--- title: "Evidence records" language: en canonical: https://dossiertwist.com/dossiers/bb-trade-estonia-ou/evidence-records/ as_of: 2026-10-19 keywords: ["BB Trade Estonia OÜ","Pinewood Estonia OÜ","zondacrypto","Zonda Global","BitBay","Divisio Holding AG","Przemysław Kral","Sylwester Suszek","BB Trade Switzerland AG","Orion Software","AdmiTrade OÜ","virtual currency licence FVT000209","Estonian Financial Intelligence Unit","Harju County Court bankruptcy","Prokuratura Krajowa","TryPay","AMINA Bank","client funds","crypto-asset custody","MiCA"] --- # Evidence records **Question.** Which records support the articles? **Answer.** Full assertions with source references, qualifications, responses and known outcomes. The topic articles explain these records in context. ## BB Trade Estonia OÜ: register record, names and filings - Documented: 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. [src-001] - Documented: 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. [src-001] - Documented: 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. [src-001] [src-006] - Documented: 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. [src-003] [src-006] [src-028] [src-104] - 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. - Documented: 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. [src-028] [src-104] [src-006] [src-003] - 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. - Documented: 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. [src-001] [src-028] - 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. - Documented: 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. [src-104] - 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. - Documented: 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. [src-067] - 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. - Documented: 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. [src-001] [src-067] - 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. - Documented: 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. [src-001] - Documented: 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). [src-003] ## From BitBay to zondacrypto: which company ran the exchange? - Documented: 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. [src-006] - Documented: 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. [src-003] - Documented: 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. [src-028] [src-027] [src-013] - Documented: 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. [src-039] - Documented: 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. [src-039] - Documented: 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. [src-086] - Documented: 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. [src-113] - Documented: 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. [src-107] - Documented: 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. [src-107] [src-086] - Documented: 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. [src-052] - Documented: 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. [src-114] - Documented: 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. [src-004] [src-094] [src-096] - Attributed: 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. [src-008] - 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. - Attributed: 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. [src-088] - Qualification: Quotation of a management report that the law firm says it read; the report itself is not in the retained record. - Documented: 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. [src-023] - Documented: 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. [src-023] - Documented: 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. [src-077] - 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. - Documented: 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. [src-058] [src-021] - Attributed: 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. [src-088] - Qualification: The firm's reading of registry documents that are not themselves in the retained record. - Attributed: 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. [src-088] - 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. - Documented: 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. [src-015] - Documented: 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. [src-056] [src-006] - 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. - Attributed: 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. [src-074] - 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. - Attributed: 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. [src-074] - 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. - Documented: 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. [src-101] - 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. ## Who owns BB Trade Estonia OÜ? - Documented: 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. [src-006] - Documented: 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. [src-104] - 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. - Documented: 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. [src-047] - Documented: 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. [src-003] [src-013] - Documented: 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. [src-001] - 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. - Documented: 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. [src-005] [src-099] - Documented: 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. [src-005] [src-099] - Documented: 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. [src-005] [src-002] [src-063] - Qualification: A shared business address does not by itself establish any link between the companies registered there. - Attributed: 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. [src-008] - 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. - Attributed: 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. [src-008] [src-013] - 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. - Attributed: 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. [src-010] - 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. - Attributed: 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. [src-091] - Qualification: Press account; the list of entities registered at the firm's premises is not in the retained record. - Documented: 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. [src-063] ## Who ran BB Trade Estonia OÜ? Boards