", "src-119", "src-024", "src-120" ], "entity_ids": [ "bbte", "assertum", "tsistjakov", "crowe-dnw" ] }, { "id": "display-claim-384e151a9373fc051cf3538e", "kind": "analysis", "text": "On 29 July 2025 the same auditor issued an unqualified opinion on the 2024 consolidated statements, stating that they present fairly in all material respects the group's position at 31 December 2024.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013" ], "entity_ids": [ "bbte", "assertum", "tsistjakov" ] }, { "id": "display-claim-33b92a8967d4e52f3ee01828", "kind": "analysis", "text": "A law firm acting for claimants describes an 80-page statement of BB Trade Estonia OÜ dated 18 June 2021 and signed by Sylwester Suszek as chairman of the management board, certifying the exchange's wallets at 31 December 2020: 4,513.93 BTC in the cold wallet, 308.48 BTC in the hot wallet and 51,646.73 ETH in the cold ether wallet, with the bitcoin figures taken from the exchange's internal \"Funds Monitor\" system. The statement itself was not retained, and the firm notes that it gives no bitcoin address, so it cannot be matched to the address cited in 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte", "suszek" ] }, { "id": "display-claim-c35f5f8085e8d13f8c2abbf2", "kind": "analysis", "text": "The auditor of the 2021 statements disclaimed an opinion in November 2022 largely for this reason: bitcoin worth about EUR 145.7 million was, according to the company, held in a wallet to which management had restricted access citing security measures, so its existence and ownership could not be verified.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003" ], "entity_ids": [ "bbte", "crowe-dnw", "mullo" ] }, { "id": "display-claim-20fa47cee6daa2c4e51955b0", "kind": "analysis", "text": "When the Regional Prosecutor's Office in Katowice opened its investigation on 17 April 2026, its release stated that the exchange's owner had indicated that since 2022 the exchange had had no access to a so-called cold wallet said to hold about 4,500 BTC, and that this had been concealed from clients. That is the prosecutors' summary of the owner's statement, not a finding, and the release does not say how or when access was lost. In early April 2026 Przemysław Kral had said that Zondacrypto was stable, solvent and safe and called a press analysis of a 99% fall in its bitcoin reserves erroneous, untrue and harmful; on 16 April 2026 he said publicly that the keys to the roughly 4,500-bitcoin wallet were held by Sylwester Suszek, the founder of the predecessor exchange BitBay, who has been missing since March 2022.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-065", "src-112" ], "entity_ids": [ "bbte", "kral", "suszek" ] }, { "id": "display-claim-df083744cbb337ca1be166cf", "kind": "analysis", "text": "The company's statement of 16 April 2026, attributed to Kral, identified a specific address holding 4,503 BTC as its cold wallet. A law firm acting for claimants says the address is a publicly known wallet dormant since March 2016 with no outgoing transactions, and that the company never gave auditors or the public a signed message or test transaction proving control. Both the company's account and the firm's reading of the blockchain are unverified in the retained record, and the address is not published here. In the bankruptcy, according to the same firm citing the trustee's report, the trustee could confirm only about EUR 167,000 of cash on accounts abroad, and the chief executive maintains that there is no key to the address, which accounted for 77% of the assets in the 2024 statements.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-008", "src-083", "src-075" ], "entity_ids": [ "bbte", "kral", "suszek" ] }, { "id": "display-claim-5619eac8254b9efb95e0b383", "kind": "analysis", "text": "The claimants' law firm has read a Fireblocks export dated 31 December 2024, filed in the bankruptcy proceedings before Harju County Court but not retained in this case. By its account the export lists 685,738 wallets in 227,496 vaults, including a cold vault with 4,796 ETH but only 0.000012 BTC; bitcoin deposits were handled by a second custodian, BitGo, which held 59.9 BTC on 1 January 2025, while the 4,503 BTC that balanced the accounts sat on a 2016 address outside any vault. The firm counts 14,846 client vaults created from 25 March to the end of 2021, 34,901 in 2022, 78,273 in 2023 and 99,463 in 2024, so that 20,230 predate the end of March 2022 and 207,253 came afterwards, and links that timing to its view that the exchange's own reconciliations showed only partial coverage of client liabilities after March 2022; the reconciliations were not retained either.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte", "fireblocks", "bitgo" ] }, { "id": "display-claim-1a424e191c918a811c40b168", "kind": "analysis", "text": "Reading public blockchain data against the same export, the firm says the exchange's ether cold vault, hot wallet and network-fee wallet match addresses that a public block explorer labels \"Zonda\"; by 15 September 2026 the cold-vault address held 0.4999 ETH and illiquid tokens worth about USD 236,000, with nothing left of the 4,796 ETH and 1.5 million USDC held at the balance-sheet date. It adds that tokens left the cold-vault address throughout the first quarter of 2026, the last on 13 April 2026, three days before the cold-wallet statement, and that on 19 April 2026, after client payouts had stopped, about 1.39 ETH left the hot wallet, partly to a deposit address at the Binance exchange. These readings are not verified in the retained record, and addresses and transaction identifiers are not published here.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-6e61526a8de52b885d82a5aa", "kind": "analysis", "text": "Swiss crypto-industry press reported in May 2026, citing a Zug blockchain-forensics firm, that bitcoin in the exchange's hot wallets fell from 55.7 BTC in August 2024 to 0.07 BTC on 1 April 2026, and that between December 2025 and April 2026 there were 511 transactions to wallets at the Kraken exchange totalling about USD 21 million, including USD 4.59 million in bitcoin; the article names BB Trade Estonia OÜ as the operating company, and the analysis itself was not retained. The claimants' law firm, citing criminal complaints and press coverage, says that shortly before the withdrawal crisis the company moved crypto-assets worth more than PLN 76 million to Kraken, operated by Payward Ltd.; no transfer records are in the retained record. According to the firm, the company told customers the transfers were for market making, and on 14 April 2026 Kral wrote that investing customer funds was not to be confused with liquidity management.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-096", "src-008" ], "entity_ids": [ "bbte", "payward", "kral" ] }, { "id": "display-claim-f5cfe3d131b1b351f3c28294", "kind": "analysis", "text": "The claimants' law firm, citing the trustee's findings, says that on the day of the freeze the operator's balance sheet showed EUR 476 million of assets, EUR 347 million in cryptocurrency and EUR 129 million in loans and shareholdings, of which the trustee could confirm only EUR 167,000 in cash on accounts abroad; the rest were book entries without source documents, prepared from aggregate data that management passed to the bookkeeper. Customer liabilities of EUR 429 million sat on several aggregate accounts without a breakdown by customer, and 77% of the assets in the 2024 statements was the single address holding 4,503 coins, to which according to Kral there is no key, although in a notarised statement in June 2025 he had said access existed. The company had thirteen employees and its bookkeeping ended on 22 April 2026. The trustee's report and the June 2025 statement are not in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-075", "src-108" ], "entity_ids": [ "bbte", "kral" ] }, { "id": "display-claim-1d3dfa4b76480486830170bb", "kind": "analysis", "text": "In 2020, according to its first annual report, BB Trade Estonia OÜ agreed with Fenige Sp. z o.o. to enable card payments, widening users' deposit and withdrawal options. The same report describes express deposits of Polish zloty to the BitBay.net platform through Polish Post (Poczta Polska), at a fee of 2% and at least PLN 5, and cash withdrawals of up to PLN 15,000 at a time at post offices, a service provided by the payment service provider Payment Technology. From December 2020 the company also offered a payment gateway for instant cryptocurrency payments, first as BitBayPay and later as \"Pay with zondacrypto\", charging a commission per transaction, and its 2021 report lists PayByZEN: instant deposits and withdrawals in PLN, USD and EUR between a client's account on zondaglobal.com and the client's account with ZEN.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006", "src-028", "src-003" ], "entity_ids": [ "bbte", "fenige", "poczta-polska", "payment-technology", "zen" ] }, { "id": "display-claim-d6f9584a8beab196ff256286", "kind": "analysis", "text": "The main Polish channel changed hands in 2022. In a current report of 29 April 2022 Femion Technology S.A. stated that Payment Technology sp. z o.o. had until then provided BB Trade Estonia OÜ, the operator of the ZONDA exchange at zondaglobal.com, with money-remittance services under a cooperation agreement. The same day Femion's subsidiary TryPay S.A., a Polish national payment institution, signed with both companies an assignment of all rights and obligations under that agreement, effective once Femion completed its purchase of Payment Technology's shares, and signed directly with BB Trade Estonia an open-ended partnership agreement to provide it with payment services in Poland and other countries.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-032" ], "entity_ids": [ "femion", "bbte", "payment-technology", "trypay" ] }, { "id": "display-claim-90172ce0709baaa6c8a52328", "kind": "analysis", "text": "A press report summarising Femion's stock-exchange reports said Femion announced the completion of the purchase in June 2022 and that Payment Technology had processed about PLN 275 million a month over the preceding six months, against about PLN 14 million at TryPay; a law firm acting for claimants describes Payment Technology as processing about USD 70 million a month between Polish bank accounts and BB Trade Estonia until April 2022. Both are secondary accounts: Femion's June 2022 report was not retained, the press figure covers all of Payment Technology's processing rather than BB Trade Estonia alone, and the firm's figure is an approximation. Payment Technology was later declared bankrupt and fined PLN 200,000 by the KNF for anti-money-laundering breaches; TryPay terminated its own agreement with BB Trade Estonia with immediate effect on 20 April 2026, and on 30 April 2026 TryPay's board resolved that it was insolvent.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-029", "src-088", "src-064", "src-076", "src-031", "src-090" ], "entity_ids": [ "femion", "payment-technology", "trypay", "bbte" ] }, { "id": "display-claim-0a6a6c6651e8dc0a902151c8", "kind": "analysis", "text": "Polish National Court Register (KRS) data reproduced by a registry-data aggregator list Femion Technology S.A. (KRS 0000377784) as the sole shareholder of TryPay S.A. (KRS 0000412103) since 27 July 2022 and Przemysław Kral as TryPay's beneficial owner. Femion's management report for 2025 shows Kral as its largest shareholder at 31 December 2025, with 14,109,812 shares or 49.8674% of the capital, the next largest holder having 11.8303%, and describes TryPay, a national payment institution entered in the KNF register as IP25/2014, as the group's operating company. Among events after that date the report lists a loan to Femion from Kral of EUR 60,000, increased by annex to EUR 120,000, Femion's subscription for 500,000 new TryPay shares at PLN 0.50 each, and an extension to 31 December 2027 of a loan from TryPay, under which Femion owed its subsidiary PLN 2,266.8 thousand at the end of 2025.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-033", "src-064", "src-055", "src-034" ], "entity_ids": [ "trypay", "femion", "kral", "orion" ] }, { "id": "display-claim-3572043feef41d519782ffb7", "kind": "analysis", "text": "A machine-generated summary of TryPay's filings on a registry-data aggregator states that the Polish financial supervisor (UKNF) inspected TryPay in 2024 on anti-money-laundering and sanctions compliance, and that TryPay implemented all post-inspection recommendations by February 2025, commissioned an audit in September 2025 and faced no pending administrative proceedings. The aggregator labels the text as AI-generated, and the underlying documents and any supervisory record were not retained.