As you saw in my previous posts, Latvian company “New Generation Market SIA“ that should be the owner of IBAN Wallet, is not active and not reachable, but turns out - there is another owner… Is the situation better here? Let’s find out.

Note: if you missed the first posts about IBAN Wallet, please start with those:

Part 1: IBAN Wallet - another P2P ponzi?
Part 2: IBAN Wallet - hiding in Estonia?
Part 4: IBAN Wallet review - 100% scam! Stay away!

So back to owners… Depending on visitor’s country, ibanwallet.com website redirects you to a different Terms and Conditions page - I used a VPN service and here are my results:

As you can see, in most cases we see the unreachable Latvian company, but there is a different legal entitiy mentioned in ibanwallet.com, if you visit it from Mexico. Then according to Terms and Conditions you will have to deal with this company:

Clearchoice Management S.A.P.I. de C.V., con domicilio en en Colima 161-1, Col. Roma. Del. Cuauhtemoc. CDMX. Mexico 06700 (en lo sucesivo “Clearchoice Management S.A.P.I. de C.V.”), da a conocer por este medio su página electrónica: https://www.ibanwallet.com/es-MX/ (en adelante “Sitio”).

And following payment service:

Estimado Usuario, CACAO PAYCARD SOLUTIONS, S.A. DE C.V. (en lo sucesivo “CACAOPAY” o “nosotros”), con domicilio en Boulevard Manuel Ávila Camacho 50, 5º piso, Lomas de Chapultepec, C.P. 11000, Miguel Hidalgo, Ciudad de México, pone a su disposición los presentes Términos y Condiciones, mismos que rigen el uso que haga de las Tarjetas emitidas por CACAOPAY, y permanecerán vigentes mientras continúe utilizando nuestras Tarjetas o mientras éstas sean válidas, y hasta que se actualice una causa de terminación.

Let’s start with address: Colima 161-1, Col. Roma. Del. Cuauhtemoc. CDMX. Mexico 06700 - in a way it is similar to Latvia - some random location, where several companies are registered, but not much to see from outside:

What about owners of Clearchoice Management S.A.P.I. de C.V? There are 2 persons:

Jorge Alberto Díaz Flores, owns 49 950 shares worth MXN 49 950 (about 2 000 EUR)
Glennys Ramona Rosario de la C., owns 50 shares worth MXN 50 (about 2 EUR)

I also received address and ID of Jorge. I won’t publish it, but this is the area of his registered address:

Maybe this is a common thing in Mexico, but to me looks like a guy living in not the best neighborhood, if you have to place metal bars on windows.

And note that he is not only the 99.9% owner of IBAN Wallet Mexico, but also 99.9% owner of IBAN Wallet Mexico loan originator:

ibanonline.com.mx

Here is a screenshot of their Terms and Conditions page:

Short translation: Iban Online S.R.L. (company from Dominican Republic) will generate leads for First Home Solutions (Mexican company), and First Home Solutions will issue loans to borrowers.

Want to guess, what is the ownership structure of First Home Solutions? Exactly the same as described above. Owners of FIRST HOME SOLUTIONS, S.A.P.I. DE C.V. are:

Jorge Alberto Díaz Flores, owns 49 950 shares worth MXN 49 950 (about 2000 EUR)
Glennys Ramona Rosario de la C., owns 50 shares worth MXN 50 (about 2 EUR)

IBAN Wallet Mexico

Someone might think - OK, well, these are good news, right? We have real operations in Mexico, and a real loan originator? That is the good part, sure.

But for me the low share capital and ownership structure seems suspicious. This “First Home Solutions“ company is giving out loans of up to 1 million EUR for terms up to 20 years. How does that go together with a share capital of only 2 000 EUR?

Questions that come to my mind:

Why are Daniel Suero, Iban Wallet CEO and Marc Hurr, Iban Wallet Director not owning any shares in these companies?
Why is Glennys Rosario owning only 0.1% of both companies?

To me it looks like Glennys is the real representative from IBAN Wallet side, and Jorge Albert is probably used for the same purpose as the guy from Afghanistan that owns Latvian company.

And as always - it get’s better… These Mexico operations are being investigated:

13.10.2020: FGR investiga financieras virtuales que ofrecen 10% de intereses diarios
23.10.2020: La FGR investiga a Iban Wallet por captación irregular de recursos

Translation to english:

The Attorney General's Office investigates the Iban Wallet company for the probable crimes of Irregular Deposit and Irregular Banking, where the penalties can range from five to fifteen years in prison.
On September 14, 2020, the FGR opened an investigation against Clearchoice Management, S.A.P.I. de CV, a legal entity that, without being a Financial Technology Institution for not having been authorized by the National Banking and Securities Commission to operate as one, has deceived various Mexican users by criminally capturing money through the Iban Wallet platform, easily downloadable application through any smartphone.
According to the investigations, the Prosecutor's Office began to take action after a user of the IBAN Wallet application had made an investment and Clearchoice Management S.A.P.I. de C.V would not return the money.
This is how they found out that Clearchoice Management, S.A.P.I. de C.V., in addition to not returning the money to its users, it cannot collect money from the general investing public because it is not a Credit Institution, committing the crimes of Irregular Funding and Irregular Banking.
It should be noted that in addition, the same company that passes itself off as a Financial Technology Institution, explains -very vaguely-, in its privacy notice on the website https://www.ibanwallet.com/es-MX/, that It works with various legal entities to whom it lends the money collected (committing another crime), in order to comply with the most attractive investment that a server has read in years within the market of up to 10% daily interest.
Iban Wallet users have also asked the National Banking and Securities Commission, the Bank of Mexico and the CONDUSEF, to help scammed people to recover their money and also investigate Clearchoice Management, S.A.P.I. de C.V. so that you stop committing the aforementioned irregularities.

