EFRI Case Note · Part I · Evidence reviewed through 28 October 2026
This case note sets out documented facts about NomuPay, its shareholders and the publicly backed funds invested in it, drawn from company filings, audited accounts, preserved web pages and correspondence with NomuPay and the European Investment Fund (EIF). EFRI holds copies of all web pages cited, including those NomuPay has since removed. The case note does not allege consumer loss in connection with any NomuPay merchant and makes no finding that NomuPay, Finch Capital or any fund breached applicable rules. Statements attributed to NomuPay, the EIF or the fund manager are reported as theirs; EFRI’s own view is set out under “Our Assessment”. NomuPay’s response of 16 October 2026 is reproduced in full in the annex, and its corrections are reflected in the text.
Why EFRI is examining NomuPay
EFRI examines NomuPay for two reasons.
The first is public money. Funds backed by EU, Dutch and UK public investment programmes hold stakes in a payments group that, during the period of that investment, marketed its services under its own name to high-risk merchant categories (among them adult entertainment, online gaming and gambling, cryptocurrency, foreign exchange, investment schemes, payday loans, and direct sales and pyramid selling).
The second is what happens after a payment processor that processed payments for investment-fraud platforms leaves the market. Payvision B.V., Amsterdam under the leadership of Rudolf Booker, Cheng Liem Li and Gijs op de Weegh processed card payments for online investment-fraud platforms, as documented in EFRI’s report of 15 May 2026. On 5 April 2024 the Dutch Public Prosecution Service (Openbaar Ministerie) announced that two former directors (Booker and Cheng Liem Li) of Payvision B.V. had been fined EUR 150,000 and EUR 180,000 by penal order (strafbeschikking) for de facto leadership of years-long, structural violations of the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), in that Payvision carried out inadequate customer due diligence from 2016 through April 2020.. Payvision is in dissolution.[18] In EFRI’s observation, the closure of such a processor does not end the business: owners, managers and capital move on into new payment structures.
StablR, a Maltese e-money institution on which EFRI has reported repeatedly, is the first case EFRI has followed: its founder and chief executive (Gijs op de Weegh) describes himself as a co-founder of Payvision.[19] NomuPay is the second:
- Origin. NomuPay was built from the payment businesses of the Wirecard insolvency estate and subsequent acquisitions, set out below.
- Investor network. Funds managed by the Finch Capital, Amsterdam together hold a majority of NomuPay’s shares. In 2018 Finch Capital and Rudolf Booker, the founder of Payvision, invested together in Safened, an Amsterdam identity-verification company: Finextra reported on 1 June 2018 that Safened had closed the final tranche of a EUR 14 million round backed by Booker and by Finch Capital from its first fund. Safened was renamed Fourthline, which by October 2019 had received EUR 13.5 million from Finch Capital and Booker. According to the EIF, Finch Capital Opportunities Fund I, which holds 0.94 per cent of Nomu Pay Limited, has also invested in Fourthline through a quasi-equity convertible loan not yet converted into shares.[1][15][16]
- Staff. According to the public LinkedIn profile, NomuPay’s Global Head of Merchant Risk, in post since February 2025 and responsible for fraud, merchant onboarding and credit risk across the UK, Europe and Asia, previously worked at Payvision in London as Head of Risk (September 2019 to June 2020) and Director Risk Operations (June 2020 to January 2021), and was then Chief Risk Officer (Acquiring) at Trust Payments (February 2021 to January 2025). According to the same profile, in the second Payvision role the person “led risk management and operations through acquisition phase” and “restructured fraud and onboarding processes to align with EU regulatory frameworks”.[17]
EFRI has not found evidence that NomuPay is owned, controlled or directed by any former owner of Payvision. This case note does not suggest that NomuPay’s Global Head of Merchant Risk took part in the conduct for which Payvision’s former directors were sanctioned.
