Red-Flag Review: Russian vbanq / Vault – A DigiBaaS “Crypto Bank” Built on the Crypterium / Choise Legacy

1. Overview: Why vbanq / Vault Is a High-Risk “Crypto-Banking” Cluster

Vault / vbanq promotes itself as a “crypto-friendly secure banking platform” and a provider of “Digital Banking-as-a-Service.” Behind this marketing, however, the structure, disclosures, and backstory point to a high-risk, non-transparent setup closely aligned with the troubled crypto projects Crypterium and Choise, driven by Russian entrepreneur Vladimir Gorbunov.

Open-source research indicates that:

• A Russian-controlled team, led by Vladimir Gorbunov, coordinates the operation.
• Vault IST DMCC (UAE) owns the Vault site and app and holds only a Software House licence, not a bank or financial-institution licence. (Source: Vault)
• Vault Fintech Solutions s.r.o. (Czech Republic) is registered as a virtual-asset service provider (VASP) and delivers crypto-related services for Vault.
• Pure Digital Exchange LLC (Delaware, USA) is an MSB registered with both FINTRAC (Canada) and FinCEN (USA) and appears to handle crypto–fiat transaction flows for the group.
• Payment cards are issued by Reap Technologies Limited (Hong Kong), with Vault Global Solutions Limited acting as the contractual “Partner” for cardholders under card terms governed by Lithuanian law. (Sources: Vault, Ltd Dir)
• vbanq.com / vbanq.net list Charism LLC (St. Vincent & the Grenadines) as site owner – the same offshore entity previously used in the Crypterium / Choise infrastructure. (Source: VBANQ)

Leadership profiles and internal documents clearly connect Vault / vbanq to the Russian-controlled Crypterium / Choise complex, which raised tens of millions during the 2017–2018 ICO wave and is now in liquidation in Lithuania (Choise Services UAB) after extended user complaints and scam allegations (Source: Scam-Or Project).

From a compliance standpoint, vbanq / Vault fits best into the category of a high-risk, multi-jurisdictional crypto-banking infrastructure, built on a problematic legacy and marked by serious transparency and investor-protection concerns.

2. Business Model & Promotional Claims

Vault (vault.ist) and vbanq (vbanq.com / vbanq.net) promote a white-label “bank + cards + crypto” package, marketed to brands that want to offer their own digital or “crypto bank” under a private label.

Key Selling Points

They advertise:

• Individually segregated IBAN accounts, Visa/Mastercard cards, support for Apple Pay / Google Pay, and “crypto-friendly” processing to more than 200 countries.
• Custody for 100+ cryptocurrencies, token integration, on-/off-ramp services, and FX between fiat and digital assets.
• Rapid go-to-market: launch a new “bank” within days, with minimal capital expenditure and “millions saved” versus building and licensing a full stack in-house.

vbanq is presented as the end-user interface: a business account supposedly “live in 24 hours,” offering:

• Corporate banking tools
• Multi-currency fiat balances (USD, EUR, INR)
• Digital-asset wallets (BTC, ETH, USDT)
• Third-party payment rails: SWIFT, ACH, Fedwire, SEPA, NEFT

Both brands consistently blur the line between:

1. Banking services (accounts, cards, payments), and
2. Technology / Banking-as-a-Service (pure software and integrations),

while neither Vault nor vbanq hold their own banking or payment-institution licences. They instead claim to operate via unnamed “regulated partners.”

The privacy policy explicitly states that Vault IST DMCC:

• “does not hold a banking or financial institution license,” and
• that “all financial, card, and token services are provided by regulated third-party institutions under their respective licenses and jurisdictions.”

This is a textbook “synthetic banking” scheme: a software entity brands and markets bank-like products, while the actual client relationships and legal responsibilities are fragmented across multiple external banks, card issuers, and MSBs.

3. Corporate Structure & Beneficial-Ownership Landscape

3.1 Key Entities and Their Roles

As disclosed on Vault’s own materials and related sources:

VAULT IST DMCC (UAE)

• DMCC-registered “Software House” (licence DMCC198149)
• Owns and operates the vault.ist website and app
• Not a bank or EMI; positioned as a technology platform only

Vault Fintech Solutions s.r.o. (Czech Republic)

• Company no. 21627002, Prague
• Registered as a provider of virtual-asset services (crypto exchange / wallet)
• Delivers crypto functionality to the Vault ecosystem

Pure Digital Exchange LLC (Delaware, USA)

