--- title: "Which payment firms and banks handled BB Trade Estonia's money?" language: en canonical: https://dossiertwist.com/dossiers/bb-trade-estonia-ou/payments/ 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"] --- # Which payment firms and banks handled BB Trade Estonia's money? **Question.** Through which payment institutions and banks did BB Trade Estonia OÜ move money, and who owned its main Polish payment provider? **Answer.** BB Trade Estonia OÜ did not provide payment services itself: deposits and withdrawals in fiat ran through licensed payment firms, from Fenige, Polish Post and Payment Technology in 2020 to TryPay, ZEN, Clear Junction, Tpay and Fenige by 2026. TryPay's parent, Femion Technology, had Przemysław Kral as its largest shareholder; TryPay ended its services on 20 April 2026 and its board resolved ten days later that it was insolvent. ## Fiat channels, 2020–2022 - Analysis: In 2020, according to its first annual report, BB Trade Estonia OÜ agreed with Fenige Sp. z o.o. to enable card payments, widening users' deposit and withdrawal options. The same report describes express deposits of Polish zloty to the BitBay.net platform through Polish Post (Poczta Polska), at a fee of 2% and at least PLN 5, and cash withdrawals of up to PLN 15,000 at a time at post offices, a service provided by the payment service provider Payment Technology. From December 2020 the company also offered a payment gateway for instant cryptocurrency payments, first as BitBayPay and later as "Pay with zondacrypto", charging a commission per transaction, and its 2021 report lists PayByZEN: instant deposits and withdrawals in PLN, USD and EUR between a client's account on zondaglobal.com and the client's account with ZEN. [src-006] [src-028] [src-003] - Analysis: The main Polish channel changed hands in 2022. In a current report of 29 April 2022 Femion Technology S.A. stated that Payment Technology sp. z o.o. had until then provided BB Trade Estonia OÜ, the operator of the ZONDA exchange at zondaglobal.com, with money-remittance services under a cooperation agreement. The same day Femion's subsidiary TryPay S.A., a Polish national payment institution, signed with both companies an assignment of all rights and obligations under that agreement, effective once Femion completed its purchase of Payment Technology's shares, and signed directly with BB Trade Estonia an open-ended partnership agreement to provide it with payment services in Poland and other countries. [src-032] - Analysis: A press report summarising Femion's stock-exchange reports said Femion announced the completion of the purchase in June 2022 and that Payment Technology had processed about PLN 275 million a month over the preceding six months, against about PLN 14 million at TryPay; a law firm acting for claimants describes Payment Technology as processing about USD 70 million a month between Polish bank accounts and BB Trade Estonia until April 2022. Both are secondary accounts: Femion's June 2022 report was not retained, the press figure covers all of Payment Technology's processing rather than BB Trade Estonia alone, and the firm's figure is an approximation. Payment Technology was later declared bankrupt and fined PLN 200,000 by the KNF for anti-money-laundering breaches; TryPay terminated its own agreement with BB Trade Estonia with immediate effect on 20 April 2026, and on 30 April 2026 TryPay's board resolved that it was insolvent. [src-029] [src-088] [src-064] [src-076] [src-031] [src-090] ## TryPay, Femion and Przemysław Kral - Analysis: Polish National Court Register (KRS) data reproduced by a registry-data aggregator list Femion Technology S.A. (KRS 0000377784) as the sole shareholder of TryPay S.A. (KRS 0000412103) since 27 July 2022 and Przemysław Kral as TryPay's beneficial owner. Femion's management report for 2025 shows Kral as its largest shareholder at 31 December 2025, with 14,109,812 shares or 49.8674% of the capital, the next largest holder having 11.8303%, and describes TryPay, a national payment institution entered in the KNF register as IP25/2014, as the group's operating company. Among events after that date the report lists a loan to Femion from Kral of EUR 60,000, increased by annex to EUR 120,000, Femion's subscription for 500,000 new TryPay shares at PLN 0.50 each, and an extension to 31 December 2027 of a loan from TryPay, under which Femion owed its subsidiary PLN 2,266.8 thousand at the end of 2025. [src-033] [src-064] [src-055] [src-034] - Analysis: A machine-generated summary of TryPay's filings on a registry-data aggregator states that the