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-033" ], "entity_ids": [ "trypay" ] }, { "id": "display-claim-b956e4fc20e4108feba4853a", "kind": "analysis", "text": "On 20 April 2026, in a current report issued as inside information, Femion announced that TryPay had terminated with immediate effect its agreement to provide payment services to \"BB Trade Estonia EU\", following a negative result of its risk assessment of further cooperation, and expected a negative effect on the group's results. On 30 April 2026 Femion reported that TryPay's board had resolved that TryPay was insolvent and would file for bankruptcy, citing mainly the loss of a key counterparty, whom the report does not name, and failed talks on outside financing; TryPay also asked the KNF to extinguish its payment-institution authorisation. The same day Femion's board resolved that Femion itself was insolvent, citing TryPay's deteriorating finances and its inability to raise outside financing.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-031", "src-090", "src-097" ], "entity_ids": [ "femion", "trypay", "bbte" ] }, { "id": "display-claim-c94994443a261f5f49725672", "kind": "analysis", "text": "Femion's management report for 2025 states that in 2024 a court declared Payment Technology sp. z o.o. bankrupt. The claimants' law firm dates the declaration 3 October 2024 (file GD1G/GU/1487/2023), while a machine-generated summary of Femion's filings gives 4 October 2024 and says Femion wrote down its shares; the decision itself was not retained. On 13 June 2025 the Polish Ministry of Finance published the final KNF decision fining Payment Technology sp. z o.o. w upadłości (in bankruptcy), of Gdynia, PLN 200,000 for breaches of the Anti-Money Laundering Act: failing to assess its money-laundering risk, to identify and verify customers and beneficial owners, to monitor business relationships and analyse transactions, to document beneficial-owner measures and to train staff. The company did not appeal. The publication does not state the period of the breaches or link them to any customer, including BB Trade Estonia.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-064", "src-076" ], "entity_ids": [ "payment-technology", "femion" ] }, { "id": "display-claim-e8421245d1a8716e8d6e482f", "kind": "analysis", "text": "The exchange's terms valid from 3 October 2025 say zondacrypto itself does not provide payment services: licensed payment operators handle deposits and withdrawals and safekeep clients' fiat. The operator list published with the terms, in an archived copy of 8 April 2026, named TryPay S.A. of Wrocław (KNF licence IP25/2014, without safekeeping of funds), ZEN UAB of Lithuania (Bank of Lithuania electronic-money licence LB000457), Clear Junction Limited of the United Kingdom (FCA licence 900684), Krajowy Integrator Płatności S.A. of Poznań (Tpay; KNF IP27/2014) and Fenige S.A. of Warsaw (KNF IP42/2017). The licence numbers are as the exchange stated them; they were not checked against the regulators' registers in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-039", "src-040" ], "entity_ids": [ "bbte", "trypay", "zen", "clear-junction", "kip", "fenige" ] }, { "id": "display-claim-1c637f6dfc068cd43b055740", "kind": "analysis", "text": "The 2022 annual report says BB Trade Estonia also received a monthly intermediary fee in fiat from payment operators, paid out after their costs, without naming them. In the 2023 report fees of payment intermediaries were EUR 97,339 for 2023 (EUR 413,057 for 2022), transaction costs including bank fees EUR 205,080 (EUR 242,986) and licence fees and platform use EUR 1,122,170 (EUR 2,498,010). The 2024 report gives revenue of EUR 6,076,753, EUR 4,694,517 of it from Poland, and by service lists Trading EUR 4,980,510, TryPay EUR 325,293, Pay EUR 264,185, Pay-ZEN EUR 175,057, Fenige EUR 108,084 and Fiat exchange EUR 49,009; for 2023 it shows no TryPay or Pay-ZEN line but ZEN at EUR 161,243.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028", "src-027", "src-013" ], "entity_ids": [ "bbte", "trypay", "zen", "fenige" ] }, { "id": "display-claim-3ad56466699a441383852fbc", "kind": "analysis", "text": "According to a law firm acting for claimants, which says it handed the trustee a list of account numbers, contract dates and transaction identifiers on 17 September 2026, BB Trade Estonia held accounts at AMINA Bank and Sygnum in Switzerland, ZEN.COM in Lithuania, Clear Junction in London and Fenige, TryPay and Tpay in Poland, kept the keys to 685,000 wallets in a Fireblocks workspace and used wallets at BitGo, while its subsidiaries had accounts at the Kraken and Gate exchanges. The same firm, citing the general ledger, says monthly payments to Orion Software under its loan and investment agreements, some booked as \"Zen Regular outgoing\", ran through ZEN.com until 31 March 2026, which also carried the monthly transfers to ZND Ventures. No bank, payment-institution or custodian confirmation, and no ledger extract, is in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-075", "src-083" ], "entity_ids": [ "bbte", "amina", "sygnum", "zen", "clear-junction", "fenige", "trypay", "kip", "fireblocks", "bitgo", "payward", "orion", "znd-ventures" ] }, { "id": "display-claim-0552ed9ded94d87841acb3c3", "kind": "analysis", "text": "AMINA Bank AG of Zug (UID CHE-434.446.643), formerly SEBA Crypto AG and SEBA Bank AG, was registered on 24 April 2018. BB Trade Estonia's annual reports show that it bought B shares of SEBA Bank AG for EUR 2,317,819 in 2020, converted in 2021 into equity tokens representing about 1.01% of the bank; it bought more for EUR 952,199 in 2022 and carried the stake at EUR 3,484,716 at the end of 2022, EUR 3,827,891 at the end of 2023 and EUR 3,785,087 at the end of 2024, when the report no longer named the issuer. The bank also lent the company EUR 5,000,000 at 4% (outstanding at 31 December 2022) and EUR 10,000,000 at 4% (outstanding at 31 December 2023); the 2024 balance sheet shows no loan liabilities.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-070", "src-003", "src-028", "src-027", "src-013" ], "entity_ids": [ "amina", "bbte" ] }, { "id": "display-claim-6fe53d468ecbf374254a325a", "kind": "analysis", "text": "A law firm acting for claimants, citing a share purchase agreement of 21 January 2025, says BB Trade Estonia agreed to sell its 781,250 AMINA participation certificates (par value CHF 1, about 1.014% of the bank's capital) to LL (BVI) Investment Limited for CHF 3.40 each, CHF 2,656,250 in total, about a quarter below the EUR 3,785,087 at which the position stood at the end of 2024; closing required consents from the bank's board, other holders and the regulator, either side could withdraw if they were not obtained by 30 April 2025, and disputes go to the Cantonal Court of Zug. The agreement is not in the retained record and nothing shows whether the sale closed or the price was paid. The buyer's legal entity identifier record describes it as an active British Virgin Islands company created on 12 January 2022, registered at Vistra Corporate Services Centre in Road Town, Tortola, with headquarters at 100 Queen's Road Central, Hong Kong, and no reported parent (reason: no known person).", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-010", "src-068" ], "entity_ids": [ "bbte", "amina", "ll-bvi" ] }, { "id": "display-claim-70facc6d540342f1fc0ba7ff", "kind": "analysis", "text": "The same firm says the price was to be paid to BB Trade Estonia's account at Sygnum Bank AG in Zurich, and that in the exchange's ledgers the position fell from about EUR 3.79 million on 1 January 2025 to one cent by 22 April 2026, with no cash received and no loss recognised; it describes SEBA (now AMINA) as the bank that kept BB Trade Estonia's accounts and lent to it. No statement from Sygnum and no extract from AMINA's register is in the retained record, so whether the sale closed and where the price went remain open.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-010" ], "entity_ids": [ "bbte", "sygnum", "amina" ] }, { "id": "display-claim-d8eb185912b6abe1dd94c6ed", "kind": "analysis", "text": "The firm also notes that Guido Bühler, SEBA Bank's first chief executive, having come from UBS Wealth Management, sat on the exchange's board when the certificates were sold. It adds that the certificates were acquired before 2021 and the loan taken in 2022, that Bühler joined the exchange about a year and a half after leaving the bank, that no document suggests he brokered either, and that it does not know whether the board knew of the sale. BB Trade Estonia's 2024 annual report lists Bühler as a management board member at 31 December 2024 and moves him to the supervisory board only in March 2025.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-010", "src-013" ], "entity_ids": [ "buhler", "amina", "bbte" ] }, { "id": "display-claim-46d8a0eb4331067a4f1aa4f6", "kind": "analysis", "text": "For the Swiss side of the brand, a press release issued for the brand together with Incore Bank on 14 January 2025 announced that zondacrypto was opening an office in Zug for its Swiss entity, BB Trade Switzerland AG, and entering a collaboration with the bank; Swiss financial press reported the partnership the same day, quoting Przemysław Kral as chief executive of Zondacrypto. These are the partners' announcements; no account or service agreement is in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-113", "src-073" ], "entity_ids": [ "bb-switzerland", "incore", "kral" ] }, { "id": "display-claim-d80d6e543f4abbabdfd0f514", "kind": "analysis", "text": "Orion Software sp. z o.o. (KRS 0000827257, NIP 9542811828, REGON 385348160) was registered on 7 February 2020 at Aleja Wojciecha Korfantego 141B in Katowice. Polish National Court Register data reproduced by a commercial aggregator, current after an entry of 21 September 2026, show share capital of PLN 3 million, all 60,100 shares held by BB Trade Estonia OÜ, and Przemysław Janusz Kral as president of the management board since 26 March 2020 and as the registered beneficial owner; the beneficial-owner entry describes him as the company's president, and the data do not show him holding shares in Orion directly.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-055", "src-033", "src-034" ], "entity_ids": [ "orion", "bbte", "kral", "trypay", "femion" ] }, { "id": "display-claim-d802caa42293a8afc88efb7a", "kind": "analysis", "text": "An aggregator's rounded summary of Orion's own 2024 financial statements, which were not retained, gives total assets of PLN 258.1 million, revenue of PLN 19.7 million, costs of PLN 18.4 million and a profit of PLN 1.1 million; under its articles each management board member may represent the company alone.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-055" ], "entity_ids": [ "orion" ] }, { "id": "display-claim-836fbfd0bdbe88d4cb721eca", "kind": "analysis", "text": "According to a law firm acting for claimants, on 2 March 2020 in Katowice BB Trade Estonia, represented by Sylwester Suszek, undertook to recapitalise Orion, then a private company of Kral with PLN 5,000 of capital, by up to PLN 100 million in monthly payments convertible into share capital; the same day Orion, represented by Kral, undertook to recapitalise EXPOFÉR SERVIS HOUSE s.r.o. of Ostrava by up to PLN 100 million on the same pattern, with Suszek signing for Expofer. The agreements are not in the retained record. BB Trade Estonia's 2021 annual report records prepayments under an investment agreement of EUR 5,498,608 in 2020 and EUR 8,923,511 in 2021, shown as financial investments of EUR 14,422,121 at the end of 2021.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083", "src-003", "src-028" ], "entity_ids": [ "bbte", "orion", "expofer", "kral", "suszek" ] }, { "id": "display-claim-e11785c6115fcad5b0fbcfd1", "kind": "analysis", "text": "On 22 July 2022 BB Trade Estonia acquired 100% of Orion and resolved to raise its share capital by PLN 1,000,000 with a share premium of PLN 60,636,679, both contributed in kind because the payments had already been made. The 2022 annual report describes the acquisition as a transaction between related parties that produced a loss of EUR 540,825, booked in retained earnings rather than the income statement; the claimants' law firm says the nominal price was EUR 1,052 and that Orion was bought from a related party, whom the reports do not name. The 2024 report lists Orion as a wholly owned IT subsidiary consolidated from 2022 and carries it at EUR 12,975,010 at the end of 2023 and EUR 19,272,407 at the end of 2024, after capital increases during 2024.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003", "src-028", "src-013" ], "entity_ids": [ "bbte", "orion", "zonda-token", "znd-ventures", "znd-co", "bb-trade-it", "bb-bahamas" ] }, { "id": "display-claim-20f1861fe72a8cc1006b8d6e", "kind": "analysis", "text": "According to the claimants' law firm, a loan agreement of 4 August 2022, signed by Kral for BB Trade Estonia and by a proxy for Orion, provided for up to EUR 50 million in tranches, each repayable within ten years, at 10% a year, unsecured and convertible into Orion's capital; an annex of 1 January 2024 cut the rate to 4.6%, payable at the end. The firm counts more than 170 ledger entries, a last tranche on 16 March 2026 and a balance of EUR 75,084,120.12, and says monthly payments to Orion, some booked as \"Zen Regular outgoing\", ran through ZEN.com until 31 March 2026. The agreement and the ledger are not in the retained record and no reply by the persons concerned is recorded.