An In-Depth Guide for Ventus Investors on What to Do Next

On June 11, Ventus announced it would seek court-supervised restructuring in Estonia. A repayment plan is due by July 10. After that, a creditor vote.

As of late June, three independent Estonian law firms confirmed that no restructuring petition has been filed with any Estonian court and nothing appears in the Ametlikud Teadaanded (the official gazette). Ventus told investors on June 16 it would file within roughly two weeks. That deadline is passing. Until a court accepts a petition, there is no moratorium and no one watching the board.

Source: https://www.ametlikudteadaanded.ee/

A lot of investors are waiting. See what the plan says. See how the vote goes.

Crowdestor investors waited (except for this guy). Same founder. Same structure. Same office. Nobody filed on unlicensed activity. The subsidiaries dissolved one by one. EUR 41.2 million has not come back.

Source: https://www.karsten.me/money/ventus-energy-investigation/ (Crowdestor outstanding portfolio)

This time there are things investors can do before the vote.

The vote

If the restructuring is formally opened, the company has 60 days to submit a plan. Then creditors vote. Approval requires creditors holding at least two-thirds of the total claim value to vote yes. Not voting works against the plan: the required majorities are measured against all creditors, not just those who show up. The plan fails unless a supermajority actively votes in favour.

Source: https://insol-europe.org/download/documents/1341

There is a separate deadline that matters more than it looks. Once the court accepts the petition and appoints a restructuring adviser, that adviser sends each creditor a formal notice listing the claim amount attributed to them. This is not the June 11 email from Ventus. It has not been sent yet. Within two to four weeks of receiving it, each creditor must file a written objection if they disagree with the stated amount. Miss that window and the law treats your silence as agreement with whatever Ventus put on the list.

Source: https://www.riigiteataja.ee/en/eli/ee/510072014027/consolide/current (Saneerimisseadus §§12-13)

Out of 153 restructuring cases opened in Estonia between 2008 and 2011, twenty resulted in an approved plan. Thirteen percent. Most of the rest never reached a creditor vote. The debtor withdrew, the court refused to approve the plan, the 60-day deadline passed without a submission, or the proceedings converted to bankruptcy.

Source: https://insol-europe.org/download/documents/1341

Accept or reject

Accept the plan and the board that built this structure stays in charge. A court-appointed restructuring adviser will supervise them. That adviser cannot manage the company, cannot deny payments, and cannot replace the board. The company’s management decides what to disclose, what to sell, and at what price. The adviser is not a bankruptcy trustee. Their role is to supervise and assess the restructuring, not to conduct a backward-looking asset-recovery investigation. Whether the board overpaid itself in consulting fees, whether asset purchases were priced at five times fair value, whether funds were moved between related entities before the restructuring opened: none of that is in the adviser’s mandate. Past conduct stays uninvestigated for as long as the restructuring holds.

Source: https://insol-europe.org/download/documents/1341

Reject the plan and the restructuring fails. In bankruptcy, an independent court-appointed trustee takes over. That trustee can look backwards. Under Estonian bankruptcy law, the trustee can recover assets transferred at a loss to the company. For transactions involving connected persons, the lookback window is up to five years.

Sources: https://www.riigiteataja.ee/en/eli/ee/510072014027/consolide/current; https://insol-europe.org/download/documents/1341

The question for each creditor is whether the plan offers transparent disclosure of where the money went and a credible path to repayment. If it does not, insolvency proceedings put someone in charge who has the authority and the mandate to find out.

Consider what you already know. In the year-in-review PDF, Ventus valued its own assets at EUR 193 million. On the lender Zoom call on June 16, that number became a much less confident “more than 100 million euros.” This reminds me of the audit that became an opinion. It’ll be interesting how much further this number will shrink when a truly independent party looks at it.

Source: https://youtu.be/Fh7zkVxNut0 (at 27:39)

What you can do, sorted by what it costs

Three options. They are not mutually exclusive.

1. File a criminal complaint for unlicensed financial activity. Free. Twenty minutes. The key facts and starting prompts are in this article. This puts the alleged underlying licensing offence on the record regardless of what happens in the restructuring.
2. Send a formal demand letter (Anforderungsschreiben) with a repayment deadline. Free. You send it yourself or have a lawyer send it. Address it to Ventus Energy Group OÜ demanding repayment of your loan by a specific date (typically 14 days). This documents your demand and may establish default (Verzug) for interest, costs, and later civil claims. If your lawyer advises it, send separate demands to relevant individuals or related entities where you intend to pursue personal liability. Keep proof of delivery.
3. Retain a lawyer for asset-seizure proceedings (Arrest). German lawyers representing Ventus investors have filed Arrest applications and German courts have accepted jurisdiction (Kanzlei Oelschig, which represents a group of affected investors, confirmed an Arrest application filed at LG Würzburg). Arrest is a precautionary asset-securing measure under ZPO sections 916-934, distinct from enforcement of a claim.

The criminal complaint (free)

Not fraud. Fraud didn’t work for Crowdestor. The police said investment risk, not deception, and EUR 41.2 million in losses went unanswered. Proving someone lied to you is hard.

Unlicensed financial activity is a different charge. It starts with two facts: the activity required authorisation, and Ventus did not have it. Two regulators have already put that licensing problem on the public record. That is the complaint you file first. Fraud can come later, and it lands differently when there is already an open criminal case.

The charge

As of May 2026, Ventus owed more than EUR 94 million to over 6,000 retail investors, on plain loan agreements with interest rates from 16 to 19.2 percent, while registered in Estonia as a “web portal” with 4,166 euros of capital, no filed accounts, and zero employees. Taking repayable money from the public like that is a licensed activity. Banking licence, crowdfunding licence, pick one. Ventus picked neither.