and the 2026 resignations - Documented: 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. [src-006] - Documented: 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. [src-003] - 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. - Documented: 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. [src-001] - Documented: 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. [src-001] - 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. - Documented: 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. [src-028] [src-027] - Documented: 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. [src-028] - Documented: 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. [src-009] - Documented: 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. [src-013] - Documented: 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. [src-104] - 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. - Unresolved: 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. [src-098] [src-028] - 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. - Documented: 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. [src-004] - Attributed: 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. [src-025] [src-104] - 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. - Attributed: 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. [src-044] [src-025] [src-104] - 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. - Documented: 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. [src-024] - Qualification: The listing does not disclose what the applications or entries concerned. - Attributed: 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. [src-010] [src-069] - 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. ## Which companies did BB Trade Estonia own or consolidate? - Documented: 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). [src-013] - Documented: 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. [src-013] - Documented: 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. [src-003] - Documented: 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. [src-026] [src-062] - Unresolved: 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. [src-008] [src-013] [src-062] - 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. - 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. - Documented: 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. [src-062] [src-016] - Documented: 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. [src-062] - Documented: 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. [src-045] - Documented: 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. [src-045] - Documented: 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. [src-028] - Attributed: 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. [src-010] - Qualification: This is the law firm's reading of accounting records obtained in the bankruptcy; the general ledger is not in the retained record. - Documented: 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. [src-046] - Documented: 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. [src-046] - Attributed: 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. [src-008] [src-013] - 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. - Documented: 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. [src-055] - Qualification: The beneficial-owner entry describes Kral as the company's president; the KRS data do not show him holding shares in Orion directly. - Documented: 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. [src-055] - 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. - Documented: 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. [src-009] - Qualification: Read through a commercial aggregator's reproduction of the KRS entry. - Documented: 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. [src-013] [src-100] - Documented: 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. [src-003] - Qualification: The report gives no shareholding, registration number or later status for Zonda Gibraltar Ltd, and no Gibraltar register record was retained. - Documented: 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". [src-036] [src-053] - 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. - Documented: 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. [src-054] - Attributed: 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. [src-010] - 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. - Documented: 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. [src-037] - Documented: 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. [src-020] - Documented: 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. [src-092] [src-048] - Unresolved: 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. [src-048] [src-010] [src-013] - 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. - Documented: Zonda Token AG's Swiss enterprise identifier (UID) is CHE-221.704.071. [src-062] - Documented: 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. [src-055] [src-033] [src-034] ## Which companies share BB Trade Estonia's brand, owner or managers? - Documented: 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. [src-016] [src-014] - Documented: 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. [src-016] - Documented: 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. [src-026] [src-079] - Documented: 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. [src-014] [src-018] [src-080] - Documented: 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. [src-014] [src-082] - Documented: 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. [src-014] - Unresolved: 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. [src-010] [src-014] [src-013] [src-082] - Qualification: Shareholders of a Swiss AG are recorded in its private share register; none of the retained records shows who holds the shares. - 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). - Attributed: 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. [src-106] [src-080] - 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. - Documented: 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. [src-105] [src-116] [src-082] - Documented: 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. [src-017] - Documented: 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. [src-007] [src-059] [src-002] - 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. - Documented: 