A payments group built through acquisitions
Nomu Pay Limited was incorporated in Ireland on 8 April 2021 (company number 692034), wholly owned by Finch Capital Fund II Coöperatief U.A. Between July and December 2021 it acquired the Malaysian, Hong Kong, Thai, Turkish and Philippine payment businesses of the Wirecard group from the insolvency estate. The 2021 accounts record capital contributions of EUR 21,664,671 from Fund II, negative goodwill of EUR 266,903 and a net cash outflow for acquisitions of EUR 327,121.[2] EFRI has found no published record of public investors in Fund II, which does not appear in the EIF lists reviewed for this case note.[7]
Cardinity. In December 2022 the group acquired the Lithuanian payment institution UAB Click2Sell, trading as Cardinity and now UAB NomuPay Europe, authorised by the Bank of Lithuania since 14 June 2012 (licence LB000214). Nomu Pay Limited itself is a holding company without a payment licence. The Bank of Lithuania’s register records a fine of EUR 17,150 on 1 July 2019 for submitting incorrect information on client funds, the Bank having found that the majority of client funds had been kept outside a credit institution, and a warning with public disclosure on 13 October 2023, after the acquisition, for breaches of the rules on reporting to the Bank. The merchant exposure inherited with Cardinity is set out under “Merchant exposure” below.[4][26]
Total Processing. On 27 October 2023 the group acquired 100 per cent of Total Processing (Holdings) Limited (UK 13928840, incorporated 21 February 2022), parent of Total Processing Ltd (UK 09841252, incorporated 26 October 2015), both registered at 111 Piccadilly, Manchester. Hill Dickinson, which advised the sellers, described the business as a “merchant services and bespoke payment processing solution provider” co-founded in 2015 by Jean-Michel Soopramanien, Alex Leigh, Cameron Lee and Matt Hamer, with a Dubai office opened in 2021, and the transaction as a USD 35 million sale. NomuPay’s 2023 accounts record consideration of EUR 24,786,029, identifiable net assets of EUR 1,352,199 and goodwill of EUR 23,433,830; the purchase-price allocation was stated to be provisional, and the 2024 accounts record no measurement-period adjustment. Deferred consideration payable to three former owners was EUR 4,741,089 at 31 December 2023 and EUR 4,375,405 at 31 December 2024, bearing interest at 10 per cent from that date. Mr Leigh and Mr Soopramanien hold 31,023 and 25,989 NomuPay shares in the annual return made up to 30 September 2025.[3][5][21][22][23]
Before Total Processing, Mr Soopramanien was a director of Perren Consultants Ltd (07175810), a claims management company handling, among other things, claims relating to mis-sold payment protection insurance, now in liquidation, from 13 March to 23 September 2013 and from 1 July 2014 to 31 January 2015. Total Processing Ltd’s first director, from its incorporation until 18 November 2015, was Samuel Jeffrey Levy; a director of the same name is recorded at Perren Consultants for the same two periods. Mr Leigh became a director of Total Processing on 18 November 2015.[21][24][25]
NomuPay confirms that Total Processing Ltd was not, and is not, authorised as a payment institution or an electronic money institution. It operated as a payment gateway and merchant-services intermediary; according to NomuPay, the merchants were acquired by third-party acquirers under their own onboarding and screening frameworks, and Total Processing was neither acquirer of record nor in the flow of funds.[5]
Goodwill and results. Group goodwill rose from EUR 8,288,121 at 1 January 2023 (as restated) to EUR 32,247,878 at 31 December 2023: EUR 23,433,830 arising on the Total Processing acquisition, EUR 2,164,173 already carried in Total Processing’s own accounts, less EUR 1,638,246 transferred to assets held for sale relating to the Turkish subsidiary. At 31 December 2024 goodwill stood at EUR 32,350,022, equal to 45.7 per cent of total assets of EUR 70,822,514 and 75.7 per cent of total equity of EUR 42,740,250. No impairment has been recognised in any year; NomuPay states that goodwill is tested annually by reference to the value in use of the relevant cash-generating units. Cumulative losses for 2021 to 2024 were EUR 57,028,794, on cumulative revenue of EUR 37,662,107.[2][3][5]
Finch funds and the public capital behind them
At 30 September 2025, Finch Capital Fund II, Finch Capital Nomu Pay Co-Invest Coöperatief U.A. and Finch Capital Europe Fund III Coöperatief U.A. together held 513,082 of 942,020 issued shares (54.47 per cent) in Nomupay; Fund III held 35,894 Series B preference shares.[3] The EIF identifies Finch Capital Partners B.V. as manager of Fund III.[14] In its response of 7 October 2026, the EIF stated that its signed commitments to Fund III “include” the following:[1]
