FinTelegram’s current assessment is clear: Klickl Europe Sp. z o.o. appears inside the KXTRA fraud rail, not outside it. Victim materials reviewed by FinTelegram indicate that funds deposited into OpenPayd-linked, victim-facing accounts were swept onward to Klickl Europe, with the transaction reference reportedly stating “Sweep to Primary Account.” This is not a minor payment-processing footnote. It identifies Klickl Europe as the apparent primary-account recipient in the alleged KXTRA / KKR Global Investment money trail.
The 2-Minute Briefing
Klickl is not a random payee. Its own websites present a broad Web3 finance and virtual-asset infrastructure group offering global accounts, wallet services, merchant payments, stablecoin payments, payment APIs, custody services, OTC/exchange services, asset-management products, card/spending services, and Web3 SaaS solutions. Klickl describes itself as a multi-jurisdictional virtual-asset services group and states that, unless otherwise specified, the products and services on klickl.com are provided by Klickl Europe. That makes the OpenPayd → Klickl sweep highly material: victim funds were allegedly routed into a crypto-financial operating structure, not into an incidental commercial recipient.
Klickl’s Polish regulatory footing should not be overstated. Klickl states that Klickl Europe is incorporated in Poland under KRS 0001053580 and registered in Poland’s virtual-asset activity register under RD WWW-930. But Poland’s Ministry of Finance states explicitly that the register is record-keeping in nature, that entry is not equivalent to a licence or warranty, and that virtual-currency activity is not licensed or supervised in the way mainstream financial sectors are supervised.
Control and governance are equally important. Polish register data identifies Xu Zhao as president of the management board and shareholder of Klickl Europe. SEC materials for Crypto 1 Acquisition Corp identify Michael (Xu) Zhao as founder, CEO and director, and describe his background in crypto trading, IDCM, and VGPay, a crypto-payment business. FinTelegram treats Michael Zhao / Michael Xu Zhao / Xu Zhao as the relevant control identity for the Klickl Europe analysis, subject to any clarification from Klickl.
Read more on the KXTRA investment scam here.
Key Findings
1. Klickl Europe appears inside the KXTRA money trail
Victim materials reviewed by FinTelegram indicate that funds deposited into OpenPayd-linked accounts were swept to Klickl Europe Sp. z o.o. as the apparent primary-account recipient. That makes Klickl a central payment-rail actor in the KXTRA case.
2. Klickl is a crypto-financial infrastructure group, not a passive merchant
Klickl markets services including accounts, fiat and crypto payments, global transfers, stablecoin payments, payment API, custody, cards, OTC/exchange services, asset management, and Web3 SaaS infrastructure. Its own disclaimer describes Klickl as a multi-jurisdictional virtual-asset services group.
3. Klickl Europe’s Polish registration is not a robust financial licence
Klickl Europe discloses Polish KRS registration 0001053580 and virtual-asset register number RD WWW-930. However, Polish Ministry of Finance guidance states that the register is record-keeping in nature, that entry cannot be equated with a licence or warranty, and that virtual-currency activity is not licensed or supervised like mainstream financial institutions.
4. The “regulated” branding requires scrutiny
Klickl markets itself as a regulated virtual-asset platform. Polish official guidance states that Polish virtual-currency register entries cannot market themselves as conducting licensed or supervised activity under Polish law. Any reliance on Polish registration as a substitute for prudential authorisation is misleading in substance.
5. The Michael Zhao / Xu Zhao control issue is material
Polish register data reviewed by FinTelegram identifies Xu Zhao as president and shareholder of Klickl Europe. SEC filings identify Michael (Xu) Zhao as a crypto entrepreneur linked to IDCM and VGPay. This points to a broader China-linked crypto-payments network behind the Polish VASP.
6. Klickl’s public management presentation raises governance questions
Klickl’s public pages identify senior figures including Ben Huang, Dermot Mayes, Sanne Ke, Shawn Xie, Alihan Ekesan, Andrea Gay, Jane Record and others. The older klickl.eu page presents a different team format, including Ben Huang as Chief Compliance Officer and several senior figures with first names only. This is not proof of fabrication, but it is a governance and identity-verification red flag.
7. Klickl should know where the KXTRA money went next
If Klickl Europe received swept victim funds, it should know its customer, ledger entries, conversion records, wallet destinations, exchange accounts, OTC counterparties and settlement partners. “We do not know” would be an unacceptable answer for a crypto/on-ramp provider.
8. TFG Technology is a live hypothesis node
TFG Technology Ltd allegedly appeared on the payout side of the KXTRA case. Companies House records show TFG Technology Ltd as controlled by Chinese national Libo Wang and subject to a section 1002A warning relating to misleading, false or deceptive incorporation information. The possible link between TFG and the same China-linked crypto-payment infrastructure around Klickl remains a hypothesis, not a proven fact.