Polish financial supervisor (UKNF) inspected TryPay in 2024 on anti-money-laundering and sanctions compliance, and that TryPay implemented all post-inspection recommendations by February 2025, commissioned an audit in September 2025 and faced no pending administrative proceedings. The aggregator labels the text as AI-generated, and the underlying documents and any supervisory record were not retained. [src-033] - Analysis: On 20 April 2026, in a current report issued as inside information, Femion announced that TryPay had terminated with immediate effect its agreement to provide payment services to "BB Trade Estonia EU", following a negative result of its risk assessment of further cooperation, and expected a negative effect on the group's results. On 30 April 2026 Femion reported that TryPay's board had resolved that TryPay was insolvent and would file for bankruptcy, citing mainly the loss of a key counterparty, whom the report does not name, and failed talks on outside financing; TryPay also asked the KNF to extinguish its payment-institution authorisation. The same day Femion's board resolved that Femion itself was insolvent, citing TryPay's deteriorating finances and its inability to raise outside financing. [src-031] [src-090] [src-097] ## Payment Technology after the handover - Analysis: Femion's management report for 2025 states that in 2024 a court declared Payment Technology sp. z o.o. bankrupt. The claimants' law firm dates the declaration 3 October 2024 (file GD1G/GU/1487/2023), while a machine-generated summary of Femion's filings gives 4 October 2024 and says Femion wrote down its shares; the decision itself was not retained. On 13 June 2025 the Polish Ministry of Finance published the final KNF decision fining Payment Technology sp. z o.o. w upadłości (in bankruptcy), of Gdynia, PLN 200,000 for breaches of the Anti-Money Laundering Act: failing to assess its money-laundering risk, to identify and verify customers and beneficial owners, to monitor business relationships and analyse transactions, to document beneficial-owner measures and to train staff. The company did not appeal. The publication does not state the period of the breaches or link them to any customer, including BB Trade Estonia. [src-064] [src-076] ## Operators, fees and accounts, 2022–2026 - Analysis: The exchange's terms valid from 3 October 2025 say zondacrypto itself does not provide payment services: licensed payment operators handle deposits and withdrawals and safekeep clients' fiat. The operator list published with the terms, in an archived copy of 8 April 2026, named TryPay S.A. of Wrocław (KNF licence IP25/2014, without safekeeping of funds), ZEN UAB of Lithuania (Bank of Lithuania electronic-money licence LB000457), Clear Junction Limited of the United Kingdom (FCA licence 900684), Krajowy Integrator Płatności S.A. of Poznań (Tpay; KNF IP27/2014) and Fenige S.A. of Warsaw (KNF IP42/2017). The licence numbers are as the exchange stated them; they were not checked against the regulators' registers in the retained record. [src-039] [src-040] - Analysis: The 2022 annual report says BB Trade Estonia also received a monthly intermediary fee in fiat from payment operators, paid out after their costs, without naming them. In the 2023 report fees of payment intermediaries were EUR 97,339 for 2023 (EUR 413,057 for 2022), transaction costs including bank fees EUR 205,080 (EUR 242,986) and licence fees and platform use EUR 1,122,170 (EUR 2,498,010). The 2024 report gives revenue of EUR 6,076,753, EUR 4,694,517 of it from Poland, and by service lists Trading EUR 4,980,510, TryPay EUR 325,293, Pay EUR 264,185, Pay-ZEN EUR 175,057, Fenige EUR 108,084 and Fiat exchange EUR 49,009; for 2023 it shows no TryPay or Pay-ZEN line but ZEN at EUR 161,243. [src-028] [src-027] [src-013] - Analysis: According to a law firm acting for claimants, which says it handed the trustee a list of account numbers, contract dates and transaction identifiers on 17 September 2026, BB Trade Estonia held accounts at AMINA Bank and Sygnum in Switzerland, ZEN.COM in Lithuania, Clear Junction in London and Fenige, TryPay and Tpay in Poland, kept the keys to 685,000 wallets in a Fireblocks workspace and used wallets at BitGo, while its subsidiaries had accounts at the Kraken and Gate exchanges. The same firm, citing the general ledger, says monthly payments to Orion Software under its loan and investment agreements, some booked as "Zen Regular outgoing", ran through ZEN.com until 31 March 2026, which also carried the monthly transfers to ZND Ventures. No bank, payment-institution or custodian