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083", "src-075" ], "entity_ids": [ "bbte", "orion", "kral", "zen", "znd-ventures" ] }, { "id": "display-claim-f9dff0232b8904baa28fa138", "kind": "analysis", "text": "The same firm puts the bankruptcy estate's exposure to Orion at about EUR 105 million: EUR 80.6 million of loans with interest and EUR 24.7 million of capital and contributions, transferred until 16 March 2026. It says Orion's 2025 financial statements, not yet filed when it wrote, show related-party loan liabilities rising from PLN 161,432,192 to PLN 334,795,058, about PLN 254 million of receivables from EXPOFÉR SERVIS HOUSE s.r.o. booked as a \"Loan and investment agreement Expofer\", PLN 115 million of prepayments for intangible assets and PLN 188,701 of cash at the end of 2025, when Orion had 47 employees and held the exchange's servers, code and customer database. These figures come from the firm's reading of documents not in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-075", "src-083" ], "entity_ids": [ "bbte", "orion", "expofer" ] }, { "id": "display-claim-d5a67cf8f6edb935961ef6b9", "kind": "analysis", "text": "The firm also says the Nassau accounting of BB Trade Bahamas Ltd, which provided outsourcing services to the exchange from June 2024 and rented its infrastructure, software and virtual addresses from 21 February 2025 for 5% of gross profit a month, was invoiced to Orion Software. It reports too that the Bahamian company traded as \"Coin Accepted\", kept USD 200,000 of capital on deposit for the Securities Commission of The Bahamas and in March 2025 signed a payment-gateway agreement with a currency-exchange office from Wadowice; none of these documents is in the retained record and no reply by the persons concerned is recorded.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bb-bahamas", "bbte", "orion" ] }, { "id": "display-claim-07eaa1c66c3eece87ea13431", "kind": "analysis", "text": "BB Trade Estonia's first annual report, covering 30 September 2019 to 31 December 2020, named LuxBay S.A. of Luxembourg as its parent. In that period the company bought goods and services for EUR 1,300,000 from, and sold services for EUR 2,824,085 to, members of management and owners with significant interests and companies under their control; at 31 December 2020 it had receivables of EUR 6,801,077 from that group, owed it EUR 1,300,000 and had loans of EUR 114,760 and EUR 1,175,696 outstanding (2–3%, in euros and zloty, due 2030). In 2021 it lent EUR 2,700,000 to its new parent company, Divisio Holding AG (2%, due 2041); the 2021 report says the loan was repaid with interest after the balance-sheet date, and the 2022 and 2023 reports show the parent-company receivable at zero at the end of 2022. At the end of 2021 it also had a long-term receivable of EUR 688,390 from legal-entity owners with significant holdings and their companies and owed EUR 1,300,000 to that category, and in 2021 it bought services for EUR 1,728,059 from management, owners and their companies. The reports identify these counterparties only by category.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006", "src-003", "src-028", "src-027" ], "entity_ids": [ "bbte", "luxbay", "divisio" ] }, { "id": "display-claim-2a4b598c5f0fd95c4f77eba9", "kind": "analysis", "text": "The 2022 and 2023 reports show the company buying services from legal-entity owners with significant holdings and their companies for EUR 2,656,173 in 2022 and EUR 2,264,154 in 2023, and from management and private owners for EUR 42,819 and EUR 384,491. A loan to the legal-entity owner category stood at EUR 647,051 (2022) and EUR 660,157 (2023); at the end of 2022 the company owed EUR 2,275,612 to management and private owners and their companies and held a long-term receivable of EUR 371,987 from them. The reports name Divisio Holding A.G. as the parent but identify the other counterparties only by category. At 31 December 2024 short-term receivables and prepayments from legal-entity owners and their companies had reached EUR 30,509,787 (2023: EUR 8,339,160), of which EUR 30,451,398 were prepayments made to a related party that the report does not name. In 2024 the group bought services for EUR 5,457,011 from that category and EUR 332,100 from management and private owners, and management remuneration across the group was EUR 815,129 (2023: EUR 168,986).", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028", "src-027", "src-013" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-100de2985a026809095a7aa9", "kind": "analysis", "text": "Loans receivable were EUR 6,559,687 at the end of 2021 and EUR 5,936,522 at the end of 2022. The 2022 report describes them as euro and zloty loans at 2–3% maturing between January and August 2030, partly unsecured and partly granted to related parties; one, with a remaining balance of EUR 2,878,500, was secured by a mortgage valued at EUR 10 million and another, of EUR 334,136 (PLN 1,500,000), by 18 ETH. At the end of 2023 the eight loans, identified only by number, totalled EUR 12,297,900, including Loan 2 of EUR 2,878,500 (2%, due 2041), Loan 6 of EUR 3,441,429 denominated in crypto-assets and Loan 7 of EUR 2,728,068. By the end of 2024 loans receivable had risen to EUR 93,620,229, mostly Laen 6 (EUR 14,448,098) and Laen 7 (EUR 75,016,307, in crypto-assets), both due in 2025; the report, signed in July 2025, states that EUR 58,264 thousand of them had been returned by 28 July 2025 but does not name the borrowers. Claimants' counsel identifies the borrower of those two loans as AdmiTrade OÜ (see the AdmiTrade page). The 2024 report also lists Laen 4, EUR 407,297 at 2% in zloty and due in 2025, and a long-term receivable of the same amount from management and private owners with significant holdings; it does not name the borrower, and the identification of Przemysław Kral as that borrower is made only by a law firm acting for claimants.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028", "src-003", "src-027", "src-013", "src-010" ], "entity_ids": [ "bbte", "kral" ] }, { "id": "display-claim-c8a558ccf8156aff16b8fa9f", "kind": "analysis", "text": "According to a law firm acting for claimants in the bankruptcy, which says it read the company's contracts, general ledger and bank statements, EUR 30,451,398 of the EUR 30,509,787 owner-related receivable at the end of 2024 was owed by EXPOFÉR SERVIS HOUSE s.r.o. of Ostrava, which management had described in its 2023 related-party statement as Przemysław Kral's company, and the remaining EUR 58,389 was interest on loans to S.B. Bay FZE, Sylwester Suszek's company in the United Arab Emirates. The firm says the Expofér receivable grew from EUR 8,293,987 to EUR 30,451,398 in 2024 while the exchange bought services from Expofér for EUR 2,046,754 in 2023 and EUR 5,041,151 in 2024. The annual report itself does not name Expofér; the identification is the firm's, from a statement and ledgers that are not in the retained record, and no reply by the persons concerned is recorded.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-010" ], "entity_ids": [ "bbte", "expofer", "kral", "sb-bay", "suszek" ] }, { "id": "display-claim-ee27b2c950e1bbcf977c0943", "kind": "analysis", "text": "Expofér also appears in a documented guarantee. Under a contract of 28 December 2020 between UAB ZEN, BB Trade Estonia OÜ and EXPOFÉR SERVIS HOUSE s.r.o. and a further arrangement of 23 September 2022, BB Trade Estonia guaranteed Expofér's obligations up to EUR 567,240 until 31 December 2025 or performance; the 2022 annual report states that the guaranteed obligations were fulfilled in 2022 and no guarantee obligation remained at the end of that year.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003", "src-028" ], "entity_ids": [ "bbte", "expofer", "zen" ] }, { "id": "display-claim-ee9e2f88933a6bc70f186dd3", "kind": "analysis", "text": "The largest related-party flows ran to Orion Software sp. z o.o. in Katowice. A law firm acting for claimants in the bankruptcy states that on 2 March 2020 BB Trade Estonia, then represented by Sylwester Suszek, undertook to recapitalise Orion, at the time a private company of Przemysław Kral with PLN 5,000 of capital, by up to PLN 100,000,000 in monthly payments, and that the same day Orion, represented by Kral, undertook to recapitalise Expofér on the same pattern, with Suszek signing for Expofér as its executive; the documents are not in the retained record and no reply by the persons concerned is recorded. BB Trade Estonia's own 2021 report records prepayments under an investment agreement of EUR 5,498,608 in 2020 and EUR 8,923,511 in 2021, shown as EUR 14,422,121 of financial investments, and states that on 22 July 2022 the company acquired 100% of Orion and paid a PLN 1,000,000 capital increase and a PLN 60,636,679 share premium in kind, because it had already made payments under the investment agreement.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083", "src-003", "src-028" ], "entity_ids": [ "bbte", "orion", "expofer", "kral", "suszek" ] }, { "id": "display-claim-72a1f49ac7e8d6a4f72795b3", "kind": "analysis", "text": "The 2022 annual report states that the July 2022 acquisition was a transaction between related parties and produced a loss of EUR 540,825, recognised in retained earnings of prior periods rather than in the income statement; the reports do not name the seller, while claimants' counsel says the nominal price was EUR 1,052 and that Orion was bought from a related party. The 2024 report carries the Orion holding at EUR 12,975,010 at the end of 2023 and EUR 19,272,407 at the end of 2024, after capital increases during 2024.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028", "src-013" ], "entity_ids": [ "bbte", "orion" ] }, { "id": "display-claim-c88183f087e7344db54ad993", "kind": "analysis", "text": "After the acquisition, according to the same firm, a loan agreement of 4 August 2022, signed by Kral for BB Trade Estonia, provided for EUR 50,000,000 of unsecured tranches to Orion, each repayable within ten years at 10%, convertible into Orion's capital; an annex of 1 January 2024 cut the rate to 4.6% payable at the end. The firm says the last tranche was paid on 16 March 2026 and the loan account stood at EUR 75,084,120.12, and it puts the bankruptcy estate's total exposure to Orion at about EUR 105 million: EUR 80.6 million of loans with interest and EUR 24.7 million of capital and contributions. It adds that Orion's 2025 statements, unfiled when it wrote, show about PLN 254 million of receivables from Expofér and that Orion, with 47 employees, held the exchange's servers, code and customer database. These are the firm's readings of contracts and ledgers that are not in the retained record, and no reply by the persons concerned is recorded; Orion's own profile page sets out its register record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083", "src-075" ], "entity_ids": [ "bbte", "orion", "kral", "expofer" ] }, { "id": "display-claim-eecfdc82c268ca05017c8ce2", "kind": "analysis", "text": "BB Trade Estonia's 2022 cash-flow statement records EUR 792,000 paid for associates, its then 50% interest in ZND Ventures OÜ. According to a law firm acting for claimants in the bankruptcy, an investment agreement of 10 August 2022 with ICEO RED Venture Builder OÜ provided for a jointly owned company financed with EUR 1.5–2 million of interest-free convertible loans; an annex of 24 May 2023 renamed it ZND Ventures OÜ and raised the limit to EUR 4–5 million. The firm says the general ledger shows payments to ZND Ventures of EUR 18,574,553 in total, monthly in 2024 and 2025 and in smaller amounts until 6 March 2026, with conversions to reserve capital of EUR 2,500,000 and EUR 2,414,500 and a remaining balance of EUR 13,660,053. The firm's sources are not in the retained record, and no reply by the persons concerned is recorded.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-028", "src-083" ], "entity_ids": [ "bbte", "znd-ventures", "iceo-red-0" ] }, { "id": "display-claim-f3b0b197956c9c1b9e43a3e2", "kind": "analysis", "text": "The same firm describes BB Trade Bahamas Ltd (company no. 213148 B, Nassau) as trading under the name \"Coin Accepted\", providing outsourcing services to the exchange from June 2024 and, from 21 February 2025, renting its infrastructure, software and virtual addresses for 5% of gross profit a month, with its Nassau accounting invoiced to Orion Software. Citing an internal exchange memo, the firm says that between 18 June and 8 September 2025, 400,000 USDT and 4,900,000 USDC were credited \"via balance adjustment\" to the Bahamian company's technical account, with a note that there was no agreement for this formal loan or investment; the funds were withdrawn to an exchange account, used to buy 18,250,092 ZND tokens that were sold to one user for 997.6 ETH, and part of the ether was sold through AdmiTrade's account at Kraken. Neither the memo nor the contracts are in the retained record, and no reply by the persons concerned is recorded.