9. RatEx42 Red / DAREX D is justified
Klickl’s risk profile is severe: fraud-rail exposure, transitional Polish VASP status, opaque governance, China-linked control, broad crypto/on-ramp functionality, and unanswered downstream fund-flow questions.
Summary Table
| Field | Details |
|---|---|
| Brand | Klickl |
| Core entity | Klickl Europe Sp. z o.o. |
| Main domains | klickl.com, klickl.eu, klicklx.com, klicklone.com, klicklpay.com, klicklcustody.com, ex.klickl.com, futures.klicklx.com, alliance.klickl.com, cryptoeasy.app |
| Jurisdiction | Poland |
| Polish VASP registration | RD WWW-930 |
| Business model presented by Klickl | Web3 account, merchant payments, global transfers, stablecoin payments, payment API, custody, cards, OTC/exchange, asset management, SaaS |
| Control / UBO issue | Polish register data identifies Xu Zhao; SEC sources identify Michael (Xu) Zhao in crypto-payment and exchange businesses |
| Known payment-rail role | Apparent recipient of funds swept from OpenPayd victim-facing accounts in KXTRA case |
| KXTRA connection | Victim evidence indicates OpenPayd → Klickl Europe sweep structure |
| TFG Technology connection | Working hypothesis only; TFG appears on payout side and is controlled by Chinese national Libo Wang |
| RatEx42 rating | Red with DAREX tier D |
Corporate And Regulatory Profile
Klickl presents itself as a Web3 finance platform and virtual-asset group. Its website describes KlicklX as a Web3 digital financial account integrating wallet, digital assets, fiat accounts and card-based consumption services. KlicklONE is described as a digital finance system for corporates and merchants. Klickl Pay includes merchant payments, global transfers, stablecoin payments, POS terminals and payment API. The wider stack also includes custody, cards, OTC/exchange, asset management, professional trading, and listing applications.
Klickl’s regulatory pages state that Klickl Europe is incorporated in Poland under KRS 0001053580 and registered in Poland’s virtual-asset activity register under RD WWW-930 for exchange, brokerage and virtual-asset account-maintenance activities.
This registration must be read correctly. Poland’s Ministry of Finance has stated that only an application and declaration are needed for the register entry; the register is record-keeping in nature; and entry cannot be equated with a licence or warranty.
The MiCA transition adds a second risk layer. UKNF has stated that Poland had not designated a national competent authority for CASPs due to the absence of implementing legislation. It also stated that virtual-currency register entities may operate under transitional arrangements, but after 1 July 2026 domestic operators lose that possibility unless authorisation exists under the MiCA framework.
In compliance terms, Klickl Europe’s Polish VASP registration should be treated as a high-risk transitional registration, not as a strong prudential authorisation.
Control And Governance
The identity and control structure require close scrutiny.
Polish register data reviewed by FinTelegram identifies Xu Zhao as president of the management board and shareholder of Klickl Europe Sp. z o.o. Public market filings identify Michael (Xu) Zhao as founder, CEO and director of Crypto 1 Acquisition Corp and describe him as having started International Digital Currency Markets (IDCM) and VGPay, a crypto-payment business.
This matters because Klickl’s KXTRA exposure cannot be treated as a small Polish registration anomaly. The control person is linked to a broader crypto-exchange and crypto-payment history.
Klickl’s governance presentation also deserves scrutiny. Klickl’s main site lists senior figures including Ben Huang as President, Dermot Mayes as CEO of Klickl UAE, Sanne Ke as Head of Compliance / MLRO, and other regional, business and functional leaders. The older klickl.eu page presents a different structure, naming Ben Huang as Chief Compliance Officer and listing several figures with minimal identifiers, including first-name-only entries. For a crypto/on-ramp entity handling cross-border payment flows, unclear or shifting management presentation is a governance red flag.
FinTelegram does not state that Klickl’s listed executives are fake. The finding is narrower and stronger: Klickl’s public governance disclosures are inconsistent and require independent verification.
Klickl In The KXTRA Fraud Rail
The evidence-supported rail map is:
Victim → OpenPayd victim-facing VIBAN / sub-account → sweep to Klickl Europe → suspected crypto/on-ramp or settlement layer → KXTRA operators
That puts Klickl Europe in a critical position. The company’s own business model matches the functional role suggested by the evidence: fiat/crypto exchange, brokerage, account maintenance, payment API, stablecoin payments, global transfers and settlement infrastructure.
Klickl therefore should be able to answer the essential question: what happened after the money hit Klickl Europe?
Possible scenarios:
| Scenario | Status | Implication |
| Klickl acted as on-ramp processor for a KXTRA-related customer | Working hypothesis | Klickl should identify the customer and downstream wallets / exchanges |
| Klickl acted as settlement intermediary for another processor or merchant | Working hypothesis | Klickl should identify the counterparty and transaction purpose |
| Klickl was closer to the KXTRA operators | Open investigative question | Requires evidence from wallet trails, onboarding files, communications or internal records |
| Klickl was abused by fraudsters | Possible defence | Klickl should prove this by disclosing customer, monitoring, reporting and termination records |
The key point is non-negotiable: Klickl is not a random name in a bank statement. It appears to be the entity that received the swept funds.
