In a growing number of the investment and cryptocurrency fraud cases we handle, the same name appears in connection with the payment method: OpenPayd Financial Services Malta Limited, an e-money institution licensed by the Malta Financial Services Authority (MFSA), which frequently acts as a payment processor or provider of virtual IBANs behind fraudulent trading platforms. For victims who have deposited their money using such a virtual IBAN, this is not a trivial technical detail – it can be crucial for further legal action.
What is OpenPayd – and why does the name appear so frequently?
OpenPayd is part of an international network of companies under the so-called Akce Group, which is attributed to fintech entrepreneur Ozan Özerk and operates regulated payment institutions in Malta, the UK, Lithuania, and Turkey. OpenPayd provides corporate clients with so-called master vIBANs. These clients then issue individual, personalized virtual IBANs to their own users. A virtual IBAN looks like a regular bank account number but does not correspond to an independent bank account; it is merely an allocation reference. This gives payers the impression that they are transferring funds to their own account. According to our observations, this very infrastructure is repeatedly used by operators of fraudulent investment and cryptocurrency platforms to receive deposits from victims.
Why the virtual IBAN is particularly relevant forensic purposes
Unlike many other payment service providers that appear in the background of fraud cases, OpenPayd already has a solid history of supervisory and arbitration proceedings that could be important for future cases:
- precedent in the Maltese Financial Arbiter (ASF) 155/2024): A person in need of protection Older victims received full compensation. Reimbursement granted. The arbitrator ruled that OpenPayd the rules of PSD2 for regular IBANs not apply to virtual ones IBANs could be transferred, which are not covered by regulatory law and higher costs for consumers It involves risks. The decision is in the appeal proceedings pending. In subsequent proceedings ASF 228/2024 and ASF 223/2025, the arbitrator dismissed the appeals. He reiterated that OpenPayd was not authorized to credit the funds to the VIBAN account holder instead of the designated beneficiary without the sender's explicit authorization, and reported this violation to the MFSA. However, compensation was denied in each case due to a lack of causality, as the victims themselves had granted the perpetrators remote access to their accounts.
- Sanction against the group-affiliated European Merchant Bank in Lithuania: The Bank of Lithuania imposed a fine of 270,000 euros and issued additional requirements due to inadequate systems for money laundering and sanctions prevention.
- International research „Scam Empire“ (OCCRP, SVT, VG): OpenPayd and European Merchant Bank are named as payment processors in an alleged investment fraud network with at least $275 million in damages and at least 32,000 victims worldwide; at least €2.5 million is said to have flowed through an OpenPayd account on a suspected fraudulent platform. According to the researchers, there is no evidence that either company was aware of the fraudulent origin of the processed funds. OpenPayd stated that it monitors all transactions to and from customers for fraud and financial crime indicators.
- Investigations in Turkey: The Istanbul Chief Public Prosecutor's Office is investigating individuals and companies associated with Ozan Elektronik Para A.Ş., which is attributed to the same beneficial owner, on suspicion of money laundering; assets have been seized and arrests made. Ozan Özerk himself is not named as a suspect.
Important for context: Decision ASF 155/2024 is not yet legally binding; OpenPayd has filed an appeal. Proceedings ASF 228/2024 and ASF 223/2025 have been decided and dismissed. Those responsible have publicly emphasized that they are only shareholders in certain of the aforementioned companies. Nevertheless, the mere existence of a successful precedent demonstrates that a structured investigation in comparable cases can be successful.
Payment via OpenPayd: six steps for those affected
Anyone who has transferred money via an OpenPayd connection (virtual IBAN, IBAN with the country code MT and the SWIFT/BIC "CFTEMTM1") to a supposed investment or crypto platform should check the following steps in this order:
- Secure all payment receipts. Gather bank statements, transfer confirmations, IBAN and SWIFT details of the recipient account, and all communication with the platform before deadlines for information or recovery claims expire.
- Have the payment method forensically verified. Verify that your deposit was demonstrably made via an OpenPayd connection and have the payment flow forensically documented – as far as possible up to the cash-out point.
- Consider filing a complaint with the Maltese Financial Arbiter (Office of the Arbiter for Financial Services). Decision ASF 155/2024 can serve as a reference; a formal appeal is possible out of court and with a comparatively low risk of costs. According to previous case law, the decisive factors are whether there is a need for protection and whether the person concerned can be accused of gross negligence.
