Summer is now in full swing across Europe, and I hope you are finding some time to enjoy it. Although in many parts of Europe temperatures have been exceptionally high, I was fortunate to spend part of last week with my family in the UK, where the weather was surprisingly pleasant, perhaps even a little too warm for London standards. Stepping away from the daily routine always provides an opportunity to recharge, but it also creates space to reflect on broader topics. During this short break, one subject kept returning to my mind...

Recently, several important regulatory developments have taken place across Europe. One of the biggest is the implementation of the Markets in Crypto-Assets (MiCA) regulation. Since 1 July, only MiCA-authorised entities can legally provide crypto-asset services to EU citizens. As we announced earlier, TWINO is now among fewer than 300 authorised crypto-asset service providers across Europe - a milestone that reflects both our regulatory capabilities and our long-term vision. If you are interested in why we decided to pursue this licence and how it fits into our strategy, I encourage you to read our recent blog post here.

Today, however, I would like to discuss a broader topic - the relationship between innovation and regulation. Throughout the history of financial services, innovation and regulation have behaved like a pendulum. Innovation comes first. Someone creates a new product, a new business model, or a new way of serving customers. Regulation follows later, trying to determine where that innovation fits within the existing legal framework - or whether an entirely new framework is needed.

Over the past decade this process has become considerably more complex. Technology is evolving faster than regulation, while financial services are increasingly blending with industries such as e-commerce, mobility, food delivery, utilities and digital platforms. The traditional boundaries between industries are becoming less obvious, making regulation more challenging than ever. MiCA itself is a good example. Blockchain technology first emerged as a technological innovation, then evolved into financial products and services that simply did not fit within existing financial regulations. Europe eventually responded by creating an entirely new regulatory framework. But crypto is far from the only example. Peer-to-peer investing created an entirely new investment model, yet Europe still has no dedicated P2P regulatory regime. Platforms must instead operate under existing investment or crowdfunding licences, or in some cases remain outside direct regulation altogether. Buy Now, Pay Later (BNPL) developed in a similar way. Is it a payment service? Is it consumer lending? Different jurisdictions answered that question differently, creating years of uncertainty before regulation began catching up.

This brings me to another recent topic that many of you discussed actively in our Telegram community

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the potential administrative case involving Fincard.

Without commenting on the merits of the specific case itself as the situation has already been explained in the Telegram community chat, I believe it illustrates a broader reality of today's financial industry. Companies that want to build something genuinely new inevitably enter areas where regulation leaves room for interpretation. Sometimes multiple regulators are involved, each viewing the same business model through a different legal lens. Sometimes legislation written years ago simply was not designed to accommodate modern products. In the case of Fincard, several authorities and multiple regulatory frameworks intersect, making the situation particularly complex. Future implementation of CCD II should help harmonise parts of this landscape, but until then these discussions are likely to continue. As investors, I believe it is important that you understand this context.

The conclusion I increasingly arrive at is that offering truly innovative financial services inevitably comes with a degree of regulatory uncertainty. Every meaningful innovation creates questions that regulators, companies and sometimes courts eventually need to answer. Explaining business models, interpreting legislation and, where necessary, adapting products have become part of the modern cost of innovation in financial services.

At TWINO we have accepted this reality. We believe innovation and strong compliance are not opposing forces but complementary ones. Our objective is not to avoid regulation - it is to innovate responsibly within it, while being prepared that pioneering products may occasionally require additional dialogue with regulators or adjustments as regulation evolves.

FLEXI continues to gain excellent momentum. More than €800,000 has already been invested by almost 600 investors, demonstrating that many of you appreciate having a flexible place to earn attractive returns on idle cash.

Recently we also introduced daily accrued FLEXI interest on the web platform, allowing you to monitor your earnings day by day with greater transparency.

We have successfully completed the sale of the second Rentals portfolio, and all principal together with earned returns has now been distributed to investors.

As expected, summer has brought a somewhat quieter real estate market, but our team continues working actively on preparing and executing additional apartment sales.

Currently recoveries from Russia continue according to the previously communicated repayment conditions.

In Vietnam there are currently no significant new developments, and we continue following the legal process while providing all necessary support to move it forward.

There are still no major updates regarding the implementation of CCD II in Poland. The market continues waiting for the Polish government to determine the next steps, and we remain prepared for different possible scenarios.