Taking over clients of crypto firms without a MiCA licence
Since 1 July 2026 only firms with a MiCA licence may provide crypto services in Croatia, and 12 of the 17 firms in Hanfa's register did not receive one34. Their clients have to go somewhere. Electrocoin holds a licence and can take them on without any extension2.
Taking over clients, not buying the company
Electrocoin does not need to buy any of the firms left without a licence. It is enough for their clients to open an account with Electrocoin and transfer their assets. Buying a firm would bring no regulatory benefit: Hanfa grants authorisation to an individual company, so the licence does not transfer with a purchase5, and Electrocoin already holds one anyway2. Buying the firm would also mean taking on its liabilities and risks.
- What is taken over: clients and their assets, with each client's consent. Client data may only be transferred on a legal basis under the GDPR, and the safest one is the client's consent6.
- Why the firms would cooperate: ESMA requires firms leaving the market to have an orderly wind-down plan, to notify clients in advance and to transfer their assets to a licensed provider or to the client's own wallet7. Electrocoin can be that licensed provider.
- A real-world example: Hanfa ordered Fima Plus to notify its clients within 8 days that its services were ending and to ask for instructions on returning their assets. This involved 123 clients with assets of around $484,0008. That is the moment when a client chooses a new platform.
Firms without a licence: how big they are
| Firm | Services in the register | Revenue 2025 | Employees | Note |
|---|---|---|---|---|
| Moneysail | custody, crypto for money | €7.84M15 | 6 | Website mercuryo.io; in 2024 Hanfa ordered anti-money-laundering measures27 |
| Blok Be | custody, platform, crypto for money and crypto, advice | €4.60M10 | 2 | Ceased operating on 1 Jun 2026, not accepting new clients9 |
| Cana Pay | crypto for money | €3.82M11 | 3 | Profit €2.15M, so revenue is probably not gross turnover |
| FiatBit Technologies | crypto for money | €2.77M12 | 3 | Profit €1.56M |
| M obrada | execution and transmission of orders | €1.45M13 | 11 | Revenue growth 47% |
| Fintrax | custody, crypto for money and crypto, orders | €0.43M14 | 0 | Loss €140,000 |
| DUPLICO | crypto for money and crypto | €0.40M16 | 7 | Hospitality and retail, crypto is only part of the business |
| BD Innovation Hub | custody, crypto for crypto, orders, placing | €5,41317 | 1 | Revenue fell 99.5% |
| HODL Store, Marinix275, Adria Digital Exchange | various | €0181920 | 0 | No revenue, so no clients to take over |
Services as listed in Hanfa's register1. For comparison, in 2025 Electrocoin had €1.18M in net revenue and 29 employees21. Firms book revenue in different ways: some gross (the value of crypto sold), others only the commission. That is why their revenue is not directly comparable with Electrocoin's.
How to take over clients: a five-step plan
- 1.
Direct contact with management
Approach the firms that have clients (Blok Be, FiatBit, Cana Pay, M obrada, Fintrax, DUPLICO) and offer Electrocoin as a licensed provider to which they can refer their clients. For the firms, this settles the orderly wind-down obligation that ESMA requires7.
- 2.
Client referral agreement
The firm sends its clients a notice recommending Electrocoin, and each client gives consent and opens an account themselves6. The firm can receive a one-off fee for each client who switches. The amount of the fee is a matter for negotiation.
- 3.
An easy switch
Registering with Electrocoin takes about 8 minutes, with a 30-second video check, and crypto can be deposited from another wallet25. Clients who switch need a dedicated page with instructions and personal support in Croatian.
- 4.
"Switch to the first Croatian licensed platform" campaign
Large exchanges are already doing this: OKX gives an 8% bonus on transferred assets, Coinbase 5%, SwissBorg 3% on transfers from unlicensed exchanges, and Kraken ran a one-million-euro prize draw2324. Electrocoin probably cannot afford such percentages on a margin of 1–2%22. A few months with no margin or a smaller fixed bonus is more realistic.
- 5.
Retention
A client taken over is only worth something if they stay. Large clients, e.g. those who traded OTC with Blok Be9, need a personal contact, and everyone else regular perks.