Sources: https://ventus.energy/en/statistics; https://ariregister.rik.ee/eng/company/16964065/Ventus-Energy-Group-O%C3%9C

Operating in a licence-required field without the required licence is criminalised in the jurisdictions most relevant here:

• Estonia: Penal Code section 372. Up to three years. (Source: https://www.riigiteataja.ee/en/eli/ee/506032020002/consolide/current)
• Latvia: Criminal Law section 207(2). Up to three years. (Source: https://likumi.lv/ta/en/en/id/88966-the-criminal-law)
• Lithuania: Criminal Code article 202. Up to four years. (Source: https://e-seimas.lrs.lt/portal/legalActPrint/lt?jfwid=rivwzvpvg&documentId=a84fa232877611e5bca4ce385a9b7048&category=TAD)
• Germany: KWG section 54. Up to five years. This is the heaviest penalty of the four. German prosecutors are required to investigate where sufficient initial suspicion exists (Legalitätsprinzip), and Bafin’s published enforcement order is strong evidence of that suspicion. (Source: https://www.gesetze-im-internet.de/kredwg/__54.html)

Germany’s Bafin ordered Ventus on 5 May 2026 to stop unauthorised deposit-taking and repay lenders. Latvijas Banka named Ventus Energy Group OÜ among 15 companies operating without the required licence. The core licensing facts are on the public record. The regulators have done the part individual investors could not do alone.

Sources: https://www.bafin.de/SharedDocs/Veroeffentlichungen/EN/Verbrauchermitteilung/unerlaubte/2026/meldung_2026_05_18_ventus_energy_group_en.html; https://www.bank.lv/en/news-and-events/news-and-articles/news/17379-on-the-operation-of-companies-that-have-failed-to-obtain-an-appropriate-licence-or-authorisation-for-the-provision-of-investment-services

Why this charge first

Because the facts are already on the record. Two regulators have said Ventus lacked the required authorisation. You are not asking the police to start from zero. You are handing them a file where the core licensing facts are already public.

Fraud requires proving deception, intent, reliance. Those are real questions, and the police can reasonably push back. Unlicensed activity requires two facts that are already public. File the easy one first. Once criminal proceedings exist, prosecutors can trace fund flows, subpoena documents, and investigate whether the valuations were real. The fraud complaint has somewhere to land.

The fraud evidence

The unlicensed-activity charge is the one you file first because it requires the fewest facts. But the fraud evidence is already public, and your complaint is stronger if you include it. Below I cite German law and reference projects I looked at during my investigation. If you file elsewhere the statute numbers differ, but the same principles apply. Further down there are sections on what to communicate to authorities in Lithuania, Latvia, and Estonia.

The edited PDF. Ventus published a property valuation for its office at Vīlandes iela 6-6 in Rīga. In the PDF, “Crowdestor” had been pasted over with “Ventus Energy OU.” The edit history is still in the file metadata. Someone opened the document, altered it, and uploaded it to the fundraising platform. Under §269 StGB, prosecutors do not need to wait for an investor to prove reliance if the altered data was created or used as legally relevant evidence. That is why the PDF matters independently of the investment losses. Under §264a StGB, presenting someone else’s property valuation as your own asset in materials directed at thousands of investors is a false advantageous statement in connection with capital investments, to the extent prosecutors treat Ventus’s loans as a qualifying capital investment under the section.

Source: https://www.karsten.me/money/ventus-energy-investigation/

The stale valuation. The Dambis biomass plant, operated by SIA Eco Energy Riga, was valued at EUR 12 million in a 2022 appraisal by Interbaltija. That valuation included a three-year discounted cash flow projection. By the time Ventus raised funds in late 2024, the plant’s actual revenue was less than half of what the valuation had forecast for that year. The valuation was never updated. Ventus had access to the company’s actual performance because it owned the company, yet continued presenting the 2022 figure as the asset’s value to investors. Presenting an outdated valuation as current when the underlying performance has fallen below the valuation’s own projections is either a false advantageous statement or a concealment of disadvantageous facts. Both fall within §264a’s target zone if the loans qualify as a capital investment under the section. For §263, this was part of the materials that induced the original investment decision. Investors who reviewed Ventus’s asset portfolio saw those numbers.

Sources: SIA Interbaltija valuation of the Ganību dambis 40B biomass plant, as of 31 December 2022 (on file); SIA Eco Energy Riga 2024 annual report, filed with the Latvian Register of Enterprises.

The May 13 email. Ventus received Bafin’s cease-and-desist order on May 12. CEO Henrijs Jansons has confirmed this date. On May 13, Ventus emailed all lenders about “constructive dialogue with relevant regulatory stakeholders in Germany” without mentioning the order. Investors who deposited money between May 13 and May 25 (when Paysera froze outgoing payments) did so relying on that same email. That is a separate fact pattern prosecutors should examine under §263 StGB, especially for investors who deposited money after the May 13 email.

Include all three in your complaint. Every Ventus loan is an unconditional loan to Ventus Energy Group OÜ, not to a specific project. The edited PDF, the stale valuation, the May 13 email: these were platform-level representations that affected every lender’s decision, regardless of which project you invested in. The unlicensed-activity charge requires two facts already on the public record. The fraud evidence requires more, but it is also public, and it gives prosecutors a reason to look at fund flows, valuations, and who signed off on them.

What happened when nobody filed

Ventus founder Jānis Timma previously ran Crowdestor. Same office at Vīlandes iela 6-6 in Rīga. Same structure: Estonian shell, no licence, no filed accounts. Crowdestor collected EUR 41.2 million from around 2,700 investors. Criminal complaints targeted fraud and failed on the deception element. Nobody filed on unlicensed activity.