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. [src-011] [src-007] [src-009] - Documented: 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. [src-035] [src-007] - Documented: 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. [src-007] [src-071] - Documented: 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. [src-007] [src-072] - Documented: 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. [src-007] - Documented: 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. [src-012] [src-002] - Attributed: 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. [src-007] [src-063] [src-002] - 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. - Documented: 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. [src-049] [src-050] - Qualification: Read through a Slovak business-information service reproducing the commercial register and the company's accounts. - Documented: 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. [src-051] - Documented: 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. [src-051] - Documented: 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. [src-050] - 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. - Documented: 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. [src-118] - 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. - Documented: 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. [src-015] [src-022] [src-007] - Qualification: Read through a commercial aggregator's reproduction of Luxembourg register publications; the company has had further directors, who are not named here. - Documented: 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. [src-079] [src-014] ## What was BB Trade Estonia's EUR 100 million credit line to AdmiTrade? - Documented: 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. [src-057] - Documented: 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. [src-093] - Documented: 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). [src-093] - Documented: 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. [src-061] - Attributed: 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. [src-010] - 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. - Documented: 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. [src-060] - Attributed: 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. [src-083] [src-013] - 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. - 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. - Attributed: 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. [src-083] - 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. ## Which licences and registrations did BB Trade Estonia hold? - Documented: 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. [src-006] - Attributed: 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. [src-027] [src-028] - 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. - Documented: 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. [src-111] - 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. - Documented: 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. [src-111] - Documented: 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. [src-081] [src-030] - Outcome: The FIU revoked the licence on 29 June 2026 after the company neither responded to nor complied with the precept. - Documented: 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. [src-030] - 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. - Documented: 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. [src-004] - Documented: 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. [src-038] - 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. - Documented: 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. [src-085] - 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. - Attributed: 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. [src-084] [src-113] - 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. - Documented: 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). [src-100] - Qualification: The export shows no suspension or cancellation; it does not state when it was generated. - Documented: 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. [src-020] - Attributed: 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. [src-113] [src-087] - 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. - Attributed: 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. [src-117] - 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. - Attributed: 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. [src-095] - Qualification: Reported by the press from UOKiK's answer; no UOKiK decision was retained and the outcome is not known. - Attributed: 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. [src-052] [src-113] - 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. ## What did BB Trade Estonia's accounts show about client assets? - Documented: 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. [src-006] - Documented: 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%). [src-003] [src-006] - 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. - Documented: 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. [src-003] - Documented: 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". [src-028] - Documented: 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. [src-028] [src-027] - Unresolved: 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). [src-008] [src-028] [src-027] - 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. - Documented: 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. [src-027] - Documented: 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%. [src-013] - Documented: 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. [src-013] - Documented: 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. [src-006] [src-003] - 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. - Documented: 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. [src-003] - Documented: 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. [src-003] - Documented: 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. [src-028] - Documented: 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. [src-027] - Documented: 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. [src-013] - Documented: 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. [src-121] [src-006] - Documented: 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. [src-120] - Documented: 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. [src-119] - Attributed: 