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083", "src-075" ], "entity_ids": [ "bb-bahamas", "bbte", "orion", "admitrade", "payward" ] }, { "id": "display-claim-6cfde59d52cb03635e071e55", "kind": "analysis", "text": "According to a law firm acting for claimants in the bankruptcy, S.B. Bay FZE, a free-zone company in Umm Al Quwain whose director and owner was Sylwester Suszek, borrowed EUR 500,000, PLN 495,000 and PLN 200,000 from the exchange operator in July and August 2020 at 2% until 2030, with Suszek signing for both sides and crypto-assets on bitbay.net pledged as security; the firm says management's 2023 related-party statement shows nothing repaid at the end of 2023. The firm also states that the company's accounts at SEBA Bank AG received EUR 1,041,826.22 and PLN 1,323,493.15 in June 2023 from a sender named Sylwester Jan Suszek, about fifteen months after his disappearance, which the company's lawyer described as repayments of four personal loans; it treats the question of who controlled the sending account as an open hypothesis that only prosecutors can resolve. The underlying documents are not in the retained record and no reply by the persons concerned is recorded.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte", "sb-bay", "suszek", "amina" ] }, { "id": "display-claim-60e57283bdc06fbed5ff7d20", "kind": "analysis", "text": "The 2021 and 2022 reports list a EUR 2,878,500 loan (2%, due 2041) secured by a mortgage over property valued at EUR 10 million, without naming the borrower. A law firm acting for claimants in the bankruptcy identifies it as a EUR 2,910,000 credit line that Suszek signed for the company on 24 May 2021 with a private individual, Jaromira W., for buying real estate, and says that EUR 2,878,500 went to a notary's escrow account in Nice on 2 June 2021 and that it is not known whether the promised mortgage was ever created. The firm's account rests on contracts, a general ledger and bank statements that are not in the retained record, and no reply by the persons concerned is recorded. The firm also describes a \"ZND Token Exchange Agreement\" concluded for the company by Kral that let her exchange 13,352,871.75 ZND for EUR 7,993,000, exercised on 9 October 2025, the day after a notary issued her a settlement for a property purchase of EUR 7,992,480. In September 2026 prosecutors charged Jaromira W. with, among other things, receiving almost EUR 8 million from the operator's account on 9 October 2025 to buy real estate in France and obtaining a confirmation that a EUR 2.9 million loan had been repaid when it had not; she did not plead guilty and was remanded in custody for three months on 4 September 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083", "src-003", "src-103" ], "entity_ids": [ "bbte", "suszek", "kral" ] }, { "id": "display-claim-d485df9896d6461c7ce997c6", "kind": "analysis", "text": "According to a law firm acting for claimants in the bankruptcy, between 2 and 24 March 2026, in the last weeks before customer withdrawals stopped in early April, fourteen payments totalling EUR 501,037.80 went from the company's accounts to Przemysław Kral's account; the March bank statements also show EUR 105,410.79 of VAT paid, EUR 330,000 transferred to Sygnum Bank on 27 March and EUR 848,163.42 paid to four external recipients. One of the firm's pieces instead describes the fourteen transfers as ordered by the chairman and lists several recipients, and the firm says who ordered and approved them and what they covered is still to be established. The bank statements are not in the retained record and no reply by the persons concerned is recorded.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-075", "src-083" ], "entity_ids": [ "bbte", "kral", "sygnum" ] }, { "id": "display-claim-473d1c8a34b589f426356680", "kind": "analysis", "text": "Citing the trustee's report, which is not in the retained record, the same firm states that Kral replied to the trustee on 15 June 2026 without information on the composition of the assets or source documents, explaining that the servers, cloud, databases and backups were under the control of the Polish authorities, that part of the information was covered by investigative secrecy and that the accountant held the books. To a further demand he replied on 12 August 2026 with an unaudited management balance sheet for the end of 2025 and a list of the company's accounts from memory; the trustee said he could not confirm any asset beyond the cash on the accounts.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-075" ], "entity_ids": [ "kral", "bbte" ] }, { "id": "display-claim-7dace06d15bd4ca1ce759f0e", "kind": "analysis", "text": "On 17 April 2026 the Regional Prosecutor's Office in Katowice opened an investigation concerning the Zondacrypto exchange on the basis of victims' complaints and media reports about withdrawal problems; the release names the brand rather than the operating company and, as an investigation opened \"in the case\", does not itself name suspects or establish an offence (see the investigations page). On 20 April the three members of BB Trade Estonia's supervisory board, Veronika Tugo, Guido Bühler and Georgi Džaniašvili, published a statement that each had resigned that week: they said they had learned of the situation only from public sources after it escalated in the Polish media and that, with ownership and executive management concentrated in one individual whom they did not name, the trust needed for oversight had been undermined. They added that their earlier decisions were made in good faith on the information then available, and register publications record board members and the chair leaving on 15 and 17 April. The same day the Polish payment institution TryPay S.A. terminated its payment-services agreement with \"BB Trade Estonia EU\" with immediate effect after a negative risk assessment, its parent Femion Technology announced.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-065", "src-044", "src-025", "src-104", "src-031" ], "entity_ids": [ "bbte", "tugo", "buhler", "dzaniasvili", "femion", "trypay" ] }, { "id": "display-claim-90d8cacd0509ca0c53f5c043", "kind": "analysis", "text": "Claims against the brand surfaced quickly. On 2 April 2026 a Polish debt-collection agency's website advertised a PLN 173,000 debt owed by \"ZONDACRYPTO\", identified as BB Trade Estonia OÜ and its Milan branch BB Trade IT; the listing names no creditor and cites no judgment. The brand also carried large marketing commitments: according to a law firm acting for claimants, citing the contracts, its agreements with Juventus F.C. (signed by Kral in January 2024, to run until 30 June 2026) and with RKS Raków Częstochowa amounted to about EUR 4.6 million, although the retained passage names the brand rather than the contracting legal entity and the contracts were not retained. In April 2026 Raków's spokesman said the club had started terminating its sponsorship agreement, which had two more years to run. An Estonian business daily wrote on 22 April 2026 that Zondacrypto was FC Flora's main sponsor under a contract to the end of 2028, under a headline saying that 30,000 clients had lost more than EUR 80 million; only the caption and headline are retained, not the article, the contract or the basis of the figure.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-115", "src-083", "src-025", "src-122" ], "entity_ids": [ "bbte", "bb-trade-it", "juventus", "kral", "fc-flora" ] }, { "id": "display-claim-30259ebf1ae156a7ee482b33", "kind": "analysis", "text": "The Estonian Financial Intelligence Unit (FIU) partially suspended the company's virtual-currency licence on 18 May and revoked it on 29 June 2026, stating that BB Trade Estonia had not responded to or complied with its precept; no reply, statement or appeal by the company is in the retained record (details on the licences page). The FIU added that it has no mandate for prudential supervision, including the safekeeping and protection of clients' assets.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-030" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-e64b88aad40aa14c907bd051", "kind": "analysis", "text": "Bankruptcy proceedings against the company began before Harju County Court on 2 July 2026. According to a Polish news report, on 27 July the court barred the company from disposing of its assets without the consent of the interim administrator, Margus Lentsius; the interim order itself is not retained, but the register shows the notice of the disposal ban published on 28 July. The court issued its bankruptcy ruling (pankrotimäärus) on 26 August 2026 in civil case 2-26-14436/10; only the ruling's metadata, not its text, is in the retained record. The declaration was published in the official gazette Ametlikud Teadaanded on 27 August under notice 2641740. The register also lists notices of service in labour-dispute committee proceedings in June and July 2026, whose parties, number and subject are not shown.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-024", "src-108", "src-001", "src-067" ], "entity_ids": [ "bbte", "lentsius" ] }, { "id": "display-claim-2434c8b7d2f346d98cf7694a", "kind": "analysis", "text": "The e-Business Register lists Margus Lentsius as trustee in bankruptcy from 28 August 2026, administering the estate; the register of the Estonian Chamber of Bailiffs and Bankruptcy Trustees lists him, of Advokaadibüroo Lentsius & CASUS OÜ, as entitled to act as a trustee since 15 October 2025. Polish press reported that the court set the first creditors' meeting for 17 September 2026 and gave creditors until 27 October 2026 to file claims. It also reported that the Magnusson law office had represented a client from Vienna on whose petition the court declared the exchange bankrupt; the petition is not retained and the client is not named.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-019", "src-001", "src-108", "src-089" ], "entity_ids": [ "lentsius", "bbte", "magnusson", "keiman" ] }, { "id": "display-claim-69994d191c5ecd49d0dbe5fe", "kind": "analysis", "text": "By 19 October 2026 the register showed a tax debt of EUR 1,997.12 outstanding since 20 April 2026, unfiled VAT, income and social tax returns due from May 2026, an unfiled 2025 annual report, and no taxable turnover or employees reported for the third quarter of 2026.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-001" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-ca5b0ee59014a93cb6b1b76d", "kind": "analysis", "text": "According to Polish press, the first meeting of creditors on 17 September 2026 at Harju County Court kept Lentsius as trustee and unanimously elected a three-member creditors' committee: Damian Przybyłowski of Krajowe Centrum Obsługi Długów, Marek Keiman of the Estonian Magnusson law office and Robert Nogacki, a Warsaw legal adviser nominated by an Estonian advocate. The minutes are not retained, but register data list the same three as members of the bankruptcy committee (pankrotitoimkond) from 1 October 2026. The Estonian Bar Association lists Keiman as a sworn advocate at Advokaadibüroo Magnusson and a partner of the firm, and as a member of the creditors' committees of other Estonian companies, including CoinLoan, Envestio SI and Kuetzal.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-089", "src-024", "src-042", "src-078" ], "entity_ids": [ "bbte", "lentsius", "przybylowski", "keiman", "nogacki", "kcod", "magnusson" ] }, { "id": "display-claim-62c667bf388ddeef147a1b72", "kind": "analysis", "text": "An Estonian business daily reported on 17 September that more than 2,000 people had come forward in the bankruptcy, showing Keiman, who represents claims of EUR 2 million, with Polish lawyers representing EUR 2.3 million; only the headline and caption are retained. In Poland, Krajowe Centrum Obsługi Długów (KCOD), led by licensed restructuring adviser Damian Przybyłowski, invites the exchange's clients to file claims for a fee, which a Polish news report notes gives it a commercial interest; KCOD's own estimate of the potential asset pool, PLN 550–600 million, is the representative's estimate, not assets found or secured by the trustee. KCOD also files, for each client, an application to exclude crypto-assets from the estate and return them in kind as third-party property; Przybyłowski argues that cryptocurrency on a user's account belonged to the client, while the outcome depends on whether specific assets can be identified and attributed. No court or trustee decision on these applications is in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-122", "src-043", "src-108" ], "entity_ids": [ "bbte", "keiman", "kcod", "przybylowski" ] }, { "id": "display-claim-39a3d4a5597360b49a93942a", "kind": "analysis", "text": "Figures reported around the first creditors' meeting measure different things. A Polish news report said the trustee had EUR 167,000 to distribute against liabilities of EUR 432 million and that claims filed by 17 September amounted to EUR 20–30 million; a law firm acting for a group of claimants gave the same EUR 167,000 and EUR 432 million, citing an Estonian report and the interim trustee's report, and said just under 2,000 creditors had filed; in late August another Polish report quoted the trustee as saying total claims could exceed EUR 700 million. These are book liabilities, claims filed by a date and the trustee's projection, reported by the press and claimants' counsel; the trustee's reports are not in the retained record.