According to Ventus’ investor call, Paysera is sitting on more than EUR 2 million of investor money. The accounts are frozen. Ventus can’t touch it. The restructuring hasn’t been filed with any Estonian court. There is a window, and it may not stay open long.
Source: https://youtu.be/Fh7zkVxNut0 (at 27:39)
Here’s the idea: ask Paysera to reverse your transfers. Not through Ventus. Directly. You sent money to a Paysera account for an unlicensed financial service. The regulator confirmed it was unlicensed. Paysera froze the accounts. The money is still in the payment system. Ask for it back.
This applies to every transfer you ever made to Ventus through Paysera. Not just money sitting “in your wallet.” If your dashboard shows everything as “invested,” that changes nothing. The wallet/invested distinction exists only inside Ventus’s own software. It is an entry in their database. Paysera does not see it, does not have access to it, and has no reason to care about it. Paysera sees bank transfers in and bank transfers out. The internal bookkeeping of an unlicensed platform has no bearing on your claim.
This makes sense if you think about what ‘invested’ actually means: It just means Ventus loaned your money onwards. It has no meaning for your legal relationship to them or your money.
Here’s what I would try in the shoes of a Ventus investor:
Two letters. One to Paysera. One to your own bank.
Why this could work
Paysera froze the Ventus accounts and blocked outgoing payments in late May 2026. The money is sitting there. It can’t go to Ventus. It can’t go anywhere. Paysera is holding funds from a platform that three national regulators have flagged as unlicensed, while the Bank of Lithuania runs an AML assessment on Paysera’s own handling of the relationship.
For Paysera, returning funds to the documented original senders is the path of least regulatory risk. It reduces their AML exposure. It clears frozen balances off their books. It aligns with the Bafin order, which explicitly requires immediate repayment to investors. And it gets them out of a situation where they’re stuck holding someone else’s problem.
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
The legal argument is straightforward:
- Ventus operated without a licence. Bafin’s cessation order of 5 May 2026 confirms this: unauthorised deposit-taking in violation of Section 32 KWG.
- Contracts for unlicensed financial services are void under applicable law. In Germany, that’s Section 134 BGB combined with Section 32 KWG.
- Without a valid contract, there is no legal basis for Paysera to hold the funds for Ventus’s benefit.
Sources: https://www.bafin.de/dok/22567556; https://www.gesetze-im-internet.de/bgb/__134.html; https://www.gesetze-im-internet.de/kredwg/__32.html
It also doesn’t matter when you transferred. The contracts were void from the start because the business was unlicensed. Whether Ventus deployed your money into energy projects, paid it out as interest to other investors, or used it to cover operating costs is irrelevant. The practical constraint is the EUR 2 million pool at Paysera, not the age or internal status of your transfer.
The restructuring is a question mark but not a blocker. As of late June, three independent Estonian law firms confirmed that no restructuring petition has been filed with any Estonian court and no notice has appeared in the Ametlikud Teadaanded. Until a court accepts a petition, there is no moratorium and no court-appointed administrator claiming those funds. The window exists because Ventus announced a restructuring but has not actually started one.
Source: https://www.ametlikudteadaanded.ee/
First come, first served
On the June 16 lender Zoom call, Ventus stated that more than EUR 2 million was blocked at Paysera. That is the ceiling. If Paysera agrees to reverse transfers, the first requests processed get their money back. After EUR 2 million, the account is empty and Paysera has one headache less.
Source: https://youtu.be/Fh7zkVxNut0 (at 27:39)
Send both letters by express mail and email on the same day. The order in which requests arrive may matter.
Template: Letter to Paysera
Fill in the bracketed fields with your own details. Verify everything is correct for your situation. I am not a lawyer, and this is not legal advice.