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. [src-008] [src-003] - 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. - Attributed: 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. [src-008] [src-039] - 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. - Documented: 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. [src-039] - Attributed: 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. [src-041] - 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. - Attributed: 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. [src-114] - 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. - Documented: The 2022 annual report lists a migration to BitGo V2 among the IT department's plans for 2024. [src-028] - Documented: Estonian register data reproduced by a business-information service list Assertum Audit OÜ as BB Trade Estonia's auditor from 20 June 2023. [src-024] - Documented: 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. [src-028] - Documented: 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. [src-027] - Documented: 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. [src-013] - Documented: 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. [src-013] - 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. - Documented: 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. [src-013] - Documented: In the Estonian e-Business Register, Assertum Audit OÜ has registry code 10990446 and Crowe DNW OÜ registry code 14299250. [src-119] [src-120] ## What is known about the 4,503 BTC cold wallet? - Attributed: 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. [src-083] - 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. - Attributed: 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. [src-008] [src-083] [src-075] - 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. - 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. - Attributed: 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. [src-083] - Qualification: The law firm's reading of the export; the export itself was not retained in the case. - Attributed: 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. [src-083] - 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. - Attributed: 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. [src-083] - Qualification: Law firm's reading of public blockchain data; addresses and transaction identifiers are not published here. - Attributed: 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. [src-083] - Qualification: Law firm's reading of public blockchain data; not verified in the retained record. - Attributed: 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. [src-096] - 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. - Attributed: 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. [src-008] - 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). - Attributed: 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. [src-075] [src-108] - Qualification: Account of claimants' counsel; the trustee's report and the June 2025 statement are not in the retained record. - Attributed: 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. [src-065] [src-112] - 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. ## Which payment firms and banks handled BB Trade Estonia's money? - Documented: 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. [src-006] - Documented: 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. [src-006] - Documented: 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. [src-028] [src-006] - Documented: 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. [src-003] - Documented: 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. [src-028] - Documented: 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. [src-027] - Documented: 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). [src-013] - Documented: 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. [src-032] - Documented: 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. [src-032] - Attributed: 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. [src-029] [src-088] [src-064] [src-076] [src-031] [src-090] - 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. - 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. - Documented: 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. [src-064] - Qualification: The bankruptcy decision itself is not in the retained record; the two secondary accounts differ by one day on its date. - Documented: 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. [src-076] - Qualification: The publication does not state the period of the breaches or link them to particular customers, including BB Trade Estonia. - Documented: 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. [src-033] - Documented: 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. [src-064] - Documented: 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. [src-064] - Attributed: 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. [src-033] - 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. - Documented: 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). [src-040] - 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. - Documented: 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. [src-031] - Documented: 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. [src-090] - Qualification: The report does not name the key counterparty. - Documented: 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. [src-097] - Documented: 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. [src-003] [src-028] [src-027] [src-013] - Documented: 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. [src-027] [src-013] - Documented: 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. [src-070] - Attributed: 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. [src-010] - 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. - Attributed: 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. [src-010] - 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. - Documented: 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. [src-068] - Attributed: 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. [src-010] [src-013] - 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. - Documented: 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. [src-113] [src-073] - Qualification: Announcement by the partners; no account or service agreement is in the retained record. - Attributed: 