FinTelegram’s latest OpenPayd files show a hard pattern: victim deposits into OpenPayd vIBANs were swept to Klickl Europe Sp. z o.o. The Polish entity is controlled by Xu Zhao, who appears linked to Michael (Xu) Zhao, founder/CEO of Klickl and a crypto-finance figure connected to IDCM, VGPay, Crypto 1 Acquisition Corp, and C1 Fund. This is not a faceless payment rail. It has names, entities, and control points.
2-Minute Briefing
Klickl is not a small Polish VASP. The Polish entity is only the EU-facing rail node of a broader, Chinese-controlled crypto-finance system with multiple business units, websites, jurisdictions, and payment functions.
FinTelegram has repeatedly identified Klickl Europe Sp. z o.o. in OpenPayd victim files. The payment pattern is consistent: victims paid into OpenPayd named vIBANs / CFTEMTM1, and the funds were then transferred to Klickl Europe with the reference “Sweep to Primary Account.” That places the Polish entity directly inside the victim-fund flow. But the Polish company is not the whole structure. It is the European access point.
Klickl’s own ecosystem presents a much larger operation. Klickl Pay describes itself as a “multi-jurisdictional virtual asset service provider” operating across different licensing frameworks and hubs. It offers merchant payments, global transfers, stablecoin payments, and fiat/crypto collection and payout functionality through wallet and API infrastructure. In other words, Klickl is not merely registering as a Polish VASP. It markets itself as a cross-border fiat-and-crypto payment system.
The wider Klickl footprint includes multiple domains and product lines: klickl.com, klickl.eu, klicklpay.com, klicklx.com, klicklone.com, klicklcustody.com, ex.klickl.com, futures.klicklx.com, alliance.klickl.com, and other related digital-asset interfaces. These are not decorative websites. They map to payments, exchange, custody, merchant infrastructure, trading, Web3 accounts, and partner networks.
The control question leads back to Xu Zhao / Michael Xu Zhao. The Polish register identifies Xu Zhao as the control person behind Klickl Europe. Public and SEC-linked materials connect Michael Xu Zhao to the broader Klickl/IDCM/VGPay/Crypto 1/C1 Fund network. This gives Klickl an international dimension: Poland for EU market access, ADGM/UAE for MENA positioning, Canada through the IDCM Exchange / FINTRAC node, U.S. vehicles through SEC-linked structures, and Hong Kong/China-linked crypto networks.
That is the core finding: Klickl Europe appears to be the EU rail node of a global Klickl/Zhao crypto-payment system. OpenPayd provided the vIBAN infrastructure. Klickl Europe received the victim funds. The broader Klickl network must now explain where the money went, which business unit handled it, and who controlled the downstream wallets, exchanges, or settlement accounts.
Read our reports on Klickl Europe here.
Key Findings
- Klickl is not merely a Polish VASP. Klickl Europe is the EU-facing entity that appears in OpenPayd victim files, but the broader Klickl structure presents itself as a multi-jurisdictional crypto-finance and payment system with payments, fiat/crypto collection, stablecoin payments, exchange, custody, merchant services, Web3 accounts and API infrastructure. Klickl Pay explicitly describes itself as a multi-jurisdictional virtual-asset service provider.
- OpenPayd files place Klickl Europe inside the victim-fund flow. The payment summaries show the same pattern: victim Payin into OpenPayd infrastructure, immediate Transfer, and funds routed to Klickl Europe with the reference “Sweep to Primary Account.” The Humer file alone shows four Payins totaling €100,500, each matched by a transfer to Klickl Europe.
- The OpenPayd GDPR response confirms the vIBAN architecture. OpenPayd confirmed that the victim-facing IBAN was not a normal personal account, but a named virtual IBAN linked to Klickl Europe’s corporate payment account. OpenPayd also stated that once funds were credited, they became the property of Klickl Europe. That makes Klickl the economic recipient, not a passive name in the background.
- The Polish entity appears to be the EU rail node. Klickl Europe Sp. z o.o. is incorporated in Poland, disclosed with KRS 0001053580 and Polish virtual-asset registration RD WWW-930. Its role in the OpenPayd files suggests that it was used as the EU collection and on-ramp point for European victim flows. The Klickl ecosystem is global and multi-domain.
- The network includes or references multiple domains and product lines: klickl.com, klickl.eu, klicklpay.com, klicklx.com, klicklone.com, klicklcustody.com, ex.klickl.com, futures.klicklx.com, alliance.klickl.com, and related digital-asset interfaces. These map to payments, merchant collection, exchange, custody, Web3 accounts, trading and partner infrastructure.
- Klickl Pay adds a payment-system dimension. Klickl Pay markets merchant payments, global transfers and stablecoin payments, and says it integrates fiat and crypto payment modes into wallet or API infrastructure for domestic and cross-border collection and payment needs. That is directly relevant to the OpenPayd victim-fund flows.
