KLICKL EUROPE: Polish VASP, China-Linked Crypto Gateway, And A Key Node In The KXTRA Fraud Structure

According to Scam-Or Project’s current assessment, Klickl Europe Sp. z o.o. appears to be directly embedded within the KXTRA fraud payment infrastructure rather than operating outside of it. Documentation reviewed by Scam-Or Project suggests that victim deposits sent to OpenPayd-linked accounts were later transferred onward to Klickl Europe, with payment references reportedly containing the wording “Sweep to Primary Account.”

This is not a marginal processing detail. The evidence indicates that Klickl Europe may have functioned as the primary-account recipient within the broader KXTRA / KKR Global Investment transaction chain.

Quick Overview

Klickl does not present itself as an ordinary merchant or low-level payment intermediary. Across its websites, the group markets a broad Web3 financial ecosystem offering:

• global accounts
• digital wallets
• merchant payment infrastructure
• stablecoin transactions
• payment APIs
• custody services
• OTC and exchange products
• asset-management solutions
• card and spending services
• Web3 SaaS infrastructure

Klickl publicly describes itself as a multi-jurisdictional virtual-asset services platform. Its disclosures further state that, unless otherwise specified, services available on klickl.com are operated through Klickl Europe.

As a result, the alleged OpenPayd → Klickl transfer route becomes highly significant. The reviewed evidence suggests that victim funds may have been routed into a crypto-financial operating environment rather than to a standard commercial recipient.

Polish Registration Does Not Equal Full Financial Supervision

Klickl states that Klickl Europe Sp. z o.o. is registered in Poland under KRS number 0001053580 and listed in the Polish virtual-asset activities register under RD WWW-930.

However, the Polish Ministry of Finance has clearly stated that this register serves primarily as a record-keeping mechanism. Entry into the register does not constitute a financial licence, regulatory guarantee, or prudential supervision comparable to mainstream financial institutions.

This distinction is critical when assessing claims that the entity operates as a “regulated” crypto platform.

Control Structure And Governance Concerns

Governance and ownership questions are also highly relevant.

Corporate records reviewed by Scam-Or Project identify Xu Zhao as both shareholder and president of the management board of Klickl Europe. SEC filings linked to Crypto 1 Acquisition Corp identify Michael (Xu) Zhao as founder, CEO, and director, while also referencing his involvement with IDCM and VGPay, a crypto-payment business.

For analytical purposes, Scam-Or Project treats Michael Zhao / Michael Xu Zhao / Xu Zhao as the key control identity associated with Klickl Europe, pending any clarifications from the company.

Read more about the KXTRA investment fraud investigation here.

Key Findings

1. Klickl Europe Appears Inside The KXTRA Money Flow

Evidence reviewed by Scam-Or Project indicates that funds deposited into OpenPayd-linked victim-facing accounts were later swept to Klickl Europe Sp. z o.o. as the apparent destination account.

This places Klickl in a central operational role within the KXTRA payment rail.

2. Klickl Operates As A Crypto-Financial Infrastructure Provider

Klickl markets a wide range of services, including:

• fiat and crypto payments
• stablecoin transfers
• payment APIs
• custody solutions
• exchange functionality
• asset management
• cards and spending products
• global transfer systems
• Web3 SaaS infrastructure

Its own disclosures describe the group as a multi-jurisdictional virtual-asset services operator.

3. The Polish VASP Entry Is Not A Full Financial Licence

Klickl Europe publicly references:

Polish Ministry of Finance guidance explicitly states that such registration cannot be interpreted as a financial licence or guarantee and that virtual-currency operators are not supervised like traditional financial institutions.

4. “Regulated Platform” Branding Requires Careful Scrutiny

Klickl presents itself publicly as a regulated crypto-financial platform.

At the same time, official Polish guidance indicates that entities listed in the virtual-currency register should not present themselves as operating under a prudentially supervised financial-licensing framework comparable to banking institutions.

Using VASP registration as a substitute for full financial authorisation may therefore create a misleading impression.

5. The Michael Zhao / Xu Zhao Connection Is Material

Corporate data reviewed by Scam-Or Project identifies Xu Zhao as shareholder and president of Klickl Europe.

SEC documentation identifies Michael (Xu) Zhao as a crypto entrepreneur associated with IDCM and VGPay.

This points toward a broader China-linked crypto-payment network connected to the Polish VASP structure.