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. [src-075] - Qualification: List compiled by claimants' counsel; no bank, payment-institution or custodian confirmation is in the retained record. - Attributed: 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. [src-083] [src-075] - Qualification: The ledger is not in the retained record; the account is the firm's reading of it. ## How did BB Trade Estonia end up in bankruptcy in 2026? - Documented: 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. [src-024] - Qualification: Only the ruling's metadata is in the retained record, not its text. - Attributed: 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. [src-108] - Qualification: The court's interim order is not in the retained record; its date and scope come from the news report. - Documented: 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. [src-108] [src-001] - Documented: 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. [src-019] [src-001] - Attributed: 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. [src-089] - 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. - Documented: 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. [src-024] [src-042] - Documented: 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. [src-078] [src-042] - Attributed: 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. [src-089] - Qualification: Press account; the bankruptcy petition and the ruling are not in the retained record, and the client is not named. - Attributed: 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. [src-089] [src-075] [src-108] [src-043] - 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. - Attributed: 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. [src-122] - Qualification: Headline and photo caption only; the article text is not in the retained record. - Attributed: 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. [src-043] [src-108] - 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. - Attributed: 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. [src-108] - Qualification: Legal position of a claimants' representative; no court or trustee decision on segregation is in the retained record. - Attributed: 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. [src-108] - 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. - Attributed: 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). [src-115] - Qualification: The listing names no creditor and cites no judgment; it records an unverified claim by an unnamed party. - Attributed: 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. [src-083] [src-025] - Qualification: The contracts are not in the retained record, and the retained passage names the brand rather than the contracting legal entity. - 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. - Attributed: 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. [src-122] - Qualification: Caption and headline only; the article text, the sponsorship contract and the basis of the loss figure are not in the retained record. - Documented: 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). [src-065] - 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. ## Which criminal investigations concern the Zondacrypto exchange? - Attributed: 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. [src-122] - Qualification: Headlines and captions only; no act or statement of the Estonian Prosecutor's Office is in the retained record. - 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. - Documented: 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. [src-109] - Qualification: The update names the ZondaCrypto brand; the National Prosecutor's Office later identified BB Trade Estonia OÜ as the exchange's operator. - Documented: 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. [src-029] [src-110] [src-112] - Qualification: The update names the ZondaCrypto brand; the National Prosecutor's Office later identified BB Trade Estonia OÜ as the exchange's operator. - Attributed: 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. [src-112] - 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. - Documented: 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. [src-094] [src-102] - 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. - Documented: 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. [src-102] - 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. - Attributed: 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. [src-091] - 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. - Documented: 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. [src-094] - 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. - Documented: 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. [src-103] [src-095] - 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. - Documented: 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. [src-103] - 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. - Documented: Rafał Z., detained on 2 September 2026, was charged with misappropriating 1.7 million PLN of the ZondaCrypto operator's money entrusted to him. [src-103] - 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. - Attributed: 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. [src-095] - 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. - Documented: 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. [src-066] - 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. - Attributed: 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. [src-095] [src-112] - 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. - Unresolved: 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". [src-095] [src-112] [src-108] - 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. - Attributed: 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. [src-083] - 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. - Attributed: 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. [src-067] - 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. ## Which loans and related-party dealings did BB Trade Estonia record? - Documented: 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. [src-006] - Qualification: The report groups these counterparties by category and does not name them. - Documented: 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. [src-003] [src-028] [src-027] - Documented: 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). [src-003] - Qualification: The report identifies these counterparties only by category. - Documented: 