- The network extends beyond the EU. Klickl’s broader map includes a Polish EU node, an ADGM/UAE node through Klickl International Limited, a Canadian FINTRAC-linked IDCM Exchange node, U.S. SEC-linked vehicles including Crypto 1 Acquisition Corp and C1 Fund, and Hong Kong/China-linked blockchain and crypto-payment connections. This is a global crypto-finance network, not a local Polish startup.
- The control question leads to Xu Zhao / Michael Xu Zhao. Polish register data identifies Xu Zhao as the controlling person behind Klickl Europe. Public and SEC-linked materials connect Michael Xu Zhao to the broader Klickl / IDCM / VGPay / Crypto 1 / C1 Fund ecosystem. The identity and control structure must be explained by Klickl, OpenPayd and regulators.
- The fraud-front exposure is no longer isolated. Klickl Europe appears in victim flows connected to fake investment fronts including KXTRA / KKR Global Investment and fake Peel Hunt / Peelhuntaicore. The evidence points to more than one scam brand using the same OpenPayd–Klickl rail.
- Klickl must hold the downstream data. If Klickl Europe was “only” an on-ramp, it should know the customer, ledger entries, wallets, exchanges, OTC desks, settlement partners and conversion records. If it cannot identify where the victim money went, the suspicion deepens.
Read our report on the KXTRA and Peel Hunt scams here.
The Key People Behind Klickl
Michael (Xu) Zhao — The Control Person Behind The Polish Klickl Entity And The Global Klickl Network
Michael (Xu) Zhao is the central control figure in the Klickl scheme (formerly known as the International Digital Currency Markets). In Poland, he appears as Xu Zhao, the control person behind Klickl Europe. In the global market, he appears as Michael Zhao / Michael Xu Zhao, founder and CEO of Klickl and Co-Founder / Managing Partner of C1 Fund in Dubai. This makes Klickl Europe the EU-facing rail node of a wider Zhao-controlled crypto-finance network — not an isolated Polish VASP.
The hard corporate fact is in Poland: Xu Zhao is listed as president of the management board, beneficial owner, shareholder, and holder of the entire shareholding of Klickl Europe Sp. z o.o.
Klickl Europe was the merchant/client entity in the OpenPayd rail that facilitated the investment scams KXTRA and Peel Hunt / peelhuntaicore. If victim funds were swept to Klickl Europe, the Polish control person is not a footnote. C1 Fund’s SEC materials identify Michael (Xu) Zhao as Vice Chairman and also Founder & CEO of Klickl.
SEC filings for Crypto 1 Acquisition Corp identify Michael (Xu) Zhao as founder, CEO and director. The filing states that he began investing in crypto in 2016, served as founder/executive chairman of International Digital Currency Markets (IDCM), and founded/led VGPay, a crypto-payment business serving crypto exchanges and their clients.
FinTelegram’s working position: Xu Zhao and Michael (Xu) Zhao appear to be the same control identity or directly connected control identity for Klickl Europe and the broader Klickl group. If Klickl disputes this, it should provide documentary clarification.
Ben Huang, Dermot Mayes, Sanne Ke And The Public Team
Klickl lists Ben Huang as President, Dermot Mayes as CEO of Klickl UAE, Shawn Xie as Head of KlicklONE, Alihan Ekesan as Head of Payments, Andrea Gay as Chief Strategy Officer, Jane Record as VP of Corporate Affairs, and Sanne Ke as Head of Compliance / MLRO. It also lists advisors including Dr. Najam Kidwai, Andrew Au, Nina Shapiro, and Mo Shaikh.
This places Klickl in a broader crypto-finance network, not a simple Polish VASP box.
Summary Table
| Person / Entity | Role | Jurisdiction / Link | Evidence | Red Flag |
|---|---|---|---|---|
| Xu Zhao aka Michael (Xu) Zhao | President, UBO, full shareholder; Founder/CEO of Klickl; Crypto 1 founder/CEO/director | Poland / China-linked; US filings / crypto network | Polish register; C1 Fund SEC; LinkedIn profile | Controls entity receiving funds; DCM/VGPay crypto-payment background |
| Ben Huang | President listed by Klickl | Klickl public site | Klickl Exchange | Needs clarification on role and oversight |
| Shawn Xie | Head of KlicklONE | Singapore | Klickl Exchange | Klickl not listed in his LinkedIn profile |
| Sanne Ke | Head of Compliance / MLRO listed by Klickl | Klickl public site | Klickl Exchange | Must explain compliance controls; Klickl not mentioned in her LinkedIn profile |
| Dermot Mayes | CEO, Klickl UAE listed by Klickl | Klickl public site | Klickl Exchange | Needs independent verification and role clarity; |
| Alihan Ekesan | Head of Payments | Klicks public site | Klickl Exchange | |
| Dr. Najam Kidwai | C1 Fund / advisor network | C1 Fund / Klickl | C1 Fund, SEC, Klickl Exchange | Links to broader digital-assets finance network |
FinTelegram does not allege that these persons operated any scam. The issue is governance accountability. If these individuals are publicly presented as leadership, payments, compliance, or advisory figures, then they should clarify what they know about Klickl Europe’s OpenPayd rails, onboarding, transaction monitoring, and victim-fund flows.