Source: https://www.karsten.me/money/ventus-energy-investigation/ (Crowdestor outstanding portfolio)

The Latvian loan portfolio sat inside a fan of numbered subsidiaries, all controlled through a single holding company by an insider. Starting in mid-2024, those subsidiaries began entering insolvency or liquidation one by one. Several have been dissolved. The person who controls the holding company also appears in the commercial register as liquidator for at least one of them. The parent entity remains registered in Estonia, one hundred percent owned by Timma. The subsidiaries dissolve. The parent survives. The EUR 41.2 million has not come back.

Sources: https://www.karsten.me/money/ventus-energy-investigation/; https://ariregister.rik.ee/eng/company/14388462/CROWDESTOR-O%C3%9C

Nobody triggered formal bankruptcy proceedings against the parent. No trustee was ever appointed. Under Estonian bankruptcy law, a trustee can claw back connected-person transactions up to five years. But the clock runs from appointment, not from the transaction. Crowdestor operated from 2018. The original fund flows, the related-party structures, the self-dealing: most of it would fall outside the lookback periods. But the window has not opened yet. A trustee appointed today could still reach transactions from 2021 onward under the five-year period, and anything from 2023 onward under the shorter ones.

Source: https://www.riigiteataja.ee/en/eli/ee/523032023003/consolide (Pankrotiseadus §110)

Why your filing matters more than mine

I wrote the Ventus investigation. But I did not lend Ventus any money, and in some jurisdictions, like Latvia, that matters. The right to appeal if the police decline to act belongs to people who actually lost money. Under Latvian criminal procedure, a person who suffered from the offence can challenge a refusal to open proceedings. Someone who did not suffer cannot.

Source: https://likumi.lv/ta/en/en/id/107820-criminal-procedure-law

The German Arrest

This is the most aggressive option and requires a lawyer. German Arrest proceedings (Arrestverfahren) are a precautionary measure under ZPO sections 916-934: a court orders the seizure or freezing of a debtor’s assets to prevent them from being moved or hidden before a judgment is entered.

Source: https://www.gesetze-im-internet.de/zpo/__916.html

Marcel Seifert of BRÜLLMANN Rechtsanwälte has publicly recommended that Ventus investors pursue Arrest to secure the company’s assets before they can be moved. Stephan Greger of Dr. Greger & Collegen has written specifically about Arrest as a remedy for Ventus investors and confirms that German courts can assert international jurisdiction over the Estonian platform under the Brussels Ia Regulation.

Sources: https://bruellmann.de/ventus-energy-group-situation-spitzt-sich-fuer-anleger-zu; https://www.anwalt.de/rechtstipps/ventus-energy-bafin-greift-ein-welche-rechte-haben-anleger-jetzt-273169.html

Whether the Estonian restructuring moratorium blocks German Arrest applications is a question neither firm has addressed. Both recommend Arrest as a remedy; neither discusses what happens to it once a moratorium is in place. The moratorium stays enforcement of claims against the debtor. Arrest is dogmatically a security measure, not enforcement: it prevents asset dissipation but does not realize the assets. Under German insolvency law, even Arrest is blocked once proceedings open. Whether an Estonian restructuring moratorium has the same effect in a German court is an open question. Worth understanding before you spend money on it.

Sources: https://www.gesetze-im-internet.de/zpo/__916.html; https://www.riigiteataja.ee/en/eli/ee/510072014027/consolide/current

The cost is not only the lawyer. A court can require you to post security before it grants an Arrest, and under ZPO section 945 anyone who obtains an Arrest that is later found unjustified from the start is liable, with no showing of fault, for the damage the freeze caused the debtor. Get that risk priced in with counsel before filing.

Source: https://www.gesetze-im-internet.de/zpo/__945.html

If the vote protects Ventus

If the restructuring vote passes, Ventus’s assets sit inside a court-supervised shield. The influencers who promoted this platform do not. Seven of them hold equity in Ventus through a dedicated stock-option vehicle. Several did not disclose this while recommending the platform to their audiences. They earned affiliate commissions directing retail investors to an operator that Bafin has found to be conducting unauthorized deposit-taking.

Source: https://ariregister.rik.ee/eng/company/17067652

The equity matters beyond optics. Influencers who hold shares in the company they promoted are not arm’s-length affiliates collecting a referral fee. Their equity stake created a conflict of interest that ordinary investors were entitled to know about. Whether it also gave them access to non-public information is a question for investigators and for disclosure or evidence-gathering in later proceedings. Promoting the platform to their audiences while holding undisclosed equity, if they knew or should have known that the platform lacked the required authorisation, while earning commissions on each investor they recruited: that is a different legal position than someone who ran a banner ad. Their shares in the stock-option vehicle are personal assets outside any restructuring shield.

Bafin has stated it can act against anyone involved in marketing products of unlicensed companies under KWG section 37. The legal framework for holding promoters liable exists. It has been used in other jurisdictions: in the UK, influencers were convicted in 2026 for promoting unauthorized financial products under a strict-liability standard that required no proof of fraud or intent.

Sources: https://www.bafin.de/SharedDocs/Veroeffentlichungen/DE/Merkblatt/mb_finfluencer.html; https://www.fca.org.uk/news/press-releases/seven-individuals-plead-guilty-illegal-financial-promotions

If Ventus assets become unreachable through restructuring, lawyers representing investors will look for assets outside that shield. Influencer assets will not cover EUR 94 million in claims. But some of these influencers have six- and seven-figure earnings from their platforms, and depending on what prosecutors establish, the affiliate commissions they earned may become relevant as proceeds or benefits connected to the alleged offence. Criminal complaints and civil claims against promoters remain available regardless of what happens to Ventus.

The evidence trail exists. Circlewise, the affiliate network that processed all Ventus influencer commissions, terminated its Ventus partnerships on June 12, 2026. But it should have records showing which influencers received commissions, how much, when, and for directing how many investors. Those records may be relevant to criminal proceedings, including any investigation of whether the commissions were proceeds or benefits connected to an alleged offence, and to civil claims against individual influencers. Prosecutors can subpoena them. Investors’ lawyers can seek disclosure through the procedural tools available in the relevant civil proceedings.

