StablR: EFRI asks MFSA what became of its 2025 ‘exhaustive analysis’ One year after the Malta Financial Services Authority told EFRI that it was conducting an “exhaustive analysis” of concerns surrounding StablR Ltd, EFRI has returned to the regulator. Two significant developments make renewed scrutiny necessary: the May 2026 StablR
Banking Circle 2025: The Payments Bank Whose Largest Fee Line Is Not Payments An EFRI financial-structure analysis based on Banking Circle S.A.’s audited financial statements for 2022–2025, its regulatory disclosures and its own product descriptions. It makes no finding of criminal or regulatory misconduct. Where the accounts do not permit
Banking Circle’s vIBAN Model in Practice: Kraken, Bano and the Look-Through Problem EFRI has repeatedly argued that the principal risk of virtual IBAN structures is not the IBAN itself. It is the separation between the bank whose name appears in the payment chain, the regulated intermediary that is the bank’s
The OCC’s Rejection of bunq: A Continuing Fit-and-Proper Question for DNB The refusal of bunq’s U.S. banking charter is not simply a failed expansion project. For De Nederlandsche Bank (“DNB”), the decision produces information that maps directly onto DNB’s own published criteria for the continuing fitness and propriety of persons
Section 230 Doesn’t Shield Meta’s AI-Generated Scam Ads U.S. District Court for the Northern District of California, Chief Judge Richard Seeborg — Bouck et al v. Meta Platforms, Inc., No. 3:25-cv-05194-RS; order on the motion to dismiss dated 24 March 2026, followed by a subsequent dismissal on securities-preemption grounds reported
Amsterdam Court Admits WAMCA Class Action Against ING/bunq Case note on Rechtbank Amsterdam, 15 July 2026, ECLI:NL:RBAMS:2026:7864 (C/13/772051 / HA ZA 25-1256), published 10 August 2026. On 15 July 2026 the Amsterdam District Court held a collective action against two banks admissible under the Dutch Act on the Resolution of
AMLA’s direct-supervision criteria may miss smaller high-risk banks, EMIs, PSPs and acquirers that enable cross-border fraud despite not meeting size or six-Member-State thresholds
BaFin Warns About Virtual IBANs – But the Problem is Years Old On 27 July 2026, the German financial supervisor BaFin warned that virtual IBANs can become “Trojan horses” in the European payment system. According to BaFin, layered vIBAN structures may be systematically misused for money laundering and digital underground
Hamblin v Moorwand: Why Victims Cannot Fight Alone The Court of Appeal’s decision in Hamblin v Moorwand exposes a wider failure in fraud recovery. Victims are expected to prove what happened inside financial institutions without access to the relevant records, while the cost of obtaining justice can exceed the fraud
Wise Was Denied a Bank Charter. Will DNB License Qivalis? On 21 July 2026, the US Office of the Comptroller of the Currency has rejected Wise’s application to establish a national trust bank recently. The decision should attract attention far beyond the United States. The OCC did not treat Wise’s
