EFRI Case Note · StablR Ltd (C 104007), issuer of the e-money tokens EURR and USDR · StablR notice to token holders of 6 November 2026 · Published 6 November 2026 On 6 November 2026, StablR Ltd informed holders of its e-money tokens EURR and USDR that it had filed
EFRI Case Note · Bitcoinforme, S.L. (Bit2Me), CNMV-authorised crypto-asset service provider · EURR e-money token issued by StablR Ltd (Malta) · Vanadi Coffee, S.A. v Bitcoinforme, S.L., Tribunal de Instancia de Alicante, interim measures before action reported by Vanadi as granted 1 October 2026 (no decision on the merits reported)
The problem is not that the DSA lacks binding obligations — Articles 34 and 35 already impose them — but that prevention and enforcement, by themselves, restore nothing a victim has already lost.
The Binance freezes show that issuers can preserve assets within minutes. EFRI examines who can access that response, the legal basis for intervention and a practical route for ordinary victims.
The defining fact behind CP26/38 is a number. By the FCA’s own account, recorded investment-fraud cases rose 26% and losses 40% from 2024 to 2025 (UK Finance data, cited in the consultation’s Question 1).
When can routine payment processing become complicity in fraud? EFRI examines German case law and why fraud indicators must be assessed together.
Can banks refuse GDPR access because fraud victims want to assess liability? EFRI examines recent German and Austrian decisions and challenges refusals based on that purpose alone.
StablR’s 19 October update leaves EURR and USDR redemption suspended without a timetable. EFRI examines what changed since August, the unresolved status of unauthorised tokens and the supervisory questions facing the MFSA.
A practical guide to Austrian bank warning and monitoring duties in APP fraud, causation, evidence requests and limitation periods.
A practical guide to German bank warning duties in APP fraud, the burden of proof, evidence requests and limitation periods.