| Public Funding source named by the EIF | Signed commitment to Fund III |
|---|---|
| Dutch Future Fund | EUR 10,000,000 |
| European Investment Fund | EUR 500,000 |
| InnovFin Equity Artificial Intelligence | EUR 10,000,000 |
| Risk Capital Resources | EUR 9,500,000 |
| Sum of the amounts named | EUR 30,000,000 |
The sum is EFRI’s addition; the EIF did not state whether the list is exhaustive. These are commitments to the fund, not amounts paid to NomuPay. The Dutch Future Fund is a joint initiative with Invest-NL, Risk Capital Resources an EIB mandate, and InnovFin draws on EU programme and EIB Group resources.[6] Separately, the British Business Bank announced on 5 October 2022 that its wholly owned subsidiary British Patient Capital had committed EUR 25 million to Fund III.[20]
Note 24 to the 2024 accounts records a EUR 3,000,000 convertible loan note at 6 per cent from Fund III, converted in full, and describes Fund III as having “significant influence over the Group”. Note 24 dates the note to 2023. NomuPay states that this is inconsistent with its records: Fund III applied for notes by letters of 7 March and 18 July 2024, and no Fund III note existed, and no Fund III funds had been advanced, on 27 October 2023, when the Total Processing acquisition was completed. NomuPay will raise the discrepancy with its auditors.[3][5]
The EIF further stated that Finch Capital Opportunities Fund I Coöperatief U.A. holds 0.94 per cent of Nomu Pay Limited. The EIF’s InvestEU list as at 31 December 2025 records that fund with EUR 22,660,000 under the EIF Digital and CCS Investments window. It is not listed by name as a member in the annual return made up to 30 September 2025.[1][3][7]
Note 24 also lists notes from AltDebt B.V. (EUR 1,000,000) and Argentex B.V. (EUR 500,000), each “an associate of Finch Capital”, among five notes totalling EUR 13,929,768. AltDebt B.V. (KvK 63746417) is held through Liesboud B.V. (KvK 34259636), whose sole director is Radboud Vlaar, a director of Nomu Pay Limited since incorporation; AltDebt is registered at the residential address recorded for Mr Vlaar in NomuPay’s Irish filings. NomuPay states that AltDebt is not part of the group and does not currently hold an interest in NomuPay. Neither AltDebt nor Argentex appears as a member in the annual return made up to 30 September 2025, and the filed documents do not show who received the shares issued on conversion of their notes.[3][5]
Endeit and KfW Capital. A possible further public connection runs through Endeit Capital, an Amsterdam-based venture-capital firm independent of Finch Capital. According to the 2024 accounts, NomuPay completed a Series B round of USD 37 million on 15 January 2025, “led by Endeit Capital with participation from existing investors”. Note 21 records the issue of 68,897 B Preferred shares at EUR 153.852850 each, for EUR 10,600,000; the annual return made up to 30 September 2025 shows exactly 68,897 Series B preference shares held by Endeit III UNP Co-Invest Coöperatief U.A., about 7.3 per cent of the issued shares. Endeit Capital named KfW Capital, the venture-capital subsidiary of the German state development bank KfW, as institutional German anchor investor in Endeit Fund III on 9 May 2022. Asked by EFRI, KfW Capital replied on 11 September 2026 citing confidentiality and stating that as a limited partner it does not influence the investment decisions or operations of its partners. Whether KfW Capital’s capital is invested in the co-investment vehicle that holds the NomuPay shares is not public.[3][11]
What nomupay.com advertised
On 28 August 2026 EFRI preserved the pages described below. NomuPay does not contest this record. It states that the content originated on the Total Processing website, was transferred in bulk when the websites were consolidated into nomupay.com in January 2025, and was not adequately checked against its merchant acceptance policy. It describes this as a failure in its content-review process and apologises.[5][8]
Removed after EFRI’s letter
- High-risk merchants page. nomupay.com/high-risk-merchants/, carrying Nomu Pay Limited’s Irish company details, listed 31 categories under the heading “High-risk industries we work with” (sitemap date 28 January 2025; archived Total Processing version of 15 July 2024). A Lithuanian-language version existed, generated according to NomuPay by a translation plug-in. Removed on 7 September 2026 together with six related legacy pages, and de-indexed.
- CBD page. nomupay.com/cbd-payment-gateways/ offered CBD payment gateways with “100% Approval rates*” (archived Total Processing version of 15 July 2024; nomupay.com copy archived 11 June 2026). Removed on 7 September 2026.
