A February 2026 compliance review confirms that offshore broker RoboForex Ltd (Belize) continues onboarding EU retail clients and directing SEPA deposits to a Lithuanian bank account held with AB Mano Bankas. Despite clear EU residency disclosure during KYC, the broker accepted the account and issued an invoice instructing payment to its Belize entity. The structure raises material MiFID and AML governance questions.
Key Findings
- EU passport and EU address submitted and verified.
- Account opened without restriction.
- Confirmation email issued by RoboForex Ltd (Belize).
- SEPA transfer instructions to:
- Beneficiary: RoboForex Ltd
- Bank: AB Mano Bankas (Lithuania)
- IBAN: LT425030120000000032
- Invoice explicitly confirms deposit to Belize entity.
- No MiFID authorization.
- No MiCA authorization.
Regulatory Position of RoboForex
RoboForex Ltd is the operator of the offshore broker RoboForex.com. The entity is:
- Incorporated in Belize.
- Licensed by FSC Belize.
- Not licensed in the EU.
- Not passported under MiFID.
- Not authorized under MiCA.
Under EU law, the active onboarding of EU residents and acceptance of funds via SEPA banking rails constitutes cross-border financial service provision.
The review demonstrates:
- No geo-blocking.
- No rejection of EU residents.
- No disclaimers preventing onboarding.
- Active acceptance of EU deposits.
This is not incidental access.
This is structured onboarding.
SEPA Rail Mechanics
The deposit flow is straightforward:
EU client
↓
RoboForex platform
↓
SEPA instruction
↓
Transfer to Lithuanian IBAN
↓
Beneficiary: RoboForex Ltd (Belize)
The invoice confirms:
“Payment for replenishment of account.”
This is retail funding of an offshore broker.
Mano Bankas – Supervisory Implications
AB Mano Bankas (website) is a Lithuanian-regulated credit institution supervised by the Bank of Lithuania and subject to:
- EU AMLD framework
- PSD2 governance obligations
- EBA Guidelines on ML/TF Risk Factors
- Customer due diligence obligations
- Ongoing transaction monitoring requirements
Where a bank maintains an account for an offshore broker accepting retail EU funds, compliance questions arise:
- Was the broker’s licensing position assessed?
- Was cross-border authorization verified?
- Was the target market reviewed?
- Was enhanced due diligence applied?
- Was ongoing monitoring conducted after regulatory warnings?
The IBAN is not used for corporate treasury transfers. It is used for direct EU client deposits. That changes the risk profile materially.
Risk Classification
From a compliance perspective, this structure may expose the bank to:
- Reputational risk
- AML exposure
- Regulatory scrutiny
- Supervisory inquiries
- Cross-border compliance breaches
This report does not allege wrongdoing. It documents a factual structure that warrants supervisory examination.
Evidence Preservation
The review documentation includes:
- KYC confirmation records
- Deposit screens
- Invoice issued by RoboForex Ltd
- Bank details
- SEPA instructions
- Confirmation emails
All materials are preserved.
Short Analysis
The central issue is simple:
Can an offshore broker licensed in Belize accept EU retail deposits through a Lithuanian bank account without MiFID authorization?
And if not:
What is the supervisory expectation of the EU-regulated bank providing the IBAN?
Call for Information
FinTelegram invites regulators, compliance officers, and insiders with knowledge of cross-border SEPA facilitation of offshore brokers to contact us confidentially via Whistle42.com.