Dr. Najam Kidwai And C1 Fund Links
SEC materials for C1 Fund identify Dr. Najamul Kidwai as founder/chairman/director and refer to his digital-assets, blockchain, and software-investment background. Klickl Exchange also lists him in its board/advisor section as President and CEO of C1 Fund.
This places Klickl in a broader crypto-finance network, not a simple Polish VASP box.
Summary Table – The Klickl / Zhao Network
The table should be used to frame Klickl as a multi-entity crypto-finance scheme, not merely as a Polish VASP. The Polish entity, Klickl Europe Sp. z o.o., is the entity repeatedly appearing in OpenPayd victim files as the recipient of swept funds. Klickl’s own disclosures also identify Klickl International Limited in ADGM and state that, unless otherwise specified, products and services on klickl.com are provided by Klickl Europe. SEC filings then connect Michael (Xu) Zhao to Klickl, Inc., IDCM, VGPay, Crypto 1 Acquisition Corp, and C1 Fund, creating a broader crypto-exchange, payment, and capital-markets network.
| Category | Entity / Domain | Jurisdiction / Status | Role / Relevance | Source / Evidence |
|---|---|---|---|---|
| Core EU rail entity | Klickl Europe Sp. z o.o. | Poland; KRS 0001053580; VASP register RD WWW-930 | EU-facing Klickl entity. Identified in OpenPayd victim files as recipient of swept funds. Klickl says it provides services on klickl.com unless otherwise stated. | Klickl disclosure states KRS 0001053580 and RD WWW-930; OpenPayd victim files identify Klickl Europe as receiver. |
| Regulated ADGM entity | Klickl International Limited | Abu Dhabi Global Market; FSRA firm; FSP No. 220070; active | ADGM entity in the Klickl Group. Relevant to MENA positioning and regulated-crypto branding. | ADGM register lists active financial firm, FSP date 16 Apr 2024; Klickl also discloses this entity. |
| Legacy / broader group entity | Klickl, Inc. | SEC filings / Zhao-linked | C1 Fund filings say Zhao served as Executive Chairman of Klickl, Inc., formerly known as International Digital Currency Markets (IDCM). | SEC / C1 Fund filing. |
| Canadian MSB node | IDCM Exchange Limited | Canada; FINTRAC-registered MSB | Relevant because Klickl Pay’s disclosures reference IDCM Exchange Limited and the broader Zhao-linked IDCM legacy. | FINTRAC-derived public registry data identifies IDCM Exchange Limited in Vancouver; |
| Legacy crypto-exchange entity | International Digital Currency Markets / IDCM | International / Zhao-linked | Crypto exchange / digital-asset trading infrastructure. Reported predecessor or former name of Klickl, Inc. | SEC / C1 Fund filing links Zhao to IDCM. |
| Crypto-payment business | VGPay | Zhao-linked crypto-payment business | Crypto-payment operation; important because the OpenPayd/Klickl case concerns payment rails and crypto on-ramping. | SEC / C1 Fund filing says Zhao was CEO of VGPay crypto-payment business. |
| US SPAC vehicle | Crypto 1 Acquisition Corp | United States; SEC filer / SPAC | Capital-markets vehicle focused on digital assets / crypto / blockchain. Michael (Xu) Zhao identified as founder, CEO and director. | SEC / C1 Fund filing. |
| US fund structure | C1 Fund Inc. | United States; SEC filer | Digital-asset / crypto-linked fund structure. Public materials identify Michael (Xu) Zhao as Vice Chairman and connect him to Klickl. | SEC filing and Klickl/C1 public materials. |
| Industry association link | Hong Kong Blockchain Association | Hong Kong / industry association | Network node around Zhao and several public Klickl-linked persons; relevant to the China/Hong Kong crypto ecosystem. | SEC/C1 materials and Klickl public-team context link Zhao and other named persons to HK blockchain circles. |
| Group Domains / Brands | klickl.com klickluae.com/ klicklpay.com / Klickl Pay klicklone.com / KlicklONE klicklx.com / KlicklX klicklcustody.com / merchant.klicklcustody.com | Public websites & brands | Product and service related websites | public sources |
| App / related domain | cryptoeasy.app | App/domain | Previously identified related app/domain; requires further verification of ownership and operational link. | Investigative lead; verify before stating as confirmed group entity. |
Klickl Europe is the Polish entity that appears in the OpenPayd victim files, but the Klickl structure is broader. Klickl’s own disclosures point to a Polish VASP entity and an ADGM-regulated entity. SEC filings connect Michael (Xu) Zhao to Klickl, Inc., IDCM, VGPay, Crypto 1 Acquisition Corp and C1 Fund. In other words, the Polish company appears to be the EU rail node of a wider Zhao-linked crypto-finance network. The open question is whether that network was merely used by fraud operators — or whether parts of it were closer to the victim-fund flows than they now admit.