6. Public Governance Disclosures Raise Questions

Klickl’s current public pages identify executives including:

• Ben Huang
• Dermot Mayes
• Sanne Ke
• Shawn Xie
• Alihan Ekesan
• Andrea Gay
• Jane Record

Older klickl.eu pages present a different management structure and in some cases list executives with limited identification details, including first-name-only references.

This is not evidence of fabrication. However, inconsistent governance disclosures represent a significant verification and compliance concern for a cross-border crypto-payment operator.

7. Klickl Should Know Where The Funds Went

If Klickl Europe received the swept victim deposits, the company should possess records relating to:

• customer onboarding
• ledger entries
• wallet destinations
• exchange counterparties
• OTC partners
• settlement rails
• conversion activity

For a crypto on-ramp provider, “we do not know” would not be an acceptable compliance response.

8. TFG Technology Remains An Active Investigative Hypothesis

TFG Technology Ltd allegedly appeared on the payout side of the KXTRA operation.

UK Companies House records identify Libo Wang, a Chinese national, as the controlling individual behind the company. Records also reference a section 1002A warning concerning allegedly misleading, false, or deceptive incorporation information.

A potential connection between TFG Technology and the same China-linked crypto-payment infrastructure surrounding Klickl remains an investigative hypothesis rather than an established fact.

9. RatEx42 Red / DAREX D Classification Appears Justified

The overall risk profile associated with Klickl includes:

• exposure to a fraud-linked payment rail
• transitional Polish VASP status
• opaque governance presentation
• China-linked ownership indicators
• broad crypto on-ramp functionality
• unresolved downstream fund-flow questions

Summary Table

Corporate And Regulatory Structure

Klickl positions itself as a Web3 finance and virtual-asset ecosystem.

Its websites describe products including:

• KlicklX
• KlicklONE
• Klickl Pay
• custody infrastructure
• trading systems
• payment APIs
• stablecoin solutions
• merchant payment tools
• global transfers
• card services

The company states that Klickl Europe is incorporated in Poland under KRS 0001053580 and registered under RD WWW-930 for exchange, brokerage, and virtual-asset account-maintenance activities.

However, the Polish Ministry of Finance has stated that:

• only an application and declaration are required for entry
• the register functions as a record-keeping mechanism
• registration is not equivalent to licensing or supervision

MiCA Transition Risks

Another important factor concerns the MiCA transition framework.

UKNF has indicated that Poland had not yet designated a national competent authority for CASPs due to missing implementing legislation. It also stated that operators using transitional arrangements could lose the ability to continue operations after 1 July 2026 without proper MiCA authorisation.

From a compliance perspective, Klickl Europe’s current status should therefore be viewed as a transitional high-risk VASP registration rather than a strong prudential authorisation framework.

Governance And Control Analysis

Corporate control structures deserve careful examination.

Polish records reviewed by Scam-Or Project identify Xu Zhao as president and shareholder of Klickl Europe Sp. z o.o.

SEC filings associated with Crypto 1 Acquisition Corp identify Michael (Xu) Zhao as founder and CEO, while also referencing his involvement with:

• International Digital Currency Markets (IDCM)
• VGPay

This is relevant because the KXTRA exposure cannot be dismissed as an isolated issue tied solely to a small Polish entity. The associated control figures appear connected to a broader crypto-payment and exchange ecosystem.

Management Disclosure Concerns

Klickl’s public management disclosures also raise governance questions.

The primary website lists figures such as:

• Ben Huang as President
• Dermot Mayes as CEO of Klickl UAE
• Sanne Ke as Head of Compliance / MLRO

Meanwhile, older klickl.eu pages display a different governance structure and include several individuals identified only minimally.

Scam-Or Project does not claim that any executive identities are fabricated. The concern is narrower but substantial: public governance disclosures appear inconsistent and require independent verification.

Klickl’s Position Inside The KXTRA Rail

The evidence-supported transaction structure currently appears as follows:

Victim → OpenPayd victim-facing VIBAN/sub-account → sweep to Klickl Europe → suspected crypto/on-ramp or settlement infrastructure → KXTRA operators

This places Klickl Europe in a critical operational position.

The company’s own product stack corresponds closely with the functional role indicated by the reviewed evidence, including:

• fiat-to-crypto conversion
• brokerage
• account maintenance
• settlement services
• payment APIs
• stablecoin transfers
• global transaction infrastructure

The key unanswered question therefore becomes:

What happened after the funds reached Klickl Europe?