Estimate: additional monthly turnover and revenue
How revenue is calculated. Electrocoin earns a margin of 1–2% per transaction22. The margin is charged both when a client buys crypto for euros and when they sell it back for euros. Example: a client buys bitcoin for €1,000 and later sells it for €1,000. Turnover is €2,000, and Electrocoin earns €20–40, i.e. 1–2% of turnover.
Starting point. The number of clients these firms have is not public, so we use their revenue from Fina as a measure of their annual turnover. This is a lower bound, because firms that book only commission have actual turnover many times higher than their revenue. We count the eight firms that have revenue: Moneysail, Blok Be, Cana Pay, FiatBit, M obrada, Fintrax, DUPLICO and BD Innovation Hub. In total €21.3M a year, around €1.78M a month1011121314151617.
| Share of clients taken over | Turnover / month | Turnover / year | Revenue / month | Revenue / year |
|---|---|---|---|---|
| 10% | ~€178,000 | ~€2.13M | ~€1,800–3,600 | ~€21,000–43,000 |
| 20% | ~€355,000 | ~€4.26M | ~€3,600–7,100 | ~€43,000–85,000 |
| 50% | ~€888,000 | ~€10.66M | ~€8,900–17,800 | ~€107,000–213,000 |
Revenue = turnover × 1% (lower value) to turnover × 2% (upper value). All amounts are estimates.
What this means for Electrocoin: net revenue in 2025 was €1.18M, around €98,000 a month21, and we estimate turnover at around €4.9M a month26. Taking over 50% of clients would bring around 18% more turnover and 9–18% more revenue. The domestic unlicensed firms are small relative to Electrocoin, so this proposal is worthwhile as a quick and cheap add-on, but not as a main source of growth.
Risks and open questions
- The number of clients and the assets of these firms are not public. The estimate can only be refined after talks with management.
- Part of the firms' revenue, e.g. at DUPLICO and Cana Pay, may not come from crypto.
- Clients may also go to large exchanges offering 3–8% bonuses23.
- Moneysail is subject to Hanfa supervisory measures from 202427, so any cooperation with it needs separate checks.
Sources
- HANFA: register of virtual asset service providers (VASP)
- HANFA: register of crypto-asset service providers (CASP)
- HANFA: crypto services from 1 Jul 2026 only with a licence (3 Jul 2026)
- Financije.hr: Unlicensed crypto platforms may no longer operate (3 Jul 2026)
- MiCA Regulation, Art. 59: authorisation of crypto-asset service providers
- GDPR, Art. 6: lawfulness of processing of personal data
- ESMA: statement on the end of the MiCA transitional period (17 Apr 2026)
- Lider: Hanfa bans Fima Plus from providing crypto services (29 Jul 2026)
- Blok Be: notice of services ending from 1 Jun 2026
- FINA Info.BIZ: Blok Be d.o.o. (2025)
- FINA Info.BIZ: Cana Pay d.o.o. (2025)
- FINA Info.BIZ: FiatBit Technologies d.o.o. (2025)
- FINA Info.BIZ: M obrada d.o.o. (2025)
- FINA Info.BIZ: Fintrax d.o.o. (2025)
- FINA Info.BIZ: Moneysail d.o.o. (2025)
- FINA Info.BIZ: DUPLICO d.o.o. (2025)
- FINA Info.BIZ: BD Innovation Hub d.o.o. (2025)
- FINA Info.BIZ: HODL Store d.o.o. (2025)
- FINA Info.BIZ: Marinix275 d.o.o. (2025)
- FINA Info.BIZ: Adria Digital Exchange d.o.o. (2025)
- FINA Info.BIZ: Electrocoin d.o.o. (2025)
- Lider: margins fell from 15% to 1–2% (23 Jun 2019)
- CryptoSlate: exchanges pay users to switch before the MiCA deadline (27 Jun 2026)
- FinanceFeeds: Coinbase offers a 5% transfer bonus (27 Jun 2026)
- Projekt Hrvatska: Electrocoin experience 2026 (review at the company's invitation)
- Electrocoin case study: 2025 turnover estimate (~€59M, net revenue / 2%)
- HANFA: supervisory decision on Moneysail d.o.o. (16 Oct 2024)