The influencers are German-speaking, mostly German nationals, and ran their promotions in German. Some live abroad, but their audiences, assets, and business ties are predominantly German. German courts have clear jurisdiction over German-based promoters; for the Spanish-based influencers the same principles likely apply in Spain. Two German firms have published articles about Ventus: Dr. Greger & Collegen (Munich, Fachanwalt für Bank- und Kapitalmarktrecht) and BRÜLLMANN Rechtsanwälte (Stuttgart, EUR 149 flat initial assessment, won a subordinated-loan (Nachrangdarlehen) investor claim at LG Hanau, Az. 1 O 418/25). This is the scenario where a German Kapitalmarktrecht lawyer is useful. For the criminal complaints against Ventus itself, you do not need a lawyer. For civil recovery from Ventus in the Baltics, a local lawyer in the relevant jurisdiction might be more practical. More than 400 Spanish investors are organizing in the Afectados VENTUS ENERGY Telegram group to plot that path.

How to draft your criminal complaint

Filing a criminal complaint is not something most people do on a Tuesday. But you are working with the backing of national regulators who already issued public statements.

No lawyer needed. Your complaint, an email address, and for Baltic filings a qualified electronic signature. German filers do not need one. For the complaint, take the key facts below, paste them into an AI assistant along with the prompt for your country, and have it draft a complaint tailored to your situation. Review it, add your personal details, export to PDF, sign if required, send.

If you do not have access to a paid AI assistant, use a free version of ChatGPT, Gemini, Claude, or another tool, or draft the complaint manually from the checklist below. The tool is not the important part. The important part is that you review every factual statement before signing and remove anything you cannot personally verify.

1. File in every country you can. Your home country. Latvia (the regulator already named Ventus). Lithuania if your money went to a Paysera account (check your bank transfer records; if the receiving IBAN starts with LT, your money went through Lithuania). Estonia (the company is registered there; the online portal requires an Estonian or Baltic eID, but a QES-signed email to [email protected] is accepted). German investors should file domestically too: §54 KWG carries the heaviest penalty and Bafin has already established the facts. Spanish investors: see the dedicated section below. Each filing is independent.
2. Paste the prompt for that country into your AI assistant, along with the key facts and your personal details.
3. Review the output. Make sure every factual claim is true as it applies to your situation. AI tools also invent or misstate legal citations, so check that every statute and section number matches the ones in your country’s prompt and the official-source links in this guide. Correct or remove any citation the draft added on its own, and verify the prompt-supplied statutes against the official-source links for your country, keeping only the ones that check out. Remove anything you are not comfortable signing. A quick shortcut: paste the output of one AI into a different one (e.g. GPT draft into Claude or Gemini) and ask it to check the facts and citations. In my experience this catches most of the invented stuff.
4. Export to PDF. Most AI tools can output PDF directly. If yours doesn’t, print-to-PDF or use LibreOffice (File, Export as PDF, check PDF/A for archival format). A plain PDF is fine too.
5. Sign it (Baltic filings only). German filers do not need a signature: a Strafanzeige can be filed unsigned via Onlinewache or as a plain letter to the Staatsanwaltschaft. For Baltic filings you need a qualified electronic signature; see “How to sign your complaint” below for providers and cost.
6. Email it to the address in the prompt.

Key entities and people to identify

Identify the company and the individuals who appear from public records to have controlled, managed, or operated the relevant activities. Prosecutors can then determine each person’s role and responsibility.

• Ventus Energy Group OÜ (Estonian reg. 16964065), the platform entity, registered in Tallinn.
• Jānis Timma, majority owner (65%) and controlling shareholder. Also sole owner of Crowdestor OÜ.
• Henrijs Jansons, CEO and board member of Ventus Energy Group OÜ.
• Toms Ābele, CMO of Ventus and CEO of SIA White Label Solution (reg. 40203629203), the Ventus marketing and operations vehicle.

Where to send it

Latvia
Send to: [email protected] (cc [email protected])
Subject: Iesniegums par noziedzīgu nodarījumu — Krimināllikums 207. pants — Ventus Energy Group OÜ, 16964065

Estonia
Send to: politsei.ee/en/report-to-police (signed online) or [email protected]
Subject: Kuriteateade — KarS §372 — Ventus Energy Group OÜ, 16964065

Estonia note: the politsei.ee portal requires logging in with an Estonian or Baltic eID (ID-card, Mobile-ID, or Smart-ID), which most non-residents do not have. If you cannot use the portal, email a QES-signed PDF to [email protected]. An unsigned report tends to be recorded “for information” only; a qualified-signed complaint is a proper digitally signed avaldus and is harder to set aside. If the police point you back to the portal, respond that it does not let non-resident victims file and ask them to process your signed email submission.

Lithuania
Send to: [email protected] (cc [email protected])
Subject: Pranešimas dėl galimos nusikalstamos veikos — Ventus Energy Group OÜ

Germany
Send to: Your local Staatsanwaltschaft (Schwerpunkt Wirtschaftskriminalität), or online via Onlinewache
Subject: Strafanzeige — unerlaubte Bankgeschäfte (§54 KWG) / Kapitalanlagebetrug (§264a StGB) — Ventus Energy Group OÜ

Spain
Send to: CNMV whistleblowing: cnmv.es/portal/whistleblowing + Fiscalía Provincial (denuncia)
Subject: Comunicación de infracción: actividad financiera sin autorización — Ventus Energy Group OÜ (16964065)

How to sign your complaint

The three Baltic filings require a signed submission (a German Strafanzeige and a Spanish denuncia do not). Anonymous reports do not give you victim standing or appeal rights, and in practice they are not acted on. The signature must be a qualified electronic signature (QES) under eIDAS, the highest-assurance e-signature, legally equivalent to a handwritten signature, proving you are who you say you are. One from any EU country is valid in all three.