• US LLC with MSB registration at FinCEN (USA) and FINTRAC (Canada)
• Appears responsible for crypto–fiat processing and fiat-payments flows

Vault Global Solutions Limited (Hong Kong)

• Hong Kong company no. 76127971, incorporated 16 January 2024 (cr.gov.hk)
• Identified in card documentation as “Partner” and front-end contracting party for cardholders, under Lithuanian governing law

Charism LLC (St. Vincent & the Grenadines)

• SVG LLC (no. 1999 LLC 2022) used historically in Crypterium/Choise card and wallet terms
• Now also listed as the vbanq website owner (Choise.com)

Choise Services UAB (Lithuania) – Legacy Entity

• Lithuanian VASP (crypto exchange and wallet operator)
• In formal liquidation (“Likviduojamas”) since April 2025 (rekvizitai.vz.lt)

3.2 Key Individuals and Likely Controllers

According to the Vault “Meet the Team” section:

• Vladimir Gorbunov – Founder of vbanq / Vault and earlier founder of Crypterium and Choise
• Austin Kimm – Chairman of the Board & Co-Founder
• Also co-founder of Crypterium and public face of the “first ever crypto payment card” claim
• Andrey Diyakonov – CCO
• Credited with scaling Choise.com to more than 1 million users and building its B2B platform

Investigative work by the Scam-Or Project describes Russians Vladimir Gorbunov, Gleb Markov, and Slava Semenchuk as central founding figures behind the Crypterium / Choise group and characterizes Vault and vbanq as B2B/white-label infrastructure brands operating inside the same ecosystem.

Although shareholder registers for entities such as VAULT IST DMCC, Vault Fintech Solutions, Vault Global Solutions Limited, and Charism LLC are not openly available, the continuity of:

• founders (Gorbunov, Kimm, Diyakonov), and
• corporate vehicles (Charism LLC, Choise Services UAB)

strongly suggests that beneficial ownership remains concentrated within the same Russian-centric founder circle that controlled Crypterium / Choise.

4. Historical Continuity with Crypterium & Choise

The Vault narrative directly roots itself in the 2017–2018 era, when Crypterium promoted itself as the “world’s first cryptobank” and rolled out a high-profile crypto card and high-yield “deposit” offerings.

Indicators of a Shared Legacy

• Vault claims to have introduced the first “crypto-backed payment card” in 2018 – a marketing line previously associated with Crypterium.
• Vault’s C-suite (Kimm, Diyakonov) are publicly presented as former leaders of Crypterium / Choise.com retail and B2B operations.
• Vault IST’s AML/KYC and anti-fraud policy PDFs still contain references to “Choise Services UAB” and “Crypterium AS” in their definitions, suggesting document re-use and a common compliance infrastructure.
• A liquidation report by the Scam-Or Project on Choise explicitly names Vault and vbanq as white-label “cryptobanking” extensions of the Crypterium / Choise risk perimeter.

Meanwhile:

• Choise Services UAB (Lithuania) is undergoing liquidation,
• Crypterium AS (Estonia) has been struck off, and
• user communities have repeatedly accused the group of freezing funds and operating a long-running scam.

Within this context, the rise of vbanq / Vault as a “new” B2B2C bank-as-a-service venture appears less like a clean reboot and more like a repackaging of the same technology stack and stakeholder circle under refreshed brand names and new jurisdictional layers.

5. Regulatory & Licensing Posture

5.1 What Is Regulated (and Where)

• Vault Fintech Solutions s.r.o. (Czech Republic)
• Holds VASP registration under Czech law for virtual-asset services (crypto exchange / wallet)
• No banking or EMI licence
• Pure Digital Exchange LLC (USA)
• Registered as an MSB with FinCEN (USA) and FINTRAC (Canada)
• Involved in crypto–fiat conversions and payment processing
• Reap Technologies Limited (Hong Kong)
• Card issuer operating under its own local authorisations and regulatory framework

5.2 What Is Not Regulated as a Bank

Vault’s own disclosures emphasize that it is not a bank or financial institution, even though the public-facing marketing heavily leans on:

• “crypto-friendly banking,”
• “global bank accounts,” and
• references to FDIC-insured checking provided via “partners.” (Vault.ist)

5.3 Regulatory Gaps and Key Concerns

1. Bank-like Branding Without Bank Licences

The use of terms such as “cryptobank,” “digital bank,” “checking accounts,” and “FDIC-insured” can easily mislead retail users into believing they enjoy:

• bank-level prudential oversight, and
• deposit-protection guarantees,

when in reality, client relationships and protections depend on opaque third-party banks and MSBs that are not clearly named or explained.