NomuPay states that “by way of remediation of the issues highlighted by the EFRI” website changes concerning merchant categories, regulatory status or service claims now require referral to its Compliance and Legal function.[5][8]
Still online
- Forex and Prop Trading page. On 28 August 2026 nomupay.com/forex-payment-gateways/ offered Forex and Prop Trading payment gateways with a “100% approval rate” (archived Total Processing version of 8 September 2024). NomuPay states that the page was rewritten, no longer carries the claim and describes services for authorised investment firms, which are accepted subject to onboarding requirements and are not within the announced offboarding. As retrieved on 28 October 2026, the page is titled “Forex & Prop Trading Payment Gateways & Merchant Accounts”, addresses “your Forex and Prop Trading business” and businesses that “may have struggled to find a Forex payment processing provider with a high-risk merchant account”, states that NomuPay has “helped hundreds of Trading businesses” and offers to “Increase revenue by 30-40% thanks to improved approval rates”. The words “authorised” and “regulated” do not appear. On 20 October 2026 its meta description read “100% approval rate”. NomuPay exhibited at Forex Expo Dubai on 22 and 23 September 2026.[5][12][13]
- Prohibited-products page. NomuPay’s current policy lists, among others, “Escort, adult entertainment, pornography” and “Unlicensed lottery”; licensed gambling is not on it. The EIF describes the policy as excluding “unlicensed lottery and gambling activities, and drugs and cannabis” and as “inconsistent with that legacy content”.[1][5][8]
The relationships behind the logos
On 28 August 2026 the home page displayed the logos of Roobet and Capital.com, transferred according to NomuPay from the Total Processing home page. NomuPay states that it has never acted as acquirer for Roobet: Total Processing introduced Roobet, which holds a Curaçao licence, to a third-party acquirer, and the group receives a referral commission from that acquirer. Capital.com, which operates through FCA- and CySEC-authorised firms, remains a customer.[5][8]
Merchant exposure as stated by NomuPay and the EIF
On 18 September 2026, after its shareholders had forwarded EFRI’s letter to the EIF, NomuPay’s General Counsel wrote to EFRI that the sectors on the high-risk merchant pages identified by EFRI were “outside Nomupay’s focus” and that “the limited exposure inherited through the acquisition has either already been offboarded or is in the process of being fully offboarded before November this year”. On 16 October 2026 NomuPay called that description “insufficiently precise” and stated that the offboarding concerned merchants coded MCC 5967 inherited with Cardinity, whose activities fell outside its risk appetite; that “offboarded” means a notice of termination has been issued; and that its exposure to unregulated investment schemes, cryptocurrency merchants and payday lenders is nil. It has not disclosed the number of merchants, volumes, countries, or the date of the offboarding decision; nor when payment processing for these merchants actually ended, whether the termination applies across the group, or whether it extends to referral relationships such as Roobet, from which the group continues to receive commission.[5]
The EIF relays from the fund manager one very limited exposure to gambling, whose payments NomuPay did not handle; the gradual offboarding of an adult book of business in parallel with the Cardinity acquisition; and dating, chat, fantasy, role-play and similar platforms accounting for 0.2 per cent of NomuPay’s direct customers, to be offboarded by November 2026. That figure counts customers only: the 2010 Guidelines measure the importance of a sector by its share of revenues, turnover or client base, and the EIF’s response gives no figure for the payment volumes, revenues or referral commissions associated with these relationships.[1][9]
What the EIF says it checked
The EIF states that its eligibility assessment before Fund III’s investment did not identify the advertising, and that it contacted the fund manager after EFRI’s letter. It was informed of the Total Processing acquisition before signing and after completion, at the level typically given to limited partners: “generally limited to or less than” the target’s name, rationale and indicative timing.[1]
Under the EIF’s delegated model, the fund manager is responsible for due diligence and continuing compliance and confirms compliance before and after each drawdown; the Limited Partnership Agreement covers direct and indirect investments. The EIF states that the 2010 EIF Guidelines on Restricted Sectors apply to Fund III. Section I.1 of those Guidelines provides that the provisions of a mandate under which the EIF acts “will prevail to the extent such provisions are more restrictive”; the EIF’s response does not state which mandate-specific restrictions under the Dutch Future Fund, InnovFin or Risk Capital Resources apply to Fund III. The Guidelines restrict “technical applications … which aim specifically at internet gambling, online casinos or pornography” and support to counterparts that “substantially focus” on restricted sectors, measured by importance to revenues, turnover or client base, taken from the fund manager’s reporting.[1][9]