You are…	Use	Cost
A resident of Latvia, Lithuania, or Estonia	Smart-ID (qualified) or your national eID / Mobile-ID / eParaksts, via Dokobit	Free
A resident of Germany	D-Trust sign-me (QES) at cloud.sign-me.de	First 2 signatures free (eID verification); about EUR 17 via VideoIdent
Any other EU resident	Your national eID or any qualified e-signature provider	Varies

If you are in Germany and have a Personalausweis with the online function activated: go to cloud.sign-me.de, register, choose eID (AusweisIDent), hold your ID card to your phone with the AusweisApp, enter your 6-digit PIN. Registration gives you 10 free coins; each qualified signature costs 5 coins. Upload your PDF, select QES, confirm, download the signed file. If the eID online function is active, the two signatures are free; if your PIN is not set up, sign-me falls back to VideoIdent at about EUR 17. Ten coins cover two signatures, enough for the Latvia and Estonia filings. If your Paysera IBAN also puts you in Lithuania, that third Baltic filing needs a coin top-up (5 coins per signature) or another EU qualified-signature provider.

Key facts for your complaint

Copy these into your AI prompt alongside your personal details. Every fact below is sourced to a public record.

• Ventus Energy Group OÜ (Estonian registration 16964065) operated the platform ventus.energy, soliciting and accepting repayable funds from the public under loan agreements.
• Interest rates ranged from 16 to 19.2 percent, with additional bonus rates for investments above EUR 100,000 and cashback through affiliate programmes.
• The company is registered under a “web portal” activity code (EMTAK 63121) with EUR 4,166 in share capital, no filed annual accounts, and zero employees.
• As of May 2026, Ventus owed more than EUR 94 million to over 6,000 retail investors.
• Germany’s Bafin ordered Ventus on 5 May 2026 to cease unauthorised deposit-taking and repay lenders (case reference HGS-QB 9100/01014#01777).
• Latvijas Banka listed Ventus Energy Group OÜ among entities operating without the required licence or authorisation for investment services.
• The activity required authorisation as a credit institution and/or a crowdfunding service provider (Regulation (EU) 2020/1503). Ventus held neither.
• Identify the company and the individuals from the “Key entities and people” section above, and ask prosecutors to determine each person’s role and responsibility.
• Ventus published a property valuation for Vīlandes iela 6-6, Rīga on its platform in which “Crowdestor” had been pasted over with “Ventus Energy OU.” The edit history is still in the PDF metadata. Prosecutors may assess this as document forgery or falsification of evidentiary data (§269 StGB / KarS §§344-345).
• The Dambis biomass plant (operated by SIA Eco Energy Riga) was acquired with investor funds based on a 2022 asset valuation (EUR 12 million, Interbaltija) that included a three-year DCF forecast. By 2024, actual revenue was less than half of what the valuation had projected for that year. The valuation was never updated. Ventus continued presenting the 2022 figure to investors through late 2024.
• On May 12, 2026, Ventus received Bafin’s cease-and-desist order. On May 13, it emailed all lenders citing “constructive dialogue with relevant regulatory stakeholders in Germany” without disclosing the order. Investors who deposited between May 13 and the Paysera freeze on May 25 did so relying on that same email.

Your personal details to add

• Your full name, address, email, and contact phone number.
• The dates and amounts of your investments through ventus.energy.
• The amount you have not been repaid or that is frozen.
• Whether your transfers went to a Paysera/Lithuanian IBAN (relevant for the Lithuania filing).
• Attach: your loan agreements with Ventus (download from your ventus.energy account if still accessible), bank transfer records showing the money leaving your account, screenshots of your Ventus dashboard showing outstanding balances, and any communication from Ventus about non-payment, frozen funds, or the restructuring.

Prompt: Latvia (State Police, Criminal Law §207)

You file as a person who suffered from the offence. That gives you the right to appeal if the police refuse to open proceedings. That right is what makes your filing harder to dismiss than mine.

Draft a formal criminal complaint in English (with a note that a Latvian translation will follow) addressed to the State Police of the Republic of Latvia (Valsts policija, [email protected]), with CC to [email protected] (Prosecutor General’s Office).

The complaint reports a violation of Criminal Law Section 207(2): entrepreneurial activity in a field requiring a licence, carried on without that licence, on a significant scale and causing substantial harm.

I am filing as a victim (cietusais). Include the following arguments:

• State my personal details and the amount of my loss.
• The activity (accepting repayable funds from the public under loan agreements) required a licence. Ventus held no credit-institution or crowdfunding licence.
• Two national regulators have confirmed this: Latvijas Banka placed Ventus on its public list of unlicensed entities; Bafin issued an enforcement order for unauthorised deposit-taking.
• The scale is significant (tens of millions of euros from thousands of retail investors) and my harm is substantial. Both prongs of §207(2) are met.
• Ask the police to register and examine this under CPL §§370-371 and to initiate criminal proceedings.
• As a victim, ask to be recognised as cietusais and notified of any decision. I reserve the right to appeal under §373(5).

Use a formal tone suitable for a police submission. End with a list of annexes: investment records, account screenshots, and any non-payment communication. Include a signature line for a qualified electronic signature.

[Paste the key facts and your personal details here.]

Prompt: Estonia (PPA, Penal Code §372)

Frame this as unlicensed activity, not fraud. The deception route failed twice in Estonia already. This prompt targets §372, which needs no deception element.

Draft a formal criminal report addressed to the Police and Border Guard Board of Estonia (Politsei- ja Piirivalveamet, [email protected]), reporting unlicensed economic activity in the field of financial services under Penal Code §372(2).