2. Fragmented and Opaque Counterparty Risk

A single client of vbanq / Vault may find themselves exposed simultaneously to:

• VAULT IST DMCC (software house, UAE)
• Vault Fintech Solutions s.r.o. (Czech VASP)
• Pure Digital Exchange LLC (US/Canada MSB)
• Reap Technologies Limited (HK card issuer)
• Vault Global Solutions Limited (HK contracting entity)
• Charism LLC (SVG website owner)

This multi-layer structure makes it harder to:

• understand who is responsible for what,
• supervise AML/CTF exposure, and
• seek recourse in case of disputes or losses.

3. Legacy Risk From Crypterium / Choise

The single EU-regulated VASP from the legacy stack, Choise Services UAB (Lithuania), is now in liquidation, while offshore entities such as Charism LLC continue to run products that look structurally similar. (rekvizitai.vz.lt)

Overall, the group appears to intentionally distribute roles across multiple jurisdictions with varying regulatory standards – a pattern common to high-risk “crypto banking” constructs.

6. Compliance Risk Assessment

From a professional compliance and risk-management perspective, Vault / vbanq should be assessed as a high-risk crypto-banking arrangement with serious conduct, AML/CFT, and investor-protection issues:

• The founder’s record with Crypterium / Choise – including investor losses and the liquidation of Choise Services UAB – is a major negative signal.
• The overall group structure is deliberately complex and partially opaque, involving free-zone and offshore entities and at least one contracting company that is not easily traced in public registers.
• The brand promotes “banking” solutions while explicitly disclaiming bank status and outsourcing responsibility to unspecified partners – contradicting best practices for transparency and consumer protection.
• Continuing links to Charism LLC (SVG) and the earlier Choise setup suggest a habit of rebranding and relaunching under new names, rather than resolving legacy problems and compensating harmed users.

6.1 Guidance for Regulated Institutions and Compliance Officers

Regulated firms should:

• Flag the following as high-risk counterparties:
• Vault / vbanq
• VAULT IST DMCC
• Vault Fintech Solutions s.r.o.
• Charism LLC (SVG)
• any Vault Global Solutions entity in Hong Kong or related jurisdictions
• Apply Enhanced Due Diligence (EDD) to any customer or transactional exposure, including:
• detailed review of source of funds,
• scrutiny of a customer’s relationship to the Vault / vbanq ecosystem, and
• checks for possible layering of transactions through these platforms.
• Carefully review any proposed partnership or white-label cooperation with Vault / vbanq, as reputational and regulatory risks are substantial.
• Where indicators of fraud, laundering, or unusual activity arise, consider filing Suspicious Activity Reports / Suspicious Transaction Reports (SARs/STRs) with the relevant Financial Intelligence Units (FIUs).

6.2 Guidance for Retail and SME Users

For individuals and smaller businesses:

• Treat Vault / vbanq as a high-risk, non-bank fintech.
• Do not use it as the primary place to store savings or for mission-critical business payments.
• Prefer well-regulated banks and EMIs where the legal entity, regulator, and jurisdiction are clearly disclosed and easily verifiable.

Preliminary conclusion for regulated partners:
For banks, EMIs, payment institutions, and other regulated intermediaries, vbanq / Vault should be categorised as a high-risk counterparty requiring:

• robust EDD,
• tightly drafted contracts allocating risk, and
• thorough verification of underlying bank/MSB partners, KYC standards, and complaint/exit mechanisms.

7. Structured Summary Table

8. Call for Information – Scam-Or Project Whistleblower Section

The Scam-Or Project will continue to track vbanq / Vault / Vault IST DMCC / Vault Fintech Solutions / Charism LLC and their predecessor entities Crypterium and Choise, focusing in particular on:

• The real beneficial-ownership and shareholder arrangements behind the structure
• How client funds move between EU, UAE, SVG, HK, and US entities
• The actual identity and risk profile of any U.S. partner banks behind FDIC-labelled products
• Internal practices around withdrawals, account freezes, KYC/AML controls, and complaint handling

We explicitly invite:

• insiders,
• former staff and contractors,
• banking and payment partners, and
• affected clients

to share documents, contracts, screenshots, and correspondence via the Scam-Or Project whistleblower section.

Submissions can be made confidentially. Verified information will support regulators, law-enforcement bodies, and victims in building a more complete picture of vbanq / Vault and its connection to the broader Crypterium / Choise complex.