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-089", "src-075", "src-108", "src-043" ], "entity_ids": [ "bbte", "lentsius" ] }, { "id": "display-claim-3988a238ba6f8a597dfb926a", "kind": "analysis", "text": "Citing the trustee's findings, the same law firm states that on the day of the freeze the operator's balance sheet showed EUR 476 million of assets, of which the trustee could confirm only EUR 167,000 of cash on accounts abroad, the rest being book entries without source documents; that EUR 429 million of liabilities to customers were booked on aggregate accounts without a breakdown by customer; that 77% of the assets in the 2024 statements was one bitcoin address holding 4,503 coins, to which the chief executive, Przemysław Kral, says there is no key although he had stated in a notarised statement in June 2025 that access existed; and that the company had thirteen employees and its bookkeeping ended on 22 April 2026. The trustee's report and the June 2025 statement are not in the retained record; the wallet is described on the cold-wallet page.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-075", "src-108" ], "entity_ids": [ "bbte", "kral" ] }, { "id": "display-claim-ffeeae85d5bcb78d9053da96", "kind": "analysis", "text": "Separately, Roman Giertych, who said on 25 August 2026 that he had been Kral's defence counsel since May, stated that his client had placed \"huge assets\" at the prosecutors' disposal, in his view enough to satisfy all injured persons who had reported; two days later Justice Minister Waldemar Żurek said prosecutors had secured more than PLN 100 million towards future compensation. A Polish news report notes that it is not known whether the two statements concern the same assets, what was secured, to whom it belongs or how it relates to the Estonian bankruptcy, and the National Prosecutor's Office gave no details, citing investigative secrecy.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-108" ], "entity_ids": [ "kral", "bbte" ] }, { "id": "display-claim-4d867f1546eb42ef4199e31c", "kind": "analysis", "text": "On 17 April 2026 the Regional Prosecutor's Office in Katowice opened an investigation concerning Zondacrypto into the misleading of many people as to the possibility of buying and storing fiat currencies and crypto-currencies on the exchange, causing them to dispose of their property disadvantageously (fraud of large value under Article 286 §1 with Articles 294 §1 and 12 §1 of the Polish Penal Code), and into handling funds in ways that could conceal their criminal origin (money laundering under Article 299 §1 and §5). It covers conduct across Poland since 2022, was opened on victims' complaints and media reports about withdrawal problems, put the damage at no less than PLN 350 million and was entrusted to the Wrocław office of the Central Cybercrime Bureau (CBZC). The release names the Zondacrypto brand, not the company operating it, which later releases of the National Prosecutor's Office identify as BB Trade Estonia OÜ; an investigation opened \"in the case\" does not itself name suspects or establish an offence.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-065" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-7a021eb6c76b0e99d4ea4dd9", "kind": "analysis", "text": "The prosecutors' updates describe the scale of the inquiry. On 12 May 2026 they reported 104 electronic devices and more than 13 TB of files from the exchange's production servers secured, requests to more than 100 crypto exchanges to secure funds and data, almost 2,000 complaints received and a European Investigation Order sent to the Czech Republic. On 22 June they reported that a joint investigation team with Estonia had been set up on 28 May, that they had coordinated with Monaco's judicial authorities, and that more than 3,600 complaints had been registered, 162 devices and more than 250 TB of server files secured and 63 search and production orders executed, with requests sent to Italy and Switzerland. Both updates name the brand; the National Prosecutor's Office later identified BB Trade Estonia OÜ as the operator. According to a Polish news-agency report, the Katowice spokesman said on 27 July that the investigation had been extended to 17 January 2027 and that a freeze had been ordered on a French bank account that received EUR 4 million from the sale of a Monaco-registered company whose shareholders are suspects, which a judge of the Paris Court of Appeal ordered seized; the French decision is not retained and the suspects were not named.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-109", "src-029", "src-110", "src-112" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-ecec9607d1cf96ea4c77fd85", "kind": "analysis", "text": "The National Prosecutor's Office has stated that the Katowice investigation (2003-2.Ds.14.2026) was merged into its own case 1001-109.Ds.77.2022, opened on 18 March 2022 into the unlawful deprivation of liberty of Sylwester Suszek, founder of the BitBay exchange, because both examine the founding and activity of BitBay, later ZondaCrypto. The two official texts give different dates for the merger: 19 July 2026 in the release of 28 August and a decision of 30 July 2026 in the Prosecutor General's statement of 25 August.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-094", "src-102" ], "entity_ids": [ "suszek", "bbte" ] }, { "id": "display-claim-d7057ac24f8237aa10da821b", "kind": "analysis", "text": "An earlier investigation had ended. According to a law firm acting for claimants, when the Regional Prosecutor's Office in Katowice discontinued an investigation into blocked withdrawals on the exchange in April 2024, its reasoning noted among other things that the exchange was still operating and sponsoring Juventus; the decision is not in the retained record and no official release on that investigation was retained.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-083" ], "entity_ids": [ "bbte", "juventus" ] }, { "id": "display-claim-4f5ed3938759d038e3dadf8b", "kind": "analysis", "text": "The first charges in the merged case were announced on 28 August 2026. Radosław P., detained the day before, was charged with invoking influence in the consumer-protection office UOKiK in 2025 and undertaking, in return for a watch worth PLN 169,476, to settle UOKiK proceedings against ZondaCrypto and its operator BB Trade Estonia OU, and with inducing a member of the company's management board in April 2026, when it faced insolvency, to pay out PLN 194,420.15 and EUR 100,000 to the detriment of its other creditors, the exchange's users. These are charges, not findings: he did not admit them and gave explanations, and the prosecutor applied for three months' detention; the court's decision is not recorded in the retained releases.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-094" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-c114f99182e3cf13bad83ca9", "kind": "analysis", "text": "On 2 September 2026 prosecutors detained three more people. Anna P. was charged with taking part in 2020–2026 in an organised group aimed at taking over Sylwester Suszek's assets, with causing large-scale damage to the operator of ZondaCrypto (BB Trade Estonia OU), including through the transfer to her of a Katowice property worth PLN 700,000 without payment, and with obstructing the proceedings on Suszek's deprivation of liberty. Jaromira W. was charged with taking part in the same group, with damaging the operator by receiving almost EUR 8 million from its account on 9 October 2025 to buy real estate in France, obtaining a confirmation that a EUR 2.9 million loan had been repaid when it had not and accepting a Katowice property worth PLN 800,000, and with laundering PLN 7.5 million. Rafał Z. was charged with misappropriating PLN 1.7 million of the operator's money entrusted to him. All three did not admit the charges and gave explanations, and on 4 September the court remanded each in custody for three months; a legal news site reported that the regional court upheld the custody decisions. These are charges, not findings of guilt.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-103", "src-095" ], "entity_ids": [ "bbte", "suszek" ] }, { "id": "display-claim-100f808c1d2efd9d9f910d5c", "kind": "analysis", "text": "A legal news site reported that on 7 September 2026 the Prosecutor General's spokesperson announced charges against Roman Ż. of taking part in an organised group aimed at computer fraud against the exchange's users and of misappropriating, with others, PLN 7.8 million of users' funds by altering IT data; the prosecutors' own release is not retained, Roman Ż. did not admit the charges according to the report, and a court ordered his detention, upheld on 18 September. On 23 September prosecutors announced that Artur K., detained on 22 September, had been charged with taking part in a group that interfered with the exchange's IT data, created fictitious receivables and misappropriated at least PLN 7.8 million of users' funds and 3,900 bitcoins handed to a third party as collateral for a loan, with laundering the proceeds, and with failing in his duties as security director of BitBay, later ZondaCrypto. He did not admit the charges and gave explanations; the court's decision on the requested detention is not recorded in the retained release, which names the exchange rather than its operator. These are charges, not findings of guilt.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-095", "src-066" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-8de11d23c53551bc3951f66c", "kind": "analysis", "text": "Further charges are known only second-hand. A legal news site, citing a television report, stated that Marian W. faces charges of unlawfully depriving Suszek of his liberty, of acting to the detriment of BB Trade Estonia OÜ, including by instructing the transfer of nearly EUR 8 million for real estate in France, of leading an organised group intended to take over the assets of Suszek and companies he controlled, including Luxbay S.A., S&B Investment S.A. and BB Trade Estonia OÜ, and of money laundering. The retained official releases do not list these charges, no plea is recorded, and they are charges, not findings.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-095", "src-112" ], "entity_ids": [ "suszek", "bbte", "luxbay", "sb-investment" ] }, { "id": "display-claim-f642cca55e2ff661cc645c8c", "kind": "analysis", "text": "Prosecutors have not officially disclosed the procedural status of Przemysław Kral, the exchange's chief executive: the Prosecutor General's spokesperson, Anna Adamiak, said she could not disclose it. Ewa Wrzosek, a prosecutor serving as general counsel at the Ministry of Justice, said in a radio interview that Kral had begun cooperating and was giving explanations as a suspect and, in her view, had been charged with fraud against the exchange's clients among other things, while Justice Minister Waldemar Żurek said he \"is not a crown witness and is not a witness\". In late July 2026 a Polish daily had reported that Kral was then not a suspect or subject to an arrest warrant. None of these accounts is an official record of charges. Kral's defence counsel, Roman Giertych, said on 25 August 2026 that his client had placed \"huge assets\" at the prosecutors' disposal, enough in his view to satisfy all injured persons who had come forward; two days later the minister said prosecutors had secured more than PLN 100 million for future compensation, and it is not known whether both statements concern the same assets.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-095", "src-112", "src-108" ], "entity_ids": [ "kral" ] }, { "id": "display-claim-e570e8aec42cdaf30a4f390f", "kind": "analysis", "text": "In a statement of 25 August 2026, Prosecutor General Waldemar Żurek said prosecutors could not disclose the suspects or the charges but were verifying information on possible offences connected with ZondaCrypto's funding of the foundation of former Justice Minister Zbigniew Ziobro, the foundation of Przemysław Wipler and others in connection with legislation on the crypto market, Telewizja Republika and its president Tomasz Sakiewicz, the CPAC conference, a possible financial benefit to Radosław Piesiewicz, president of the Polish Olympic Committee, and actions of persons helping former deputy justice minister Marcin Romanowski. He said the priority was to secure as much potentially criminal money as possible for the injured parties. The statement describes lines of inquiry, not findings, and does not say which legal entity made any payment.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-102" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-f5494354db2b3ae8d9851260", "kind": "analysis", "text": "A Polish news report of April 2026 stated, from what it described as publicly available data, that Zondacrypto was the main sponsor of the CPAC Polska conference in May 2025, that Przemysław Kral paid PLN 450,000 to the Instytut Polski Suwerennej foundation of Zbigniew Ziobro at the turn of October and November 2025, and that EXPOFÉR SERVIS HOUSE s.r.o., described as a company from Kral's network, transferred EUR 70,000 to Przemysław Wipler's Fundacja Dobry Rząd. The payment records are not in the retained material, and the Prosecutor General's later statement records verification of such funding, not a finding.