Asked whether the InvestEU exclusions for gambling “processing-related activities” and sex-trade “related infrastructure, services” (Regulation (EU) 2021/523, Annex V, Section B, points 5 and 6) reach a payment intermediary, the EIF referred to the 2010 Guidelines and did not address the question. It did not state which framework applies to Opportunities Fund I. The EIF’s monthly report on new transactions records the approval of Opportunities Fund I on 28 February 2025 under the InvestEU Joint Equity Product for the digital and cultural and creative sectors; this documents the funding route, not a particular payment to NomuPay.[27] On AltDebt, EIF stated that it is conducting an internal assessment based on EFRI’s information. On valuation, it stated that its fund-level review found no indication of impairment.[1][10]
Timeline
| Date | Event |
|---|---|
| 8 April 2021 | Nomu Pay Limited incorporated |
| July–December 2021 | Acquisition of Wirecard businesses in Asia and Turkey |
| December 2022 | Acquisition of Cardinity (Lithuania) |
| 27 October 2023 | Acquisition of Total Processing completed |
| 7 March 2024 | Fund III applies for convertible loan notes |
| 15 July 2024 | Archived Total Processing high-risk merchants page |
| 18 July 2024 | Fund III applies for further convertible loan notes |
| January 2025 | Websites consolidated into nomupay.com |
| 28 August 2026 | EFRI preserves nomupay.com pages |
| 7 September 2026 | High-risk page, six related legacy pages and CBD page removed |
| November 2026 | Announced completion of MCC 5967 offboarding |
Correspondence and NomuPay’s opportunity to respond
EFRI wrote to the EIF and KfW Capital on 31 August 2026; KfW Capital replied on 11 September and the EIF on 7 October 2026. NomuPay wrote to EFRI on 18 September. EFRI put eight questions to NomuPay on 23 September, which NomuPay declined to answer individually on 28 September, asking EFRI to set out the statements it intended to publish. EFRI submitted 28 numbered statements on 2 October; NomuPay responded on 16 October, within the period it had proposed. On 13 October EFRI submitted eight supplementary statements on service relationships, convertible loan notes, shareholdings and the Forex page, and further questions to the EIF. NomuPay undertook to respond by 27 October 2026. Neither NomuPay nor the EIF had responded by publication.
NomuPay has asked EFRI for any evidence of consumer loss involving a merchant served by a NomuPay group entity. This case note does not allege such loss. Consumers, merchants, former employees, acquiring banks and payment-industry professionals with relevant documents can contact [email protected]. Part II will examine the service relationships and offboarding in more detail.
Our Assessment
EFRI is a qualified entity for representative actions under Directive (EU) 2020/1828 and acts as a public watchdog for victims of online investment fraud. This assessment concerns how public investment capital can reach a payment business serving high-risk merchant categories.
Publicly backed capital is invested in NomuPay through two Finch funds: Fund III, backed by EIF-managed resources including InnovFin and by the UK’s British Patient Capital, and Opportunities Fund I, backed by InvestEU. The high-risk business came with the acquisitions and continued under NomuPay’s ownership: in Total Processing’s marketing, carried over to nomupay.com until September 2026; in Cardinity’s MCC 5967 book, which is to be offboarded only by November 2026; in a referral commission connected to a Curaçao-licensed online casino; and in a Forex page that still addresses prop-trading firms. The public stake is small: Fund III holds 3.8 per cent … No document shows how those funds were used. That is not the point.
The point is that, on the EIF’s own account, the EIF does not itself look at what a portfolio company processes; it relies on what the fund manager reports, and its answers do not show what merchant-level review, if any, took place in this case. Compliance is confirmed by the fund manager at drawdown. The “substantial focus” test is measured by the manager’s reporting. An acquisition of EUR 24.8 million was notified at the level of the target’s name and rationale. And whether “processing-related activities” in the InvestEU exclusion list reach a payment intermediary remains unanswered.
EFRI’s view is that public investment instruments should apply their exclusions to what a payment business processes, not only to what it presents itself as, and should verify this independently of the fund manager. EFRI will ask the Commission and the EIF to state, for each of Fund III and Opportunities Fund I, which exclusion rules were applied to NomuPay; what merchant data, if any, was reviewed, measured by volumes and revenues and not only by customer counts; how the Total Processing and Cardinity acquisitions were assessed; and what action followed EFRI’s information.
The contrast with the victims is stark. Public investment programmes commit tens of millions of euros to a fund that finances a payments group built from the remains of Wirecard. The victims of Wirecard and Payvision have no comparable support: on 13 November 2025 the German Federal Court of Justice ranked the claims of Wirecard’s shareholders behind those of ordinary insolvency creditors (IX ZR 127/24); the fines imposed on Payvision’s former directors, EUR 330,000 in total, went to the Dutch state; and EFRI is not aware of any EU instrument that funds the recovery of losses suffered by victims of online investment fraud. Public money is available to build the next (high-risk) payment business, but not to repair the damage done through the last ones. Alongside this, EFRI will continue to document where the owners and staff in critical functions of payment processors involved in investment-fraud cases go once those processors close, beginning with StablR and NomuPay.