This is NOT a fraud complaint. Emphasise early in the document that no deception element is needed: the objective facts are that a licence-required activity was carried on without a licence. Include these arguments:

• State my personal details and loss amount.
• The unlicensed activity: Ventus solicited repayable funds from the public under loan agreements while registered only as a “web portal” with no financial services licence.
• Regulators confirm this: Bafin ordered Ventus to cease unauthorised deposit-taking. Latvijas Banka listed it as lacking the required authorisation. Finantsinspektsioon has stated that unlicensed operation in a licence-mandatory field is a criminal matter for investigative bodies.
• Jurisdiction: Ventus is an Estonian-registered legal person. The offence has Estonian situs.
• Ask for proceedings under §372(2) for the natural persons and §372(4) for the legal person.

Use a formal tone suitable for a police submission. The report must be digitally signed. End with annexes. Include a signature line.

[Paste the key facts and your personal details here.]

Prompt: Lithuania (FNTT, factual report)

Lithuanian prosecutors prefer that you state the facts and let the investigator pick the charge. Do not cite specific Criminal Code articles. Your Lithuanian nexus is that Ventus collected investor funds through a Paysera LT account. If possible, ask the AI to also produce a Lithuanian translation; a careful machine translation avoids a clarification round-trip.

Draft a factual report addressed to Lithuania’s Financial Crime Investigation Service (FNTT, [email protected]), with CC to [email protected] (Prosecutor General’s Office). The report concerns unlicensed financial activity by Ventus Energy Group OÜ, which collected investor funds through a Lithuanian Paysera account.

Do NOT cite specific Lithuanian Criminal Code articles. State the facts and let the investigator decide the charge. Include:

• My personal details and loss amount.
• The factual circumstances: Ventus solicited repayable funds under loan agreements, collected through a Lithuanian Paysera (Paysera LT, UAB) IBAN, while holding no credit-institution or crowdfunding licence.
• The Lithuanian nexus: funds flowed through a Lithuanian payment institution.
• Regulatory findings: Bafin enforcement order, Latvijas Banka warning list.
• Ask the FNTT to register and examine this information.

Use a formal tone. The report should be digitally signed and ideally submitted in Lithuanian. End with annexes including any evidence showing the Paysera/LT IBAN. Include a signature line.

[Paste the key facts and your personal details here.]

Prompt: Germany (Staatsanwaltschaft, §54 KWG / §264a StGB)

German investors have three charges to work with. KWG section 54 criminalises operating without a Bafin licence: up to five years, and Bafin has already made the finding. Section 264a StGB covers false or misleading statements in connection with capital investments, and does not require proof that you actually lost money. Section 263 StGB is standard fraud, which requires proof of deception and actual loss but carries up to ten years for commercial-scale cases. File on all three and let the Staatsanwaltschaft sort out which ones stick.

Sources: https://www.gesetze-im-internet.de/kredwg/__54.html; https://www.gesetze-im-internet.de/stgb/__264a.html; https://www.gesetze-im-internet.de/stgb/__263.html

File in writing, directly with the Staatsanwaltschaft. Every German state has specialised prosecution offices for economic crime (Schwerpunktstaatsanwaltschaften für Wirtschaftskriminalität). A written complaint to the relevant office carries more weight than an online form. If you prefer online: the Onlinewache portal at portal.onlinewache.polizei.de routes to your state. You can also file directly with the Zentralstelle Cybercrime Bayern (ZCB) in Bamberg at [email protected], which specialises in internet-based investment fraud. ZCB’s prosecutorial jurisdiction is Bavaria, but any Strafanzeige sent to any German Staatsanwaltschaft is forwarded to the competent one if it lands in the wrong place. For an internet platform that targeted investors across all of Germany, there is nothing wrong with filing where the specialists sit.

Sources: https://portal.onlinewache.polizei.de/de/; https://www.justiz.bayern.de/gerichte-und-behoerden/generalstaatsanwaltschaft/bamberg/spezial_1.php

German law gives investors a formal escalation route if the Staatsanwaltschaft dismisses the complaint. First to the Generalstaatsanwalt (Beschwerde, §172(1) StPO). If that fails, to the Oberlandesgericht (Klageerzwingungsverfahren, §172(2) StPO). The mandatory prosecution principle (Legalitätsprinzip) means the Staatsanwaltschaft cannot simply decide not to investigate when initial suspicion exists. Bafin’s enforcement order is strong evidence of that initial suspicion.

Source: https://www.gesetze-im-internet.de/stpo/__172.html

Draft a formal criminal complaint (Strafanzeige) in German, addressed to the Staatsanwaltschaft [your city] (Schwerpunkt Wirtschaftskriminalität). Alternatively, address it to: Zentralstelle Cybercrime Bayern, Generalstaatsanwaltschaft Bamberg, [email protected].

The complaint reports violations of:

• §54 KWG (unerlaubte Bankgeschäfte): operating a deposit-taking business without the required Bafin authorisation under §32(1) KWG.
• §264a StGB (Kapitalanlagebetrug): making false advantageous statements and concealing disadvantageous facts in representations directed at a large number of investors.
• §263 StGB (Betrug): obtaining money through deception, commercial scale (gewerbsmäßig), causing substantial loss to a large number of victims.

Include:

• My personal details, investment amount, and loss.
• Bafin’s enforcement order of 5 May 2026 (reference HGS-QB 9100/01014#01777) ordering Ventus to cease unauthorised deposit-taking. This provides Anfangsverdacht for §54 KWG.
• Latvijas Banka’s warning listing Ventus as operating without authorisation.
• The factual circumstances: Ventus solicited repayable funds from German retail investors under loan agreements at 16-19.2% interest, while registered in Estonia as a “web portal” with EUR 4,166 capital, no financial licence, and no filed accounts.
• State that the German Legalitätsprinzip (§152(2) StPO) requires the Staatsanwaltschaft to investigate when Anfangsverdacht exists, and Bafin’s published order establishes that suspicion.
• Ask for the complaint to be registered and for the complainant to be informed of any decision.