Possible Scenarios

One conclusion remains unavoidable: Klickl does not appear as a random recipient name in a bank statement. It appears to have received swept victim funds.

TFG Technology Ltd: Ongoing Investigative Hypothesis

TFG Technology Ltd has not been proven to be affiliated with Klickl.

Nevertheless, it remains an important investigative node.

Companies House records identify:

Within the KXTRA structure, TFG allegedly appeared on the payout side through a Danish IBAN / Banking Circle-type rail.

This matches patterns commonly associated with investment-fraud confidence payouts, where small withdrawals are processed to preserve victim trust before larger withdrawals are blocked.

Current working hypothesis:

TFG Technology Ltd may have intersected with the same Asia-linked or China-linked crypto-payment infrastructure associated with Klickl and the broader KXTRA network.

At present, this remains a hypothesis only. Scam-Or Project has not obtained evidence proving direct ownership or corporate linkage between TFG Technology Ltd and Klickl Europe.

Conclusion

Klickl Europe does not appear peripheral to the KXTRA investigation.

Based on evidence reviewed by Scam-Or Project, the company appears to have received funds swept from OpenPayd-linked victim-facing accounts, placing it directly inside the payment trail.

Klickl publicly presents itself as a regulated Web3 finance platform. However, the Polish registration structure referenced by the company represents a record-keeping VASP registration rather than a banking-style licence or prudential financial authorisation.

The Polish Ministry of Finance itself states that the register should not be interpreted as equivalent to licensed financial supervision.

If Klickl was merely exploited by KXTRA-linked operators, it should be able to demonstrate that fact through:

• customer identification records
• wallet trails
• settlement records
• suspicious-activity filings
• onboarding documentation
• compliance actions
• termination records

If the company cannot explain the downstream movement of funds, the compliance concerns become significantly more serious.

KXTRA may have been the bait. OpenPayd may have functioned as the intake mechanism. Based on the reviewed evidence, Klickl appears to have operated as the gateway layer.

That is why RatEx42 categorises Klickl as Red with DAREX Tier D.

Scam-Or Project Complaints: Call For Sources

Scam-Or Project invites:

• victims
• former employees
• compliance officers
• payment specialists
• crypto-exchange personnel
• OpenPayd insiders
• Klickl insiders
• Banking Circle contacts
• law-enforcement sources

to provide relevant information.

We are specifically seeking:

• OpenPayd Excel files
• Klickl statements
• wallet addresses
• crypto transaction hashes
• KXTRA screenshots
• WhatsApp conversations
• onboarding documentation
• internal compliance correspondence
• DSAR responses
• Banking Circle and Danish IBAN documentation
• TFG Technology payout records
• information relating to Michael Xu Zhao / Xu Zhao
• information relating to Libo Wang
• evidence connecting Klickl, OpenPayd, TFG Technology, or KXTRA operators

Source References

Klickl Corporate Overview — Klickl’s official About section presents the group as a Web3 financial-services platform and outlines its digital-payment, crypto, custody, and merchant-infrastructure offerings, alongside publicly listed management personnel.

Klickl Regulatory Disclosure — Regulatory information published by Klickl references Klickl Europe’s Polish corporate registration (KRS 0001053580), RD WWW-930 virtual-asset registration, and related activity disclosures.

Klickl Europe Archived Corporate Page — The legacy klickl.eu website contains information regarding the Warsaw office, Polish tax registration details, KRS filing data, and RD WWW-930 virtual-asset activity registration.

Polish Ministry of Finance – Communication No. 77 — Official guidance clarifying that Poland’s virtual-currency register serves a record-keeping function only and should not be interpreted as a licence, guarantee, or prudential supervision framework comparable to traditional financial sectors.

UKNF MiCA Transitional Guidance — UKNF documentation discussing Poland’s transitional framework under MiCA, including the absence of a designated CASP supervisory authority and associated regulatory-transition concerns.

SEC Filing – Crypto 1 Acquisition Corp (Form S-1) — SEC materials identifying Michael (Xu) Zhao and referencing his historical involvement with IDCM and VGPay.

UK Companies House – TFG Technology Ltd Officers — Companies House records identifying Libo Wang and referencing the section 1002A warning concerning allegedly misleading or deceptive incorporation information.

UK Companies House – Persons With Significant Control (PSC) — Official PSC filings identifying Libo Wang as the controlling individual behind TFG Technology Ltd.