Sources
1. EIF Infodesk, response to EFRI dated 7 October 2026, questions 1–11.
2. Irish Companies Registration Office, Nomu Pay Limited (692034): incorporation records; audited consolidated financial statements 2021, including note 14.
3. Nomu Pay Limited, audited consolidated financial statements 2023 (notes 15 and 26) and 2024 (statement of financial position; notes 13 and 24); annual return (form B1C) made up to 30 September 2025. Kamer van Koophandel: AltDebt B.V. (63746417), Liesboud B.V. (34259636).
4. Bank of Lithuania, register of financial market participants: UAB NomuPay Europe, licence LB000214, including recorded sanctions and measures.
5. Correspondence NomuPay–EFRI: NomuPay emails of 18 and 28 September 2026; EFRI questions of 23 September 2026; EFRI statements of 2 October 2026 (1–28) and 13 October 2026 (29–36); NomuPay letter of 16 October 2026 (annex).
6. EIF descriptions of the Dutch Future Fund, Risk Capital Resources and InnovFin.
7. EIF InnovFin Equity and EFSI equity signature lists as at 31 December 2024; InvestEU equity intermediary list as at 31 December 2025.
8. Pages preserved by EFRI on 28 August 2026: nomupay.com/high-risk-merchants/; nomupay.com/lt/high-risk-merchants/; nomupay.com/cbd-payment-gateways/; nomupay.com/forex-payment-gateways/; nomupay.com/support/which-products-and-businesses-are-prohibited/; nomupay.com home page and sitemap.
9. EIF Guidelines on Restricted Sectors, approved 13 July 2010, sections I.1 and II.3.
10. Regulation (EU) 2021/523 (InvestEU), Annex V, Section B, points 5 and 6.
11. EFRI letters to the EIF and KfW Capital of 31 August 2026; KfW Capital response of 11 September 2026; Endeit Capital announcement of 9 May 2022.
12. NomuPay, “Forex & Prop Trading Payment Gateways & Merchant Accounts”, nomupay.com/forex-payment-gateways/, retrieved 20 and 28 October 2026.
13. NomuPay, LinkedIn announcement of Forex Expo Dubai, 22–23 September 2026, stand 185.
14. EIF, equity fund partners as at 31 December 2025, entry for Finch Capital Europe Fund III.
15. Finextra, company announcement “Safened”, 1 June 2018.
16. Silicon Canals, “Fourthline: Here’s how this Amsterdam-based fintech startup is successfully fighting financial crime”, 30 October 2019.
17. Public LinkedIn profile of NomuPay’s Global Head of Merchant Risk, preserved by EFRI on 28 October 2026.
18. Openbaar Ministerie, “Geldboetes voor voormalig bestuurders betaaldienstverlener vanwege tekortkomingen bij het bestrijden van witwassen”, 5 April 2024.
19. Blockworks, author profile of Gijs op de Weegh (“CEO and Founder of StablR”; “co-founded Payvision … in 2002”); EFRI reports on StablR on efri.io.
20. British Business Bank, “British Patient Capital commits €25 million to Finch Capital’s Fund III”, 5 October 2022.
21. Companies House: Total Processing Ltd (09841252); Total Processing (Holdings) Limited (13928840).
22. Hill Dickinson, “Hill Dickinson advises on $35m sale of Total Processing to NomuPay”, December 2023.
23. Silicon Canals, “NomuPay acquires Total Processing”, 1 December 2023.
24. Companies House: Perren Consultants Ltd (07175810), officers and status.
25. Financial Ombudsman Service, decision DRN-3882425 (Perren Consultants Ltd), for the description of Perren Consultants’ business.
26. Bank of Lithuania, “Už netinkamą klientų lėšų laikymą – bauda UAB Click2Sell”, 29 July 2019.
27. EIF, “Monthly report on the approval of new transactions – February 2025” (delegation of powers to the Chief Executive), entry for Finch Capital Opportunities Fund I Coöperatief U.A., 28 February 2025.
Annex
NomuPay, letter to the Board of EFRI dated 16 October 2026, “Nomu Pay Limited: Response to your letter of 2 October 2026”, reproduced in full.