confirmation, and no ledger extract, is in the retained record. [src-075] [src-083] ## SEBA Bank (AMINA Bank) and the 2025 certificate sale - Analysis: AMINA Bank AG of Zug (UID CHE-434.446.643), formerly SEBA Crypto AG and SEBA Bank AG, was registered on 24 April 2018. BB Trade Estonia's annual reports show that it bought B shares of SEBA Bank AG for EUR 2,317,819 in 2020, converted in 2021 into equity tokens representing about 1.01% of the bank; it bought more for EUR 952,199 in 2022 and carried the stake at EUR 3,484,716 at the end of 2022, EUR 3,827,891 at the end of 2023 and EUR 3,785,087 at the end of 2024, when the report no longer named the issuer. The bank also lent the company EUR 5,000,000 at 4% (outstanding at 31 December 2022) and EUR 10,000,000 at 4% (outstanding at 31 December 2023); the 2024 balance sheet shows no loan liabilities. [src-070] [src-003] [src-028] [src-027] [src-013] - Analysis: A law firm acting for claimants, citing a share purchase agreement of 21 January 2025, says BB Trade Estonia agreed to sell its 781,250 AMINA participation certificates (par value CHF 1, about 1.014% of the bank's capital) to LL (BVI) Investment Limited for CHF 3.40 each, CHF 2,656,250 in total, about a quarter below the EUR 3,785,087 at which the position stood at the end of 2024; closing required consents from the bank's board, other holders and the regulator, either side could withdraw if they were not obtained by 30 April 2025, and disputes go to the Cantonal Court of Zug. The agreement is not in the retained record and nothing shows whether the sale closed or the price was paid. The buyer's legal entity identifier record describes it as an active British Virgin Islands company created on 12 January 2022, registered at Vistra Corporate Services Centre in Road Town, Tortola, with headquarters at 100 Queen's Road Central, Hong Kong, and no reported parent (reason: no known person). [src-010] [src-068] - Analysis: The same firm says the price was to be paid to BB Trade Estonia's account at Sygnum Bank AG in Zurich, and that in the exchange's ledgers the position fell from about EUR 3.79 million on 1 January 2025 to one cent by 22 April 2026, with no cash received and no loss recognised; it describes SEBA (now AMINA) as the bank that kept BB Trade Estonia's accounts and lent to it. No statement from Sygnum and no extract from AMINA's register is in the retained record, so whether the sale closed and where the price went remain open. [src-010] - Analysis: The firm also notes that Guido Bühler, SEBA Bank's first chief executive, having come from UBS Wealth Management, sat on the exchange's board when the certificates were sold. It adds that the certificates were acquired before 2021 and the loan taken in 2022, that Bühler joined the exchange about a year and a half after leaving the bank, that no document suggests he brokered either, and that it does not know whether the board knew of the sale. BB Trade Estonia's 2024 annual report lists Bühler as a management board member at 31 December 2024 and moves him to the supervisory board only in March 2025. [src-010] [src-013] ## The Swiss entity's bank - Analysis: For the Swiss side of the brand, a press release issued for the brand together with Incore Bank on 14 January 2025 announced that zondacrypto was opening an office in Zug for its Swiss entity, BB Trade Switzerland AG, and entering a collaboration with the bank; Swiss financial press reported the partnership the same day, quoting Przemysław Kral as chief executive of Zondacrypto. These are the partners' announcements; no account or service agreement is in the retained record. [src-113] [src-073] ## Sources - [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-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-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-032] Company statement source · src-032 - [src-029] Media source · src-029 - [src-088] Other source · src-088 - [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-033] Corporate registry source · src-033 - [src-055] Corporate registry source · src-055 - [src-034] Corporate registry source · src-034 - [src-097] Company statement source · src-097 - [src-039] Company statement source · src-039 - [src-040] Company statement source · src-040 - [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-075] Other source · src-075 - [src-083] Other source · src-083 - [src-070] Corporate registry source · src-070 - [src-010] Other source · src-010 - [src-068] Corporate registry source · src-068 - [src-113] Company statement source · src-113 - [src-073] Media source · src-073