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. [src-028] [src-027] - Qualification: The reports identify the counterparties only by category; Divisio Holding A.G. is named as the parent. - Documented: 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). [src-013] - Qualification: The annual report does not name the related party that received the prepayments. - Attributed: 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. [src-010] - 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. - Attributed: 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. [src-013] [src-010] - 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. - Documented: 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. [src-028] [src-003] - Documented: 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. [src-027] - Documented: 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. [src-013] - Attributed: 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). [src-083] - 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. - Documented: 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. [src-003] [src-028] - Documented: 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. [src-028] [src-013] - 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. - Attributed: 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. [src-083] - 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. - Attributed: 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. [src-075] [src-083] - 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. - Documented: 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. [src-003] [src-028] - Attributed: 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. [src-028] [src-083] - 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. - Attributed: 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). [src-083] - 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. - Attributed: 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. [src-083] - 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. - Attributed: 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. [src-083] [src-003] [src-103] - 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. - 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. - Attributed: 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. [src-083] [src-103] - 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. - 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. - Attributed: 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". [src-083] [src-075] - 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. - Attributed: 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. [src-083] - 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. - Attributed: 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. [src-075] [src-083] - 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. - Attributed: 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. [src-075] - 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. ## Sources - [src-001] e-Business Register company card: BB Trade Estonia OÜ (registry code 14814864), Centre of Registers and Information Systems (RIK), Estonian e-Business Register, 2026-10-19 - [src-006] Annual report of BB Trade Estonia OÜ for 30 September 2019 to 31 December 2020, filed with the Estonian Commercial Register, Centre of Registers and Information Systems (RIK), Estonian e-Business Register, 2021-09-24 - [src-003] Annual report of BB Trade Estonia OÜ for 2021, filed with the Estonian Commercial Register, Centre of Registers and Information Systems (RIK), Estonian e-Business Register, 2022-11-30 - [src-028] Consolidated annual report of BB Trade Estonia OÜ for 2022, filed with the Estonian Commercial Register, Centre of Registers and Information Systems (RIK), Estonian e-Business Register, 2024-01-12 - [src-104] Corporate registry source · src-104 - [src-067] Corporate registry source · src-067 - [src-027] Consolidated annual report of BB Trade Estonia OÜ for 2023, filed with the Estonian Commercial Register, Centre of Registers and Information Systems (RIK), Estonian e-Business Register, 2024-06-30 - [src-013] Consolidated annual report of BB Trade Estonia OÜ for 2024, filed with the Estonian Commercial Register, Centre of Registers and Information Systems (RIK), Estonian e-Business Register, 2025-07-29 - [src-039] Company statement source · src-039 - [src-086] Company statement source · src-086 - [src-113] Company statement source · src-113 - [src-107] Company statement source · src-107 - [src-052] Company statement source · src-052 - [src-114] Company statement source · src-114 - [src-004] Warning notice (hoiatusteade) of 6 May 2026 concerning BB Trade Estonia OÜ, Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority), 2026-05-06 - [src-094] Zarzuty dla Radosława P. w śledztwie dotyczącym ZondaCrypto (charges against Radosław P.), Prokuratura Krajowa (Polish National Prosecutor's Office), 2026-08-28 - [src-096] Media source · src-096 - [src-008] Other source · src-008 - [src-088] Other source · src-088 - [src-023] Corporate registry source · src-023 - [src-077] List of public warnings: BitBay Sp. z o.o., Komisja Nadzoru Finansowego (Polish Financial Supervision Authority) - [src-058] Corporate registry source · src-058 - [src-021] Corporate registry source · src-021 - [src-015] Corporate registry source · src-015 - [src-056] e-Business Register company card: Creative Invest Int OÜ (registry code 14432051), Centre of Registers and Information Systems (RIK), Estonian e-Business Register, 2026-10-19 - [src-074] Other source · src-074 - [src-101] Corporate registry source · src-101 - [src-047] Corporate registry source · src-047 - [src-005] Corporate registry source · src-005 - [src-099] SHAB publication HR01-1005231846: new entry Divisio Holding AG, Zug, Swiss Official Gazette of Commerce (SHAB), 2021-06-29 - [src-002] Corporate registry source · src-002 - [src-063] Corporate registry source · src-063 - [src-010] Other source · src-010 - [src-091] Media source · src-091 - [src-009] Corporate registry source · src-009 - [src-098] Media source · src-098 - [src-025] Media source · src-025 - [src-044] Other source · src-044 - [src-024] Corporate registry source · src-024 - [src-069] Corporate registry source · src-069 - [src-026] Corporate registry source · src-026 - [src-062] Corporate registry source · src-062 - [src-016] Corporate registry source · src-016 - [src-045] e-Business Register company card: ZND Ventures OÜ (registry code 