And even while these investigations are going on, IBAN Wallet still is doing business as usual, at least their Facebook ads are still active:

IBAN Wallet position

If IBAN Wallet was operating a legitimate business, I would expect them to either explain all this stuff or fix the problems, but seems like they have decided to take a different path.

In July 2020 one investor was asking very good questions to IBAN:

Question: the Latvian company register for New Generation Market SIA (40203215233) indicates that the board, shareholders and beneficial owners are all listed with citizenship of Afghanistan. Would it be possible to elaborate on that as well?
Answer: As you might know, Iban Wallet is an internet-based platform, so whilst we provide our operations in 30+ countries, we have an international staff and we don't have a need for any national offices or hubs. Just as Iban Wallet functions internationally and so has a staff from the EU, Americas, and Asia, New Generation Market may also have an international staff. In the 21st Century, it is possible for individuals of any nationality to work internationally, so NewGen board may indeed have Afghani members.
Question: Could you please elaborate on the relationship between Iban Wallet and New Generation Market ? From the terms I understood that “Iban Wallet” means New Generation Market SIA, i.e. a brand name in use by the entity.
As the Latvian entity was founded on 06.06.2019 and Iban Wallet as a name has been around at least sinds 2016/2017 - was there a recent acquisition or other event that the brand belongs now to NewGen? Could you please elaborate on that as well.
Answer: About NewGen we prefer not to dig on that direction the content because this will keep on rising more and more questions that are not really impactful so far on customers acquisition and it might be complicating content more than needed. We produce everyday compliant content according European regulators and laws, and we try to make it easier for the user to understand.
Source: qwerty-273.tweakblogs.net/blog/18884/ibanwallet-laatste

So IBAN Wallet kind of admitted having Afghani members on board, but did not want to “dig on that direction“ and answer any further questions.

But when a different investor made withdrawals recently, his account manager had following explanation:

When I confronted my "account manager" about me getting defensive about their lack of transparency, their current structure, their office in Estonia, their CEO with afghan passport, she told me they decided to terminate operations in the UK, even though the company was started there, due to Brexit, and they have an office in Estonia for tax efficiency reasons and a physical address in Berlin.
She said the CEO having an afghan passport was not true, and they'll issue an update about their structure.
When I queried her about where do they lend our money, Latin America, Portugal, Spain, Belarus, Kazakhstan, she didn't had a precise answer - just told me they lend everywhere in the globe, and they only do with with collateral, though she didn't describe what that collateral was.
Still about the company owners, she told me one of the co-founders is portuguese and was working with her on their office.

As you can see, IBAN Wallet support is avoiding questions, so I asked Sigrid Arteaga Marquard, Head of Communications at IBAN (and also owner of their Germany legal entity), if she had anything to say:

Kristaps Mors @KristapsMors

@inv_provinciano @InvertirAhorros @IbanWallet @sigxs any comment?

No response, complete silence. I don’t get it. Should not “head of communications“ communicate? Or maybe I am the wrong audience? I see that investors are getting some nice offers:

More questions

In last days several investors reported getting money not from PECUNIA CARDS EDE, S.L.U. as before, but from TITANES TELECOMUNICACIONES S.A.

But the most important, unanswered questions so far:

Which company or person is receiving investor deposits? Investors see only an IBAN account GB40LOYD30801286558082, but there is no way to tell, who it belongs to. Is it the Latvian company with Afghanistan owner? The Mexican company? The Estonian company with Marc as owner?
What is the TECH CONSULTANCY MANAGEMENT PARTNERS OÜ (Estonian company) used for? If it is investor money, then it is declared as something else (investments should not be taxable turnover). If it is money to be paid to affiliates, where are investor deposits going, and are they 10-20x larger than 30 million, considering that for affiliates they should pay 5-10% of deposits?
Why does IBAN Wallet need 20+ legal entities in 8+ countries? And why are many of them not owned by largest shareholders mentioned in Seedrs campaigns?

Key takeaways

IBAN Wallet claims to be a different company depending on visitor’s location. But also Mexican owner is not providing any confidence.
IBAN Wallet Mexican operations are being investigated for operating lending and investment business without licenses, and not returning investor’s money.
IBAN Wallet support and co-founders are completely silent and ignoring all the questions. Even Kuetzal and Envestio tried to explain stuff away. Is situation here much worse?

P.S. Join “High-risk investments“ Telegram group for an informal discussion.

Kristaps Mors

Who owns IBAN Wallet?