Use formal legal German. End with a list of annexes (investment records, Bafin order, Latvijas Banka warning, account screenshots, transfer records). Include a signature line.

[Paste the key facts and your personal details here.]

For Spanish investors: CNMV was notified

CNMV was notified about Ventus twice. On December 2, 2025, I emailed their communications desk ([email protected]) a detailed report: unlicensed platform, no ECSP authorisation, actively targeting Spanish retail investors. Isabel Selas Badía at the Dirección de Comunicación replied the same day with a template directing me to use their webform. On May 21, 2026, I followed up with the Bafin enforcement order attached. The Dirección de Comunicación sent the same template.

Between May 5 (Bafin order) and May 25 (Paysera freeze), German investors at least had a regulator issue a public cease-and-desist and repayment order. Spanish investors did not. CNMV had enough information to examine whether one was warranted. Both emails are on file and have been shared with the Spanish investor group.

Spanish investors are now under pressure to get their regulator to act. Bafin’s order explicitly requires Ventus to repay German lenders. If repayment resources are limited, regulatory timing may matter. Every week without a CNMV intervention risks leaving Spanish investors with less leverage.

What to do:

1. File with CNMV through the whistleblowing channel. Not the general complaints form. CNMV’s own template reply points to their canal de comunicación de infracciones. Use it. Report Ventus as an entity providing financial services without authorisation under Ley 6/2023 de los Mercados de Valores. Reference the Bafin order and the Latvijas Banka warning. Attach your investment records.
2. Ask CNMV why they did not act on the December 2025 notification. Your regulator received a sourced report about an unlicensed platform targeting Spanish investors six months before it collapsed. The question is not whether they received it. They replied. The question is why they did nothing with it.
3. File a denuncia with your Fiscalía Provincial for estafa (artículos 248-251 del Código Penal). The criminal route in Spain runs through the Fiscalía, not through CNMV. In Spain, unlicensed financial activity is handled administratively through CNMV rather than as a standalone crime, so that angle is the complaint above and the criminal denuncia is estafa.

Sources: https://www.cnmv.es/portal/whistleblowing/presentacion.aspx?lang=es; https://www.boe.es/buscar/act.php?id=BOE-A-2023-7053 (Ley 6/2023)

A group of more than 200 Spanish investors is already filing collectively with CNMV. If you are a Spanish investor and not part of that group, file individually anyway. Your own filing gives you standing in your own right.

If someone sold you into this

On Crowdestor, a related platform run by the same people, there are documented cases of individuals recruiting investors through personal calls, showing their own accounts, and selling positions in projects they knew were failing. In at least one case, someone sold a EUR 60,000 position to another investor, framing it as a rotation into better assets. That project stopped paying. The seller had documented ties to Crowdestor’s management.

If something similar happened to you on Ventus – someone talked you into investing, maybe encouraged you to take out loans to fund it, maybe even arranged contacts to people who provided those loans – that person has their own criminal exposure. If they sold you a position they knew was failing and concealed that, or made false statements about its prospects to induce your purchase, that is the fact pattern of §263 StGB (Betrug). Kapitalanlagebetrug under §264a only reaches misrepresentations aimed at a larger circle of investors, such as Ventus’s own fundraising materials, not a one-to-one sale. If they earned undisclosed commissions for recruiting you into an unlicensed operation, the commissions themselves may constitute proceeds from a criminal offence under §261 StGB (Geldwäsche). Their personal assets are not inside any restructuring shield.

Sources: https://www.gesetze-im-internet.de/stgb/__263.html; https://www.gesetze-im-internet.de/stgb/__264a.html; https://www.gesetze-im-internet.de/stgb/__261.html

Choosing a lawyer

The criminal complaints in this guide do not need a lawyer. For civil recovery from Ventus in the Baltics, a local lawyer in the relevant jurisdiction is more practical than a German one. Where a German Kapitalmarktrecht lawyer is useful is going after influencers with German assets – see the section above.

If you do hire a lawyer for any part of this, Stiftung Warentest has warned about dubious investor lawyers who file mass proceedings that barely help the injured parties. Before signing or paying anything, ask what comparable cases they have handled and whether they can show, even anonymised, that they have actually recovered money for investors in similar situations. A Fachanwalt credential is a reasonable minimum. A track record is better.

In the past you could gauge a firm’s quality from their published articles. With large language models, that is no longer reliable. Everyone with a website now produces “specialised” takes on these subjects, and as a retail investor you have no way of telling whether that is genuine expertise or AI-generated SEO content. The credential and the track record are what matter. The publications are marketing.

One question worth asking any lawyer you hire: whether any Ventus entity or subsidiary carried Directors & Officers (D&O) insurance. D&O policies may survive the company’s insolvency, and in some jurisdictions or policy structures injured parties may be able to reach the insurance proceeds. If a policy exists, it may be a recovery source that does not depend entirely on Ventus’s own assets.

Other targets outside the restructuring

The restructuring shields Ventus Energy Group OÜ. It does not shield every entity that handled investor money.

Paysera

Paysera LT, UAB is the Lithuanian electronic money institution that processed Ventus’s investor deposits. For years, it handled tens of millions of euros in flows for an entity with EUR 4,166 in capital, zero employees, no filed accounts, and no financial services licence. Under EU anti-money-laundering directives, payment institutions have customer due diligence obligations. A payment processor that moves that kind of volume for a company registered as a “web portal” presents an obvious AML question.