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-091" ], "entity_ids": [ "kral", "expofer" ] }, { "id": "display-claim-1c309bc14c435a2572cb10f0", "kind": "analysis", "text": "Estonian proceedings are known only from business-press headlines and captions retained on a business-information card for the company. On 11 May 2026 an Estonian business daily reported that victims were trying to have the firm declared bankrupt in Estonia and that the Prosecutor's Office was considering opening criminal proceedings; on 19 May it reported that criminal proceedings had been opened and that the state prosecutor's office was investigating possible money laundering in connection with the platform, which operated through an Estonian company. No act or statement of the Estonian Prosecutor's Office is in the retained record, and the scope and status of the proceedings are not known.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-122", "src-067" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-59405a51bb116ba83d70e190", "kind": "analysis", "text": "BB Trade Estonia's 2021 annual report states that in July 2021 a Swiss company, Divisio Holding AG, acquired the company's shares and Kral became its ultimate beneficial owner. The current register card lists Divisio as sole owner from 30 March 2022 and Kral as beneficial owner through an indirect holding from 8 March 2022; these dates differ from the July 2021 change in the annual reports, and the register's publication history lists Divisio's entry as shareholder on 14 July 2021, with the difference unexplained in the retained records. A law firm acting for claimants quotes the 2024 ZND token white paper as naming Kral, \"CEO of zondacrypto\", as Divisio's sole shareholder; the white paper is not retained and the Swiss register publications do not disclose Divisio's shareholders.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003", "src-013", "src-001", "src-008" ], "entity_ids": [ "bbte", "divisio", "kral" ] }, { "id": "display-claim-42630406814a70ea3e8bdcfc", "kind": "analysis", "text": "The 2021 annual report records Kral as the company's chief executive and, from November 2021, the second management board member beside Dawid Sendecki, whose membership that report dates from June 2021 although the previous report already listed him in 2020; the register lists him on the board from 8 November 2021 and records a rule under which the company was represented by Kral alone or by two board members jointly, one of them Kral, although the same card says no special representation rules are currently in force and does not show when the rule ceased. He signed the 2023 and 2024 annual reports alone, the latter on 29 July 2025 after a March 2025 restructuring into a two-member management board of Kral and Sendecki and a separate supervisory board. Since 28 August 2026 the trustee in bankruptcy has disposed of the company's estate, while the register still lists Kral on the management board.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003", "src-001", "src-028", "src-027", "src-013" ], "entity_ids": [ "bbte", "sendecki", "kral", "lentsius", "buhler", "dzaniasvili", "chiellini" ] }, { "id": "display-claim-205a4780a0ad67bf74570934", "kind": "analysis", "text": "Registers show Kral at the head of most companies around the brand. In Poland he has been president of the management board of Orion Software sp. z o.o. since 26 March 2020, where the KRS records him as beneficial owner in his capacity as president rather than as a direct shareholder; director of BB Trade Estonia's Polish branch since 16 December 2024, according to the KRS entry as reproduced by a registry-data aggregator; president of Fundacja Zondacrypto since 9 May 2024; and chief executive of BB Trade Poland sp. z o.o., a company held by Divisio whose 2024 accounts show assets of PLN 5 thousand and no revenue, and its liquidator since its shareholders resolved on 15 September 2025 to dissolve it. In Estonia he is procurator of ZND Ventures OÜ since 28 June 2023 and a board member since 20 April 2026, and is recorded as indirect beneficial owner of ZND Ventures and of ZND.CO OÜ.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-055", "src-009", "src-011", "src-007", "src-059", "src-002", "src-045", "src-046" ], "entity_ids": [ "orion", "bbte", "kral", "bbte-pl-branch", "fundacja-zondacrypto", "bb-poland", "divisio", "znd-ventures", "znd-co", "sroka" ] }, { "id": "display-claim-6000e4e07a1918abc0ae0f92", "kind": "analysis", "text": "In Switzerland he was entered on the board of Zonda Token AG at its incorporation in December 2021 and remains registered there after the court-ordered dissolution of 2026, and a SHAB publication of 10 January 2024 entered him as president of the board of BB Trade Switzerland AG without signing authority; he is still listed as a board member of that company in liquidation. He is the sole statutory director of zondacrypto SK, s. r. o. in Slovakia from 25 March 2023 and statutory director of EXPOFÉR SERVIS HOUSE s.r.o. in the Czech Republic from 3 January 2022. The Bahamian securities regulator's register names him principal and a director of BB Trade Bahamas Ltd, and the Florida record lists him as chief executive of BB Trade Florida Inc., without showing who owns that corporation.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-026", "src-062", "src-016", "src-079", "src-014", "src-051", "src-012", "src-002", "src-020", "src-118" ], "entity_ids": [ "zonda-token", "terlinden", "gwozdz", "kral", "bb-switzerland", "buhler", "fenner", "zondacrypto-sk", "expofer", "bb-bahamas", "sendecki", "chipman", "wilkinson", "bb-florida" ] }, { "id": "display-claim-3924921d3358c9ee8756fc8d", "kind": "analysis", "text": "Outside the brand, KRS data show him as sole shareholder of Seed Investments sp. z o.o. since 9 April 2020 (its chief executive until it went into liquidation on 5 January 2026) and of Digesta Pro sp. z o.o. since 11 February 2021 (chief executive until 15 January 2026). He was a management board member of Decori sp. z o.o. from July 2020 to June 2024 and, from 2011 to 2020, a partner of the Katowice advocates and tax advisers partnership Duraj, Reck & Kral. In Luxembourg he has been a director of S&B Investment SA since 13 November 2023, when Sylwester Suszek left its board, according to register publications reproduced by an aggregator that does not name the company's other directors.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-035", "src-007", "src-071", "src-072", "src-015", "src-022" ], "entity_ids": [ "seed-investments", "kral", "gwozdz", "digesta-pro", "decori", "duraj-reck-kral", "suszek", "luxbay", "sb-investment" ] }, { "id": "display-claim-12184830253be48ba64ec396", "kind": "analysis", "text": "Kral also held the largest stake in the parent of the exchange's Polish payment institution. Femion Technology's management report for 2025 shows him with 14,109,812 shares, 49.8674% of its capital, at 31 December 2025; KRS data list him as beneficial owner of Femion and of its wholly owned subsidiary TryPay S.A., the national payment institution that served BB Trade Estonia until it terminated their agreement on 20 April 2026. After the balance-sheet date Femion recorded a loan from Kral of EUR 60,000, increased to EUR 120,000.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-064", "src-033", "src-031" ], "entity_ids": [ "kral", "femion", "trypay", "bbte" ] }, { "id": "display-claim-bd10735d1aa50bddb2e5fa44", "kind": "analysis", "text": "The 2024 annual report lists a EUR 407,297 loan to the category of management and private owners with significant holdings, which a law firm acting for claimants identifies as a loan to Kral personally. The same firm states that between 2 and 24 March 2026 fourteen payments totalling EUR 501,037.80 went from the company's accounts to his account, although another of its pieces describes the transfers as ordered by the chairman with several recipients. The report does not name the borrower, the firm's sources are not in the retained record, and no reply by Kral is recorded.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013", "src-010", "src-075", "src-083" ], "entity_ids": [ "bbte", "kral", "sygnum" ] }, { "id": "display-claim-d096b6143b86ef4994023fb7", "kind": "analysis", "text": "In early April 2026 Kral said in a statement that Zondacrypto was stable, solvent and safe and called a press analysis of a 99% fall in its bitcoin reserves erroneous and harmful. On 16 April he said publicly that the keys to the roughly 4,500-bitcoin wallet were held by Sylwester Suszek, missing since March 2022, and the company identified an address holding 4,503 BTC as its cold wallet. The Katowice prosecutors' release of 17 April summarised the owner's statement that the exchange had had no access to that wallet since 2022 and that this had been concealed from clients; the release is a summary, not a finding. A law firm acting for claimants says the address is a wallet dormant since 2016, and neither its reading nor the company's account is verified in the retained record. In the bankruptcy, according to the same firm citing the trustee's report, the trustee could confirm only about EUR 167,000 of cash on accounts abroad, while the chief executive maintains that there is no key to the address, which accounted for 77% of the assets in the 2024 statements.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-065", "src-112", "src-008", "src-083", "src-075" ], "entity_ids": [ "bbte", "kral", "suszek" ] }, { "id": "display-claim-1d0ac4d6097469a337755eab", "kind": "analysis", "text": "When claimants' counsel and complainants said the company had moved crypto-assets worth more than PLN 76 million to the Kraken exchange before the crisis, the company explained such transfers to customers as market making, and on 14 April 2026 Kral wrote that investing customer funds was not to be confused with liquidity management; no transfer records are retained. In the bankruptcy, according to the same firm citing the trustee's report, which is not in the retained record, Kral answered the trustee in June and August 2026 that the servers and data were under the Polish authorities' control and that the accountant held the books, providing an unaudited balance sheet for the end of 2025 and a list of accounts from memory.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-008", "src-075" ], "entity_ids": [ "bbte", "payward", "kral" ] }, { "id": "display-claim-8a744bc3e3db22323390d59f", "kind": "analysis", "text": "Prosecutors have not disclosed whether Kral is a suspect. A prosecutor serving at the Ministry of Justice said he was cooperating and giving explanations as a suspect, the justice minister said he \"is not a crown witness and is not a witness\", and a July 2026 newspaper report said he was then not a suspect; none of these is an official record of charges. His defence counsel, Roman Giertych, said Kral had placed \"huge assets\" at the prosecutors' disposal, and the minister said prosecutors had secured more than PLN 100 million for compensation; it is not known whether both statements concern the same assets or how they relate to the Estonian bankruptcy.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-095", "src-112", "src-108" ], "entity_ids": [ "kral", "bbte" ] }, { "id": "display-claim-cd3306d722a3371b6f0b4722", "kind": "analysis", "text": "A Polish news report of April 2026 stated, from publicly available data, that Kral paid PLN 450,000 to Zbigniew Ziobro's foundation Instytut Polski Suwerennej at the turn of October and November 2025 and that EXPOFÉR SERVIS HOUSE, described as part of his network, gave EUR 70,000 to Przemysław Wipler's foundation; the payment records are not retained, and the Prosecutor General has said only that such funding is being verified.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-091" ], "entity_ids": [ "kral", "expofer" ] }, { "id": "display-claim-3dbb00fb237ef3fdf297efc9", "kind": "analysis", "text": "The dossier separates the zondacrypto brand from the companies behind it: BB Trade Estonia OÜ as the licensed operator, its parent Divisio Holding AG, the Swiss, Polish, Slovak, Bahamian and other entities, and the earlier BitBay companies. It sets the company's own annual reports, including the auditors' disclaimer and qualified opinions on its crypto-assets, beside the register records, regulators' decisions, the bankruptcy and the Polish prosecutors' releases, and keeps the accounts of claimants' counsel, the press and the company attributed to their speakers with the replies and outcomes found.