16382854), Centre of Registers and Information Systems (RIK), Estonian e-Business Register, 2026-10-19 - [src-046] e-Business Register company card: ZND.CO OÜ (registry code 16874675), Centre of Registers and Information Systems (RIK), Estonian e-Business Register, 2026-10-19 - [src-055] Corporate registry source · src-055 - [src-100] Register of virtual-currency service providers (export), Organismo Agenti e Mediatori (OAM), Italy - [src-036] Corporate registry source · src-036 - [src-053] Corporate registry source · src-053 - [src-054] Corporate registry source · src-054 - [src-037] Corporate registry source · src-037 - [src-020] Register of Digital Asset Businesses, registration information as at 30 November 2025, Securities Commission of The Bahamas, 2025-11-30 - [src-092] VAT registrants list, July 2026, Department of Inland Revenue, The Bahamas, 2026-07 - [src-048] Corporate registry source · src-048 - [src-033] Corporate registry source · src-033 - [src-034] Corporate registry source · src-034 - [src-014] Corporate registry source · src-014 - [src-079] SHAB publication HR02-1005930301: change BB Trade Switzerland AG, Zug, Swiss Official Gazette of Commerce (SHAB), 2024-01-10 - [src-018] Corporate registry source · src-018 - [src-080] SHAB publication HR02-1006643928: change BB Trade Switzerland AG, Zug, Swiss Official Gazette of Commerce (SHAB), 2026-05-06 - [src-082] SHAB publication HR02-1006718720: change BB Trade Switzerland AG, Swiss Official Gazette of Commerce (SHAB), 2026-07-29 - [src-106] Media source · src-106 - [src-105] Other source · src-105 - [src-116] Other source · src-116 - [src-017] Corporate registry source · src-017 - [src-007] Corporate registry source · src-007 - [src-059] Corporate registry source · src-059 - [src-011] Corporate registry source · src-011 - [src-035] Corporate registry source · src-035 - [src-071] Corporate registry source · src-071 - [src-072] Corporate registry source · src-072 - [src-012] Corporate registry source · src-012 - [src-049] Corporate registry source · src-049 - [src-050] Corporate registry source · src-050 - [src-051] Corporate registry source · src-051 - [src-118] Detail by entity name: BB TRADE FLORIDA INC. (document number P24000070168), Florida Department of State, Division of Corporations - [src-022] Corporate registry source · src-022 - [src-057] e-Business Register company card: ICEO RED 0 OÜ (registry code 16536033), Centre of Registers and Information Systems (RIK), Estonian e-Business Register, 2026-10-19 - [src-093] e-Business Register company card: AdmiTrade OÜ (registry code 16309521), Centre of Registers and Information Systems (RIK), Estonian e-Business Register, 2026-10-19 - [src-061] Corporate registry source · src-061 - [src-060] Corporate registry source · src-060 - [src-083] Other source · src-083 - [src-111] Precepts (ettekirjutused) published by the Financial Intelligence Unit, Rahapesu Andmebüroo (Estonian Financial Intelligence Unit) - [src-081] The Estonian Financial Intelligence Unit partially suspends the validity of the operating licence of BB Trade Estonia OÜ (Zondacrypto), Rahapesu Andmebüroo (Estonian Financial Intelligence Unit), 2026-05-18 - [src-030] The Financial Intelligence Unit revokes the operating licence of virtual currency service provider BB Trade Estonia OÜ (Zondacrypto), Rahapesu Andmebüroo (Estonian Financial Intelligence Unit), 2026-06-29 - [src-038] Regulatory record source · src-038 - [src-085] Regulatory record source · src-085 - [src-084] Media source · src-084 - [src-087] Media source · src-087 - [src-117] Media source · src-117 - [src-095] Media source · src-095 - [src-121] e-Business Register company card: Audit Advisory OÜ (registry code 11556099), Centre of Registers and Information Systems (RIK), Estonian e-Business Register, 2026-10-19 - [src-120] e-Business Register company card: Crowe DNW OÜ (registry code 14299250), Centre of Registers and Information Systems (RIK), Estonian e-Business Register, 2026-10-19 - [src-119] e-Business Register company card: Assertum Audit OÜ (registry code 10990446), Centre of Registers and Information Systems (RIK), Estonian e-Business Register, 2026-10-19 - [src-041] Company statement source · src-041 - [src-075] Other source · src-075 - [src-108] Media source · src-108 - [src-065] Śledztwo w sprawie Zondacrypto (investigation concerning Zondacrypto), Prokuratura Regionalna w Katowicach (Regional Prosecutor's Office in Katowice), 2026-04-17 - [src-112] Media source · src-112 - [src-032] Company statement source · src-032 - [src-029] Media source · src-029 - [src-064] Company statement source · src-064 - [src-076] Kara administracyjna nałożona przez KNF na Payment Technology sp. z o.o. w upadłości z siedzibą w Gdyni (KNF administrative penalty), Ministerstwo Finansów (Polish Ministry of Finance), 2025-06-13 - [src-031] Company statement source · src-031 - [src-090] Company statement source · src-090 - [src-040] Company statement source · src-040 - [src-097] Company statement source · src-097 - [src-070] Corporate registry source · src-070 - [src-068] Corporate registry source · src-068 - [src-073] Media source · src-073 - [src-019] Register of trustees in bankruptcy: Margus Lentsius, Estonian Chamber of Bailiffs and Trustees in Bankruptcy - [src-089] Media source · src-089 - [src-042] Corporate registry source · src-042 - [src-078] Register of advocates: Marek Keiman, Estonian Bar Association (Eesti Advokatuur) - [src-043] Company statement source · src-043 - [src-122] Media source · src-122 - [src-115] Other source · src-115 - [src-109] Informacja o czynnościach w sprawie ZondaCrypto (information on actions in the ZondaCrypto case), Prokuratura Regionalna w Katowicach (Regional Prosecutor's Office in Katowice), 2026-05-12 - [src-110] Aktualizacja w sprawie ZondaCrypto (update on the ZondaCrypto case), Prokuratura Regionalna w Katowicach (Regional Prosecutor's Office in Katowice), 2026-06-22 - [src-102] Oświadczenie Prokuratora Generalnego dotyczące śledztwa w sprawie giełdy kryptowalutowej ZondaCrypto (statement of the Prosecutor General), Prokuratura Krajowa (Polish National Prosecutor's Office), 2026-08-25 - [src-103] Wnioski o tymczasowe aresztowanie wobec kolejnych 3 osób w sprawie ZondaCrypto (applications for detention of three further persons), Prokuratura Krajowa (Polish National Prosecutor's Office), 2026-09-03 - [src-066] ZondaCrypto: zarzuty dla Artura K. i wniosek o tymczasowe aresztowanie (charges against Artur K.), Prokuratura Krajowa (Polish National Prosecutor's Office), 2026-09-23