After I filed an AML complaint in February 2026, the Bank of Lithuania opened an assessment of Paysera LT’s handling of the Ventus account (case 2026-00476). Investors can file their own AML complaints with the Bank of Lithuania asking it to examine whether Paysera applied adequate due diligence to its own client. This is a separate pressure point and potential recovery vector if lawyers can establish a viable liability theory. Paysera is a regulated financial institution with real assets. It is not inside any restructuring shield.

SIA White Label Solution

White Label Solution (WLS, reg. 40203629203) is the Ventus marketing and operations vehicle. It is a Latvian company. Until May 22, 2026, WLS was co-owned by Timma (through SIA WIN WIN INVESTMENTS) and Jansons, with both holding board seats. On May 22, seventeen days after the Bafin order, Timma and WIN WIN INVESTMENTS transferred their shares to Toms Ābele, who is now the sole owner, sole board member, and sole beneficial owner (Latvian company register). WLS received payments from Ventus for marketing and operational services. If those payments came from investor deposits routed through an unlicensed operation, they may be relevant to claims for unjust enrichment, damages, or transaction avoidance under Latvian law, depending on the payment purpose and timing. The post-Bafin ownership transfer itself may be examinable under Latvian transaction-avoidance rules. WLS has a Latvian registered address, Latvian bank accounts, and Latvian assets, all within Latvian court jurisdiction and none of it inside the Estonian restructuring.

If you send a formal demand letter to the individuals, consider sending one to WLS as well. It received Ventus money. It is a reachable entity.

Where the restructuring is filed matters

Ventus is registered in Estonia. But its operations ran from Latvia. SIA White Label Solution is Latvian. The key personnel are Latvian. The asset-holding subsidiaries (Eco Energy Riga, JUGLAS JAUDA, PJ Serviss, Power Capital) are Latvian. Its operational headquarters at Vīlandes iela 6-6 is in Rīga. Under the EU Insolvency Regulation (recast), main proceedings should open where the debtor’s center of main interests (COMI) is located. If the COMI is actually Latvia, investors may have grounds to challenge whether Estonia is the proper forum for main proceedings and whether Latvian proceedings should take priority. A Latvian bankruptcy trustee would have direct access to all the Latvian asset-holding companies without cross-border enforcement friction. This is a sophisticated argument that requires a lawyer, but no investor lawyer has raised it yet.

Tips

• Screenshot your Ventus account now. Log in and save your dashboard, portfolio, transaction history, and any loan agreements. If the platform goes dark during restructuring or bankruptcy, that data goes with it.
• Screenshot influencer content that led you to invest. Blog posts, YouTube videos, social media posts where influencers recommended or reviewed Ventus. Some of them are already adding disclaimers or editing their posts. Save the current versions and check web.archive.org and archive.ph for the originals before they were altered. Both versions matter: the original shows what you relied on, the edit shows the author knew it was a problem. If you later file a civil claim against an influencer, the promotional content is your evidence that they directed you to an unlicensed platform. If it is gone by then, so is your evidence.
• Attach your evidence: transfer records, account screenshots, any message about non-payment or frozen funds.
• Language: Each country prefers its own language. English is accepted to start, but a translation (even a careful machine translation) avoids a clarification delay. Strongest for Latvia and required in practice for Lithuania.
• Keep the signed original file, not a printout. It carries the signature.
• Anonymous reports do not give you standing or appeal rights. Your name and a valid signature are required.
• Document your losses for tax purposes. In most EU jurisdictions, investment losses can be offset against capital gains. German investors can declare Ventus losses as Verluste aus Kapitalvermögen in their tax return. The tax treatment does not necessarily depend on whether recovery proceedings ultimately succeed, but timing and classification vary. Keep your transfer records, loan agreements, and any communication confirming non-repayment. Consult your tax adviser on the timing: some jurisdictions require a formal write-off event; others allow the claim once repayment becomes unlikely.

Then what

Filing a criminal complaint does not get your money back. Not immediately, and maybe not directly. What it does is create the playing field where recovery becomes possible.

A criminal investigation can freeze assets. It means the people who controlled this platform cannot quietly move what is left out of reach while investors wait for a restructuring plan that may never deliver. It gives prosecutors the power to open the books, not the company’s own restructuring adviser, but someone whose job is to find out where the money went.

Once that happens, you see what the assets are actually worth, what fees were actually paid, and who received them. That is when you or your lawyer can make an informed call on the chances of a civil claim for fraud and asset recovery. Without that information, any recovery strategy is a guess. With it, the people who controlled the money may have to explain where it went.

The criminal complaint is not the endgame. It is the step that makes the endgame possible.

Caveats

I am not a lawyer. This is public information and filing guidance, not legal advice about your individual situation. A criminal complaint is not a finding of guilt; it is a request for authorities to examine whether an offence has occurred. The legal characterisations in this article are allegations and issues for prosecutors, regulators, and courts to assess. File only facts you personally believe to be true, remove anything you cannot verify, and do not accuse individuals beyond what your evidence supports. Filing a knowingly false criminal complaint can itself be a criminal offence. If your loss is significant, get legal advice before filing civil claims or naming individuals personally.

Corrections

• July 1, 2026: SIA White Label Solution ownership updated. The article originally described WLS as co-owned by Timma and WIN WIN INVESTMENTS. On May 22, 2026, both transferred their shares to Toms Ābele, who is now the sole owner, board member, and beneficial owner. Correction reported by a reader who checked the Latvian company register.
• July 1, 2026: Voting requirements corrected. The article originally stated approval requires “at least half the creditors” plus two-thirds by value. The 2022 amendment to the Estonian Reorganisation Act removed the headcount test. Approval now requires only two-thirds by claim value. Correction reported by a reader.
• July 1, 2026: Lookback language clarified. The article originally said the lookback “window closed because nobody started it.” The window has not opened yet because no trustee has been appointed. A trustee appointed today could still reach Crowdestor transactions from 2021 onward. Correction reported by a reader.