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-001", "src-006", "src-003", "src-028", "src-027", "src-013", "src-039", "src-113", "src-107", "src-004", "src-094", "src-096", "src-008", "src-005", "src-099", "src-083", "src-065", "src-112", "src-044", "src-025", "src-104", "src-031", "src-081", "src-030", "src-024", "src-019", "src-089", "src-075", "src-108", "src-043", "src-029", "src-110", "src-102", "src-103", "src-095", "src-066", "src-010", "src-014", "src-082", "src-048" ], "entity_ids": [ "bbte", "bb-switzerland", "incore", "sobkow", "luxbay", "suszek", "divisio", "kral", "lentsius", "terlinden", "admitrade", "sroka", "crowe-dnw", "mullo", "assertum", "tsistjakov", "tugo", "buhler", "dzaniasvili", "femion", "trypay", "fenner", "bb-bahamas", "sygnum", "amina" ] }, { "id": "display-claim-02eb358330870a01e48090a4", "kind": "analysis", "text": "BB Trade Estonia OÜ is a private limited company entered in the Estonian Commercial Register on 30 September 2019 as Pinewood Estonia OÜ and renamed on 13 February 2020; its register card now gives its status as bankrupt. Its annual reports describe it as the operator of the BitBay.net platform in 2019–2020, of the Zonda platform, rebranded Zonda Global in November 2021, and of the zondacrypto exchange from 2022, holding Estonian virtual-currency licence FVT000209, and the exchange's terms of service of October 2025 name it as the provider of the services.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-001", "src-006", "src-003", "src-028", "src-027", "src-013", "src-039" ], "entity_ids": [ "bbte" ] }, { "id": "display-claim-c2512614de92a9d989c9b5f8", "kind": "analysis", "text": "The brand and the company are not the same thing. A January 2025 press release issued for the brand with Incore Bank says that \"zondacrypto\" is a trademark identifying the services of several group entities and does not by itself refer to any single legal entity; clients of the zondacrypto Swiss platform contracted with BB Trade Switzerland AG, which handled orders and fiat money, and with BB Trade Estonia OÜ, which executed the digital-asset side. Estonia's financial supervisor, a release of Poland's National Prosecutor's Office of 28 August 2026 and Swiss specialist press all identify BB Trade Estonia OÜ as the operator of the brand's exchange.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-113", "src-107", "src-004", "src-094", "src-096" ], "entity_ids": [ "bbte", "bb-switzerland", "incore" ] }, { "id": "display-claim-e08df9bd9c2c33909af42803", "kind": "analysis", "text": "Paweł Sobków, the first sole shareholder, transferred all shares in February 2020 to Luxbay SA of Luxembourg, through which Sylwester Jan Suszek became the ultimate beneficial owner. In July 2021, according to the annual reports, Divisio Holding AG of Zug acquired the company and Przemysław Kral became its beneficial owner. The current register card dates Divisio's 100% holding from 30 March 2022 and Kral's indirect beneficial ownership from 8 March 2022; the register's publication history lists Divisio's entry as shareholder on 14 July 2021, and the retained records do not explain the difference.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-006", "src-003", "src-013", "src-001" ], "entity_ids": [ "bbte", "sobkow", "luxbay", "suszek", "divisio", "kral" ] }, { "id": "display-claim-fa1341c02a02083d0fe38af7", "kind": "analysis", "text": "Divisio's own shareholders are not disclosed in its Swiss register publications. A law firm acting for claimants quotes the ZND token white paper of June 2024 as naming Kral as Divisio's sole shareholder; the white paper itself is not in the retained record. The Estonian register separately records Kral as BB Trade Estonia's beneficial owner through an indirect holding, and he has been a member of its management board since 8 November 2021. Divisio's only board member, André Marcel Terlinden, left in April 2026, after which its register summary showed no registered managers.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-008", "src-001", "src-005", "src-099" ], "entity_ids": [ "divisio", "kral", "bbte", "lentsius", "terlinden" ] }, { "id": "display-claim-c356757fb1076dbb816649be", "kind": "analysis", "text": "BB Trade Estonia's consolidated report for 2024 shows client assets and liabilities of EUR 722,356,044 at 31 December 2024. Of EUR 648,160,309 owed to clients in crypto-assets, EUR 565,415,120 was the liability for clients' crypto-assets and EUR 82,745,189 arose from the company's use of client funds, which its client agreement allowed. The same report shows loans receivable of EUR 93,620,229, mostly two unnamed loans of EUR 14,448,098 and EUR 75,016,307 maturing in 2025, of which EUR 58,264 thousand had been returned by 28 July 2025. A law firm acting for claimants matches the two balances to the euro with a credit line to AdmiTrade OÜ, a company of Wojciech Sroka, and says AdmiTrade returned EUR 58,264,534 in crypto-assets under a termination agreement of 28 July 2025. The annual report does not name AdmiTrade, the contracts, ledger and bank statements the firm relies on are not in the retained record, and no reply by the persons concerned is recorded.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-013", "src-083" ], "entity_ids": [ "bbte", "admitrade", "sroka", "kral" ] }, { "id": "display-claim-b859057d73f7ae24a9d8225c", "kind": "analysis", "text": "Auditors repeatedly could not confirm the crypto-assets. Crowe DNW OÜ disclaimed an opinion on the 2021 statements, mainly because bitcoin worth about EUR 145.7 million was held, according to the company, in a wallet to which management had restricted access. Assertum Audit OÜ qualified its opinions on 2022, when crypto-assets were partly held by providers that issue no confirmations, and on 2023, when it could not test the group's control of EUR 172 million of crypto-assets and management proposed a notarial confirmation instead. Assertum's opinion on the 2024 consolidated statements, dated 29 July 2025, was unqualified.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-003", "src-028", "src-027", "src-013" ], "entity_ids": [ "bbte", "crowe-dnw", "mullo", "assertum", "tsistjakov" ] }, { "id": "display-claim-b84fd1006e1ef957ff512557", "kind": "analysis", "text": "In early April 2026 Kral called the exchange stable, solvent and safe. When the Regional Prosecutor's Office in Katowice opened its investigation on 17 April, it summarised a statement by the exchange's owner that since 2022 the exchange had had no access to a cold wallet said to hold about 4,500 BTC and that this had been concealed from clients — a summary, not a finding, which does not say how or when access was lost; on 16 April Kral had said publicly that the keys were held by Sylwester Suszek, the founder of the predecessor exchange BitBay, who has been missing since March 2022. On 20 April 2026 the three supervisory-board members, whose departures register publications date to 15 and 17 April, said in their own statement that they had learned of the situation only from public sources, that ownership and executive management had been concentrated in one individual, whom they did not name, and that their earlier decisions had been made in good faith. The same day the payment institution TryPay S.A. terminated its payment services to the company with immediate effect.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-065", "src-112", "src-044", "src-025", "src-104", "src-031" ], "entity_ids": [ "bbte", "kral", "suszek", "tugo", "buhler", "dzaniasvili", "femion", "trypay" ] }, { "id": "display-claim-8f04914354c66da670eee6da", "kind": "analysis", "text": "The Estonian Financial Intelligence Unit (FIU) partially suspended the company's licence on 18 May 2026 and revoked it on 29 June 2026, stating that the company had neither responded to nor complied with its precept, and no reply or appeal by the company is in the retained record; the FIU added that it has no mandate for prudential supervision of the safekeeping of clients' assets. Harju County Court, in proceedings begun on 2 July 2026, declared the company bankrupt on 26 August 2026 (only the ruling's metadata, not its text, is retained), and Margus Lentsius became trustee of the estate. Figures reported by the press and claimants' counsel around the first creditors' meeting measure different things: EUR 167,000 available to the trustee against liabilities of EUR 432 million, EUR 20–30 million of claims filed by 17 September 2026, and a projection by the trustee that total claims could exceed EUR 700 million.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-081", "src-030", "src-024", "src-019", "src-001", "src-089", "src-075", "src-108", "src-043" ], "entity_ids": [ "bbte", "lentsius" ] }, { "id": "display-claim-ea1550a34207b919e8c90908", "kind": "analysis", "text": "The Katowice investigation, opened on 17 April 2026 without naming any suspect or establishing an offence, concerns suspected large-value fraud against people misled about buying and storing fiat and crypto-currencies on the exchange since 2022, and money laundering, with damage put at no less than PLN 350 million. By 22 June 2026 more than 3,600 criminal complaints had been registered and a joint investigation team with Estonia had been set up. The early releases named only the ZondaCrypto brand; the National Prosecutor's Office later identified BB Trade Estonia OÜ as the exchange's operator. In July 2026 (on 19 or 30 July, depending on the official text) the case was merged into the investigation, opened in March 2022 and now led by the National Prosecutor's Office, into the unlawful deprivation of liberty of Sylwester Suszek; prosecutors say both cases examine the founding and activity of the BitBay, later ZondaCrypto, exchange.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-065", "src-029", "src-110", "src-112", "src-094", "src-102" ], "entity_ids": [ "bbte", "suszek" ] }, { "id": "display-claim-c8e178a8f265209f8c5b5ae3", "kind": "analysis", "text": "Since late August 2026 prosecutors have charged several private individuals, identified by initials, with offences including misappropriating the operator's funds and causing it large-scale damage; these are charges, not findings of guilt, and the suspects did not admit them. A court remanded three of them in custody for three months on 4 September 2026, and a legal news site reported that the regional court in Katowice upheld the custody decisions; the retained releases do not record the courts' decisions on the prosecutors' detention applications for the other two. Kral's own procedural status has not been officially disclosed, and the accounts differ. In late July 2026 a Polish daily reported that he was then not a suspect and that Polish officials had met him to discuss cooperation, on which the National Prosecutor's Office declined to comment; later a prosecutor serving at the Ministry of Justice said in a radio interview that he was giving explanations as a suspect, while the justice minister said he \"is not a crown witness and is not a witness\". His defence counsel said on 25 August 2026 that Kral had placed \"huge assets\" at the prosecutors' disposal; two days later the justice minister said that more than PLN 100 million had been secured for future compensation, and it is not known whether both statements concern the same assets.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-094", "src-103", "src-095", "src-066", "src-112", "src-108" ], "entity_ids": [ "bbte", "suszek", "kral" ] }, { "id": "display-claim-a6392f7d3bea4ea698ce2acf", "kind": "analysis", "text": "Several questions remain open in the retained record. No record shows who owned BB Trade Switzerland AG, whose shareholders appear only in its private share register and which its general meeting dissolved on 16 July 2026; claimants' counsel calls it a wholly owned subsidiary, but it is absent from the 2024 consolidation list. Nor does any record show who owns BB Trade Bahamas Ltd, which the 2024 report lists in its consolidation group while its legal entity identifier record names no parent and the Bahamian securities register names Kral as its principal. Whether the January 2025 sale of the company's AMINA Bank participation certificates closed, and where the price went, is not shown beyond claimants' counsel's reading of the ledgers. Neither the company's 2026 account of a 4,503 BTC cold wallet nor claimants' counsel's reading of the address on the public blockchain is verified; in the bankruptcy, according to that counsel citing the trustee's report, the trustee could confirm only about EUR 167,000 of cash on accounts abroad, and the chief executive maintains that there is no key to the address, which accounted for 77% of the assets in the 2024 statements.", "qualification": "", "response": "", "outcome": "", "source_ids": [ "src-010", "src-014", "src-013", "src-082", "src-048", "src-008", "src-083", "src-075" ], "entity_ids": [ "bb-switzerland", "bbte", "fenner", "buhler", "bb-bahamas", "sygnum", "amina", "kral", "suszek" ] } ], "sources": [ { "id": "src-001", "title": "e-Business Register company card: BB Trade Estonia OÜ (registry code 14814864)", "publisher": "Centre of Registers and Information Systems (RIK), Estonian e-Business Register", "date": "2026-10-19", "locator": "Company card: general data, contacts, tax data, owners, beneficial owners, representatives, publications", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "corporate_registry", "publisher_type": "registry_operator", "url": "https://ariregister.rik.ee/est/company/14814864" }, { "id": "src-002", "title": "Corporate registry source · src-002", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "corporate_registry", "publisher_type": "corporate", "url": "" }, { "id": "src-003", "title": "Annual report of BB Trade Estonia OÜ for 2021, filed with