FinTelegram Assessment — Global Klickl Dimension
Established Facts
Klickl Europe Sp. z o.o. is the entity repeatedly identified in OpenPayd victim-payment files as the recipient of funds swept from named OpenPayd vIBANs. The recurring pattern is clear: victim Payins entered the OpenPayd rail, were transferred out, and were swept to Klickl Europe with the reference “Sweep to Primary Account.” OpenPayd’s GDPR response confirms that the vIBAN structure was linked to Klickl Europe as corporate client and that credited funds became the property of Klickl Europe.
Klickl Europe is the EU-facing entity in this structure. Beyond Poland, the Klickl/Zhao network extends into a broader international crypto-finance structure. Klickl’s own disclosures and public materials identify entities and domains outside Poland, including Klickl International Limited in ADGM/UAE and several product domains such as KlicklX, KlicklONE, Klickl Pay, Klickl Custody and the exchange-facing Klickl environment. SEC and C1 Fund materials connect Michael (Xu) Zhao to Klickl, Inc., IDCM, VGPay, Crypto 1 Acquisition Corp, C1 Fund, and Hong Kong blockchain networks.
Klickl’s Role in Scam Schemes – Working Hypotheses
- Working Hypothesis 1 — EU Rail Node: Klickl Europe was used as the EU-facing rail for victim funds collected through OpenPayd vIBANs from German-speaking and other European victims.
- Working Hypothesis 2 — On-Ramp / Settlement Layer: Klickl Europe acted as a crypto on-ramp, settlement intermediary, or account layer for operators behind KXTRA, fake Peel Hunt / Peelhuntaicore, and possibly other scam frontends.
- Working Hypothesis 3 — Broader Network Link: The Polish entity was not acting in isolation but as part of a broader Klickl/Zhao ecosystem spanning Poland, ADGM/UAE, Hong Kong-linked crypto networks, and U.S.-linked capital-market vehicles.
- Working Hypothesis 4 — Control And Knowledge: If Klickl Europe received and controlled the victim funds, the broader Klickl control structure — including Michael/Xu Zhao and the publicly listed management and compliance personnel — should be able to identify the downstream customers, wallets, exchanges, OTC desks, and settlement partners.
These hypotheses are not final criminal findings. They are the logical investigative direction created by the documents.
FinTelegram Position
FinTelegram’s position is that Klickl Europe must not be viewed in isolation. The Polish VASP is the entity appearing in the OpenPayd victim files, but it sits inside a broader international Klickl/Zhao crypto-finance network.
The structure looks like this:
EU market access: Klickl Europe Sp. z o.o. / Poland / RD WWW-930
Payment rail: OpenPayd Malta vIBANs / CFTEMTM1
Victim source: German-speaking and European retail investors
Scam frontends: KXTRA, fake Peel Hunt / Peelhuntaicore, possibly others
Crypto layer: Klickl on-ramp / settlement / exchange or wallet infrastructure
Global network layer: Michael/Xu Zhao, Klickl, Inc., IDCM, VGPay, Crypto 1 Acquisition Corp, C1 Fund, ADGM/UAE and Hong Kong-linked structures
That is the real compliance and law-enforcement issue: a global crypto-finance network appears to have used a Polish VASP as its EU rail node, while OpenPayd provided the vIBAN infrastructure through which victim funds were collected and swept.
If Klickl Europe was merely abused, the broader Klickl group should prove it by disclosing the downstream trail.
If the group cannot explain where the money went, regulators should treat the Polish entity not as a standalone Polish VASP problem, but as the EU-facing node of a cross-border crypto-payment network exposed to suspected fraud flows.
Whistleblower Call
FinTelegram asks victims, Klickl insiders, OpenPayd staff, exchange employees, compliance officers, wallet-tracing firms and law-enforcement sources to contact Whistle42.
We need: Klickl onboarding files, OpenPayd/Klickl contracts, wallet addresses, exchange accounts, transaction hashes, SAR/STR records, compliance emails, screenshots from KXTRA or Peelhuntaicore, Klickl platform records, and any information on Xu Zhao, Michael (Xu) Zhao, Ben Huang, Sanne Ke, Dermot Mayes, Alihan Ekesan, IDCM, VGPay, Crypto 1, or C1 Fund.