- File a criminal complaint, with reference to the payment method via OpenPayd and – where applicable – to the publicly known procedures (Financial Arbiter, Bank of Lithuania, OCCRP investigation, Turkish investigation) in order to provide additional leads for investigating authorities.
- Consider taking joint action with other affected parties. Since experience shows that several victims have used the same platform and payment method, a coordinated approach – for example, when gathering evidence or dealing with authorities – can reduce effort and costs and increase the chances of success.
- Refrain from taking any unauthorized steps. Do not make any payments to so-called "recovery companies" that promise recovery against advance payment, and do not pass on any access data or seed phrases to third parties.
Why early forensic investigation is useful
Payment methods via regulated e-money institutions—unlike purely crypto transactions via pseudonymous wallets—generally leave traceable trails: account opening documents, KYC data, transaction logs, and regulatory reports. Combined with a blockchain forensic analysis of subsequent cash-out paths, this often allows for a significantly more complete reconstruction of the payment flow than would be possible with purely decentralized payment methods. Decision ASF 155/2024 demonstrates that tracing is achievable in individual cases. However, this remains the exception: in the vast majority of published OpenPayd cases, the complaints were dismissed, mostly due to the question of causality. Therefore, robust documentation of the payment path and due diligence is the decisive factor.
Was your payment made via OpenPayd or a virtual IBAN with a Maltese connection?
Financial forensics examines the actual payment route for victims, documents the connection to known platforms and processes, and prepares the results in a legally admissible manner for criminal charges, complaints to the Financial Arbiter, or civil proceedings. Contact: postfach@finanz-forensik.de
This article is based on publicly available sources (regulatory authorities, arbitration decisions, investigative journalism) and does not constitute a legal assessment or finding of guilt against the companies or individuals mentioned. Several of the proceedings mentioned are, to the best of our current knowledge, not yet legally concluded; some of the companies involved have filed appeals or made public statements.
Frequently asked questions about OpenPayd and virtual IBANs
Check your bank statement and transfer confirmation. Look for an IBAN with the country code MT and the SWIFT/BIC "CFTEMTM1". Even if the platform name is listed in the payment reference or you have listed yourself as the beneficiary, the recipient may still be a payment service provider.
A virtual IBAN looks like a regular bank account number, but it doesn't correspond to an independent bank account. It's merely an allocation reference. OpenPayd provides corporate clients with master vIBANs, from which they issue personalized virtual IBANs to their own users. The money is credited to the corporate client's account. This isn't necessarily the fraudster's account: In the cases decided so far, the perpetrators lured their victims to legitimate cryptocurrency providers.
In several cases, the Financial Arbiter has focused on whether the victims themselves granted the perpetrators access to their accounts, for example via remote access programs, or whether they initiated further payments despite an explicit warning from their bank. Both factors have so far led to the rejection of claims, regardless of whether the payment service provider itself was found to have committed a violation.
Not automatically. The Maltese Financial Arbiter ruled in several proceedings that OpenPayd was not permitted to credit funds to the holder of the virtual IBAN instead of the named beneficiary without the sender's authorization. However, this only leads to a refund if this violation actually caused the loss. This is precisely where most complaints fail.
The Office of the Arbiter for Financial Services is an independent dispute resolution body in Malta. It investigates consumer complaints against Maltese financial service providers out of court and can award compensation.
The arbitrator awarded a vulnerable elderly victim full compensation. He ruled that OpenPayd could not apply the PSD2 rules for regular IBANs to virtual IBANs because the latter are not subject to regulatory oversight and pose higher risks for consumers. OpenPayd has appealed.
The procedure is out of court and involves significantly lower costs than litigation. In previous rulings, the arbitrator ordered each party to bear its own costs. Expenses arise primarily from the preparation of evidence and, if necessary, legal representation.
Financial arbitrators have their own admissibility deadlines, starting from when they become aware of the facts. These deadlines are parallel to civil law limitation periods and deadlines for requests for information or recall from your own bank. Therefore, evidence should be secured early and the facts reviewed promptly.
Yes. The decisive factor is the location of the damage, which is usually Germany. A specifically named payment method via a regulated institution provides investigating authorities with usable leads, for example for requests for information within the European legal assistance mechanism.
This depends primarily on two questions: Was there a particular need for protection, and can the affected individual be accused of gross negligence? Those who granted perpetrators remote access to their accounts or continued payments despite a warning from their bank have so far had no success before the Financial Arbiter. Recovery of the funds can never be guaranteed. However, payment via a regulated institution leaves significantly more usable traces than purely crypto-based transfers.