Subject: Request for Reversal of SEPA Credit Transfers - Ventus Energy Group OÜ (16964065) Paysera LT, UAB Pilaitės pr. 16 LT-04352 Vilnius Lithuania Email: [email protected] [Date] [Your full name] [Your address] [Your email] Dear Sir/Madam, I am requesting the reversal of the following SEPA credit transfers to an account held by Ventus Energy Group OÜ (Estonian registry code 16964065) at Paysera LT, UAB: Date | Amount (EUR) | From IBAN | To IBAN | Reference [date] | [amount] | [your IBAN] | [Ventus IBAN] | [reference] [date] | [amount] | [your IBAN] | [Ventus IBAN] | [reference] Total: EUR [total amount] BASIS FOR THIS REQUEST 1. The German Federal Financial Supervisory Authority (Bafin) issued a cessation and repayment order against Ventus Energy Group OÜ on 5 May 2026. The order finds that Ventus conducted unauthorized deposit-taking (unerlaubtes Einlagengeschäft) in violation of Section 32 of the German Banking Act (KWG) and requires immediate repayment to investors. The order is published at: https://www.bafin.de/dok/22567556 2. The Central Bank of Latvia (Latvijas Banka) has placed Ventus Energy Group OÜ on its official warning list for operating without proper authorization. 3. Paysera LT, UAB has frozen the Ventus Energy accounts and blocked outgoing payments (confirmed by Ventus in its lender communications of 11 June 2026). 4. The Bank of Lithuania is conducting an assessment of Paysera LT, UAB's relationship with Ventus Energy Group OÜ under the Law on the Prevention of Money Laundering and Terrorist Financing. 5. Ventus Energy Group OÜ was never licensed as a credit institution, crowdfunding service provider, or investment firm in any EU member state. The company is registered under NACE code 63.12 (web portal activities) with share capital of EUR 4,166 and zero employees. The transfers listed above were made for the purpose of providing repayable funds through an unlicensed financial platform. Because the underlying activity was conducted without the required regulatory authorization, the legal basis for these transfers is defective. The Bafin order confirms the illegality of the business and orders repayment. As Paysera has frozen the relevant accounts and cannot disburse the funds to Ventus Energy Group OÜ, the funds remain within the payment system. I request that you reverse the transfers listed above and return the funds to my originating account: IBAN: [your IBAN] BIC: [your BIC] Account holder: [your name] I request a response within 14 calendar days. Should Paysera decline to process this reversal, I will file a complaint with the Bank of Lithuania and pursue the matter through the available dispute resolution and legal channels. Sincerely, [Full name] [Signature] Attachments: 1. Bafin cessation and repayment order (Verbrauchermitteilung, published 18 May 2026) 2. SEPA transfer confirmations for each transfer listed above
Template: Letter to your bank
Subject: Request for SEPA Recall - Transfers to Unlicensed Financial Platform (Ventus Energy Group OÜ, via Paysera LT, UAB) [Your bank name] [Bank address or: via online banking secure message] [Date] [Your full name] [Your account number / IBAN] [Your customer number] Dear Sir/Madam, I am requesting that you initiate a SEPA recall for the following credit transfers from my account. The transfers were sent to Ventus Energy Group OÜ (Estonian registry code 16964065) and processed through Paysera LT, UAB (Lithuania): Date | Amount (EUR) | From IBAN | To IBAN | Reference [date] | [amount] | [your IBAN] | [Ventus IBAN] | [reference] [date] | [amount] | [your IBAN] | [Ventus IBAN] | [reference] Total: EUR [total amount] These transfers were made for the purpose of investing through Ventus Energy (ventus.energy), a platform that the German Bafin has since found to be operating unauthorized deposit-taking in violation of Section 32 KWG. Bafin issued a cessation and repayment order on 5 May 2026. Paysera LT has frozen the relevant accounts. I request that you: 1. Initiate a SEPA recall request to Paysera LT, UAB for each transfer listed above, citing the Bafin enforcement order and the illegal nature of the underlying activity. 2. Advise me on any additional procedures available through your institution for recovering funds transferred to an entity subject to a regulatory repayment order. 3. Report the matter to your compliance department if appropriate under your institution's AML obligations. I have separately written to Paysera LT, UAB requesting direct reversal. A copy of that letter is enclosed. Sincerely, [Full name] [Signature] Attachments: 1. Copy of letter sent to Paysera LT, UAB 2. Bafin cessation and repayment order (published 18 May 2026) 3. SEPA transfer confirmations
If Paysera says no
File a complaint with the Bank of Lithuania. Paysera LT, UAB is a Lithuanian electronic money institution (authorisation number LB000251). The Bank of Lithuania supervises it. A complaint about how Paysera handles the frozen funds adds regulatory pressure on top of the existing AML assessment. Paysera is already under scrutiny. They do not want a second case about mishandling the resolution.
The Bank of Lithuania consumer complaint form is at https://www.lb.lt/en/complaints. Reference the AML assessment that is already running.
Act fast
This is not a strategy for next month. The EUR 2 million at Paysera is a fixed pool. The restructuring petition could be filed any day, and a moratorium could change the legal landscape. Send both letters as soon as you have your transaction details together. Express mail and email, same day.
The other things you should be doing in parallel are in the investor guide.
Disclosure
I am not a Ventus lender. I filed the original Bafin complaint in December 2025 and the Bank of Lithuania complaint about Paysera in February 2026. I am not a lawyer. The templates and strategy in this article are my own assessment, not legal advice. Consult a lawyer in your jurisdiction before acting.
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