TFG Technology Ltd: Working Hypothesis
TFG Technology Ltd is not proven to be a Klickl affiliate. It is, however, a serious hypothesis node.
The UK Companies House records identify TFG TECHNOLOGY LTD, company number 16544033, and show a warning that the registrar is taking or has taken steps to strike off the company under section 1002A of the Companies Act 2006 due to incorporation information described as misleading, false or deceptive. Companies House records identify Libo Wang, a Chinese national resident in China, as director and person with significant control, with ownership of shares and voting rights of 75% or more and the right to appoint or remove directors.
In the KXTRA case, TFG appears on the payout side as the sender of a partial victim payout through a Danish IBAN / Banking Circle-type rail. That fits the confidence-payout pattern seen in investment fraud: return a controlled amount to maintain trust, then block larger withdrawals or demand additional payments.
Working hypothesis: TFG Technology Ltd may have been connected to the same China-linked or Asia-linked crypto-payment infrastructure orbit that intersects with Klickl and the KXTRA fraud rail.
Status: hypothesis only. FinTelegram does not yet have evidence proving a corporate or ownership link between TFG Technology Ltd and Klickl Europe.
Conclusion
Klickl Europe is not peripheral to the KXTRA case. Based on victim evidence reviewed by FinTelegram, it appears as the recipient of funds swept from OpenPayd victim-facing accounts. That places Klickl inside the money trail.
Klickl markets itself as a regulated Web3 finance platform. But the Polish regulatory basis it discloses is a record-keeping VASP registration, not a banking-style licence or prudential authorisation. Poland’s own Ministry of Finance says the register cannot be equated with a licence and that virtual-currency activity is not supervised like mainstream financial institutions.
If Klickl was merely abused by the KXTRA operators, it should prove it. It should disclose the customer, the ledger trail, the wallet destinations, the exchanges, the settlement partners, the suspicious-activity filings, and the termination actions.
If Klickl cannot or will not explain where the money went, the suspicion deepens.
KXTRA was the bait. OpenPayd was the intake pipe. Klickl appears to have been the gateway. That is why RatEx42 flags Klickl Red and DAREX D.
Whistleblower Call
FinTelegram invites victims, former employees, compliance officers, payment staff, crypto-exchange personnel, OpenPayd insiders, Klickl insiders, Banking Circle contacts, law-enforcement officials, and other knowledgeable sources to contact Whistle42.
We are specifically looking for:
- OpenPayd Excel files
- Klickl account statements
- Klickl wallet addresses
- crypto transaction hashes
- KXTRA app screenshots
- WhatsApp chats
- onboarding files
- internal compliance emails
- DSAR responses
- Banking Circle / Danish IBAN documentation
- TFG Technology payout records
- any information on Michael Xu Zhao / Xu Zhao
- any information on Libo Wang
- any evidence linking Klickl, OpenPayd, TFG Technology, or KXTRA operators
Source Notes
- Klickl About page — describes Klickl as a Web3 finance platform, sets out services, and lists management/team members.
https://www.klickl.com/about - Klickl Regulatory Information — states Klickl Europe’s KRS number, RD WWW-930 registration and Polish virtual-asset activities.
https://www.klickl.com/help/detail?id=569113099598475264609f - Klickl Europe legacy page — lists the Warsaw office, KRS, Polish tax ID and RD WWW-930 activities.
https://klickl.eu/about.html - Polish Ministry of Finance Communication No. 77 — states that Polish virtual-currency register entry is record-keeping, not a licence or warranty, and that virtual-currency activity is not licensed/supervised like mainstream financial sectors.
https://www.gov.pl/web/finance/communication-no-77-on-the-status-of-virtual-currency-operators - UKNF MiCA transition position — explains the absence of a Polish CASP competent authority and transitional-period issues.
https://www.knf.gov.pl/knf/pl/komponenty/img/Stanowisko_UKNF_-_nadzor_nad_krypto_96996.pdf - SEC Form S-1, Crypto 1 Acquisition Corp — identifies Michael (Xu) Zhao and his IDCM / VGPay background.
https://www.sec.gov/Archives/edgar/data/1870471/000110465921138253/tm2124028d3_s1.htm - Companies House — TFG Technology Ltd officers — identifies Libo Wang and the section 1002A warning.
https://find-and-update.company-information.service.gov.uk/company/16544033/officers - Companies House — TFG Technology Ltd PSC — identifies Libo Wang as person with significant control.
https://find-and-update.company-information.service.gov.uk/company/16544033/persons-with-significant-control