the Estonian Commercial Register", "publisher": "Centre of Registers and Information Systems (RIK), Estonian e-Business Register", "date": "2022-11-30", "locator": "Management report, consolidated notes and independent auditor's report", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "company_statement", "publisher_type": "registry_operator", "url": "https://ariregister.rik.ee/est/company/14814864/file/9009573637" }, { "id": "src-004", "title": "Warning notice (hoiatusteade) of 6 May 2026 concerning BB Trade Estonia OÜ", "publisher": "Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority)", "date": "2026-05-06", "locator": "Warning notice", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "regulatory_record", "publisher_type": "regulator", "url": "https://www.fi.ee/sites/default/files/2026-05/hoiatusteade-bb-trade-estonia-ou.pdf" }, { "id": "src-005", "title": "Corporate registry source · src-005", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; 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identifying metadata omitted.", "source_type": "corporate_registry", "publisher_type": "corporate", "url": "" }, { "id": "src-063", "title": "Corporate registry source · src-063", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "corporate_registry", "publisher_type": "corporate", "url": "" }, { "id": "src-064", "title": "Company statement source · src-064", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "company_statement", "publisher_type": "corporate", "url": "" }, { "id": "src-065", "title": "Śledztwo w sprawie Zondacrypto (investigation concerning Zondacrypto)", "publisher": "Prokuratura Regionalna w Katowicach (Regional Prosecutor's Office in Katowice)", "date": "2026-04-17", "locator": "Communication of 17 April 2026", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "other", "publisher_type": "government", "url": "https://www.gov.pl/web/pr-katowice/sledztwo-w-sprawie-zondacrypto" }, { "id": "src-066", "title": "ZondaCrypto: zarzuty dla Artura K. i wniosek o tymczasowe aresztowanie (charges against Artur K.)", "publisher": "Prokuratura Krajowa (Polish National Prosecutor's Office)", "date": "2026-09-23", "locator": "Communication of 23 September 2026", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "other", "publisher_type": "government", "url": "https://www.gov.pl/web/prokuratura-krajowa/zondacrypto-zarzuty-dla-artura-k-i-wniosek-o-tymczasowe-aresztowanie" }, { "id": "src-067", "title": "Corporate registry source · src-067", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; 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identifying metadata omitted.", "source_type": "other", "publisher_type": "corporate", "url": "" }, { "id": "src-084", "title": "Media source · src-084", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "media", "publisher_type": "media", "url": "" }, { "id": "src-085", "title": "Regulatory record source · src-085", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "regulatory_record", "publisher_type": "regulator", "url": "" }, { "id": "src-086", "title": "Company statement source · src-086", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "company_statement", "publisher_type": "corporate", "url": "" }, { "id": "src-087", "title": "Media source · src-087", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "media", "publisher_type": "corporate", "url": "" }, { "id": "src-088", "title": "Other source · src-088", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "other", "publisher_type": "corporate", "url": "" }, { "id": "src-089", "title": "Media source · src-089", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "media", "publisher_type": "media", "url": "" }, { "id": "src-090", "title": "Company statement source · src-090", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "company_statement", "publisher_type": "corporate", "url": "" }, { "id": "src-091", "title": "Media source · src-091", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "media", "publisher_type": "media", "url": "" }, { "id": "src-092", "title": "VAT registrants list, July 2026", "publisher": "Department of Inland Revenue, The Bahamas", "date": "2026-07", "locator": "VAT registrant list", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "regulatory_record", "publisher_type": "government", "url": "https://inlandrevenue.finance.gov.bs/wp-content/uploads/2026/07/VAT-list-July-2026.pdf" }, { "id": "src-093", "title": "e-Business Register company card: AdmiTrade OÜ (registry code 16309521)", "publisher": "Centre of Registers and Information Systems (RIK), Estonian e-Business Register", "date": "2026-10-19", "locator": "Company card", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "corporate_registry", "publisher_type": "registry_operator", "url": "https://ariregister.rik.ee/est/company/16309521" }, { "id": "src-094", "title": "Zarzuty dla Radosława P. w śledztwie dotyczącym ZondaCrypto (charges against Radosław P.)", "publisher": "Prokuratura Krajowa (Polish National Prosecutor's Office)", "date": "2026-08-28", "locator": "Communication of 28 August 2026", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "other", "publisher_type": "government", "url": "https://www.gov.pl/web/prokuratura-krajowa/zarzuty-dla-radoslawa-p-w-sledztwie-dotyczacym-zondacrypto" }, { "id": "src-095", "title": "Media source · src-095", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "media", "publisher_type": "media", "url": "" }, { "id": "src-096", "title": "Media source · src-096", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "media", "publisher_type": "media", "url": "" }, { "id": "src-097", "title": "Company statement source · src-097", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "company_statement", "publisher_type": "corporate", "url": "" }, { "id": "src-098", "title": "Media source · src-098", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "media", "publisher_type": "media", "url": "" }, { "id": "src-099", "title": "SHAB publication HR01-1005231846: new entry Divisio Holding AG, Zug", "publisher": "Swiss Official Gazette of Commerce (SHAB)", "date": "2021-06-29", "locator": "Publication HR01-1005231846", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "corporate_registry", "publisher_type": "government", "url": "https://www.shab.ch/shabforms/servlet/Search?EID=7&DOCID=HR01-1005231846" }, { "id": "src-100", "title": "Register of virtual-currency service providers (export)", "publisher": "Organismo Agenti e Mediatori (OAM), Italy", "date": "", "locator": "Register export, entry PSV48", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "regulatory_record", "publisher_type": "registry_operator", "url": "https://www.organismo-am.it/documenti/elenchi/EsportazioneRegistroValutaVirtuale.csv" }, { "id": "src-101", "title": "Corporate registry source · src-101", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "corporate_registry", "publisher_type": "corporate", "url": "" }, { "id": "src-102", "title": "Oświadczenie Prokuratora Generalnego dotyczące śledztwa w sprawie giełdy kryptowalutowej ZondaCrypto (statement of the Prosecutor General)", "publisher": "Prokuratura Krajowa (Polish National Prosecutor's Office)", "date": "2026-08-25", "locator": "Statement of 25 August 2026", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "other", "publisher_type": "government", "url": "https://www.gov.pl/web/prokuratura-krajowa/zondacrypto-oswiadczenie" }, { "id": "src-103", "title": "Wnioski o tymczasowe aresztowanie wobec kolejnych 3 osób w sprawie ZondaCrypto (applications for detention of three further persons)", "publisher": "Prokuratura Krajowa (Polish National Prosecutor's Office)", "date": "2026-09-03", "locator": "Communication of 3 September 2026", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "other", "publisher_type": "government", "url": "https://www.gov.pl/web/prokuratura-krajowa/wnioski-o-tymczasowe-aresztowanie-wobec-kolejnych-3-osob-w-sprawie-zondacrypto" }, { "id": "src-104", "title": "Corporate registry source · src-104", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "corporate_registry", "publisher_type": "corporate", "url": "" }, { "id": "src-105", "title": "Other source · src-105", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "other", "publisher_type": "corporate", "url": "" }, { "id": "src-106", "title": "Media source · src-106", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "media", "publisher_type": "media", "url": "" }, { "id": "src-107", "title": "Company statement source · src-107", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "company_statement", "publisher_type": "corporate", "url": "" }, { "id": "src-108", "title": "Media source · src-108", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "media", "publisher_type": "media", "url": "" }, { "id": "src-109", "title": "Informacja o czynnościach w sprawie ZondaCrypto (information on actions in the ZondaCrypto case)", "publisher": "Prokuratura Regionalna w Katowicach (Regional Prosecutor's Office in Katowice)", "date": "2026-05-12", "locator": "Communication of 12 May 2026", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "other", "publisher_type": "government", "url": "https://www.gov.pl/web/pr-katowice/informacja-o-czynnosciach-w-sprawie-zondacrypto" }, { "id": "src-110", "title": "Aktualizacja w sprawie ZondaCrypto (update on the ZondaCrypto case)", "publisher": "Prokuratura Regionalna w Katowicach (Regional Prosecutor's Office in Katowice)", "date": "2026-06-22", "locator": "Communication of 22 June 2026", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "other", "publisher_type": "government", "url": "https://www.gov.pl/web/pr-katowice/aktualizacja-w-sprawie-zondacrypto" }, { "id": "src-111", "title": "Precepts (ettekirjutused) published by the Financial Intelligence Unit", "publisher": "Rahapesu Andmebüroo (Estonian Financial Intelligence Unit)", "date": "", "locator": "Precept register, 2023 and 2025 entries", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "regulatory_record", "publisher_type": "regulator", "url": "https://fiu.ee/tegevusluba-ja-jarelevalve/ettekirjutused" }, { "id": "src-112", "title": "Media source · src-112", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; 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identifying metadata omitted.", "source_type": "other", "publisher_type": "corporate", "url": "" }, { "id": "src-117", "title": "Media source · src-117", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "media", "publisher_type": "media", "url": "" }, { "id": "src-118", "title": "Detail by entity name: BB TRADE FLORIDA INC. (document number P24000070168)", "publisher": "Florida Department of State, Division of Corporations", "date": "", "locator": "Corporation detail record", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "corporate_registry", "publisher_type": "government", "url": "https://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=EntityName&directionType=Initial&searchNameOrder=BBTRADEFLORIDA%20P240000701680&aggregateId=domp-p24000070168-bde1acb7-6ae3-4e07-aedd-103dfbb4d676&searchTerm=BB%20TRADE%20FLORIDA&listNameOrder=BBTRADEFLORIDA%20P240000701680" }, { "id": "src-119", "title": "e-Business Register company card: Assertum Audit OÜ (registry code 10990446)", "publisher": "Centre of Registers and Information Systems (RIK), Estonian e-Business Register", "date": "2026-10-19", "locator": "Company card", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "corporate_registry", "publisher_type": "registry_operator", "url": "https://ariregister.rik.ee/est/company/10990446" }, { "id": "src-120", "title": "e-Business Register company card: Crowe DNW OÜ (registry code 14299250)", "publisher": "Centre of Registers and Information Systems (RIK), Estonian e-Business Register", "date": "2026-10-19", "locator": "Company card", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "corporate_registry", "publisher_type": "registry_operator", "url": "https://ariregister.rik.ee/est/company/14299250" }, { "id": "src-121", "title": "e-Business Register company card: Audit Advisory OÜ (registry code 11556099)", "publisher": "Centre of Registers and Information Systems (RIK), Estonian e-Business Register", "date": "2026-10-19", "locator": "Company card", "basis": "Retained copy of the document in the frozen case database, read in the passages cited by the claims.", "source_type": "corporate_registry", "publisher_type": "registry_operator", "url": "https://ariregister.rik.ee/est/company/11556099" }, { "id": "src-122", "title": "Media source · src-122", "publisher": "", "date": "", "locator": "", "basis": "Source classification retained; identifying metadata omitted.", "source_type": "media", "publisher_type": "media", "url": "" } ], "atlas": { "version": "1.0", "reference": "dudil-report-assembler/2.19.0", "default_view": "target_overview", "hypotheses_default": true, "path_policy": "evidence_first", "context_entity_ids": [ "bbte", "divisio", "kral", "luxbay", "suszek", "sobkow", "terlinden", "sendecki", "buhler", "bb-switzerland", "orion", "znd-ventures", "zonda-token", "bb-bahamas", "admitrade", "iceo-red-0", "sroka", "trypay", "femion", "amina", "expofer", "lentsius" ] }, "case_id": "bb-trade-estonia-ou", "version": "1.0", "as_of": "2026-10-19" }