Two stories are unfolding in parallel in Poland. The Sejm is searching at the last minute for consensus on the Poland MiCA implementation, while the criminal case against Zondacrypto, the country's largest crypto exchange, keeps drawing wider circles.
Poland had remained the only EU member without MiCA implementing legislation, with the deadline expiring on 1 July 2026. On 12 May 2026, the Polish Sejm held the first reading of four competing bills and referred them to the Finance Committee. In addition, the Katowice public prosecutor's office has been investigating Zondacrypto since 17 April on suspicion of large-scale fraud and money laundering. The documented minimum damage amounts to 350 million zloty (83 million EUR). Prime Minister Donald Tusk puts the number of alleged victims at around 30,000.
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Four bills, one deadline
The four drafts come from the governing coalition, from President Karol Nawrocki, and from the parliamentary groups Polska 2050 and Konfederacja. The government and presidential proposals largely converge. Both designate the financial supervisory authority KNF as the competent body. The main differences concern the scope of powers to freeze crypto accounts as well as the level of sanctions. In addition, Polska 2050 proposes allowing banks to provide crypto services.
The time pressure is considerable. Moreover, the EU deadline for CASP licences under MiCA remains 1 July 2026. Without national implementing rules, Polish providers cannot apply for a MiCA licence, while EU competitors may continue operating in Poland under the freedom to provide services. The Sejm had already adopted an earlier draft on 19 December 2025 by 241 votes to 183. However, Nawrocki vetoed the bill twice, first in December 2025 and again in February 2026.
The earlier legislative package provided for fines of up to 10 million zloty and prison terms of up to five years for breaches of CFT rules. Moreover, KNF licensing procedures already take the longest in the EU, averaging 30 months. As a result, the Polish industry warns that the project goes beyond the EU standard and could push providers to relocate to other member states.
The Zondacrypto case as evidence
The parallel collapse of Zondacrypto shows how heavily a regulatory vacuum hits investors. Launched in 2014 in Katowice as BitBay, the platform operated under an Estonian licence, effectively outside the direct reach of Polish regulators. Meanwhile, the KNF had placed the company on its public warning list as early as 2018, but had no means to impose decisive sanctions.
The Zug-based blockchain forensics firm Recoveris documented the outflow. Bitcoin holdings in the hot wallets fell from 55.7 BTC in August 2024 to 0.07 BTC on 1 April 2026, a decline of 99.7% within 20 months. Between December 2025 and April 2026, Recoveris recorded 511 transactions to Kraken wallets with a total volume of about 21 million USD, of which 4.59 million USD was in Bitcoin. CEO Przemysław Kral is reported to have fled to Israel; his Israeli citizenship complicates extradition.
Tusk linked the case directly to the blocked legislative procedures. He accused Nawrocki of having vetoed both bills, even though the president knew at that point about Zondacrypto's financial difficulties and political ties. Furthermore, the exchange is said to have donated more than 700,000 zloty to foundations connected with former justice minister Zbigniew Ziobro and with a Konfederacja member of parliament.
The Zug holding structure
The operating company behind Zondacrypto is the Estonian BB Trade Estonia OÜ. Its majority owner is Divisio Holding AG, based at Baarerstrasse 78 in Zug, registered at the address of Dr André Terlinden. The entity was incorporated on 24 June 2021 (UID CHE-161.370.248, share capital CHF 100,000). Terlinden stepped down from the board on 27 April 2026, one week after the resignation of the Estonian supervisory board.
On 20 April, the entire oversight body of BB Trade Estonia resigned as a group: Veronika Togo, Guido Bühler, and Georgi Džaniašvili. Bühler is a co-founder and former CEO of SEBA Bank (Zug), which now operates as Amina Bank; previously, he served on the board of UBS Investment Bank. He joined Zondacrypto as a non-executive director in October 2023. The board justified the step with "material inconsistencies between public statements, operational reality, and the information previously provided to the supervisory board" as well as a "systematic breakdown of governance fundamentals". Furthermore, the supervisory board only learned of the crisis through Polish media reports, not from management.
The Swiss footprint extends further. Zondacrypto opened an office in Zug in January 2025 and entered into a partnership with Incore Bank. At the time, CEO Kral described Switzerland as a key market in the global expansion strategy. For about a year, the home arena of HC Davos has carried the name "zondacrypto-Arena". As a result, the sponsorship of the women's cycling WorldTeam Canyon-SRAM is also under review.
What remains
The asymmetry between the two legal jurisdictions stands out. Switzerland created a clear framework with the DLT Act and FINMA supervision from 2021, before any major scandals emerged. Poland, by contrast, is now negotiating the basic outlines of its supervisory regime in parallel with the criminal processing of a billion-zloty case. As a result, the Zondacrypto file is likely to shape the debate in the Sejm, particularly on the question of how far KNF powers to intervene in operational platforms should extend.
The whereabouts of a cold wallet holding around 4,500 BTC remain unclear. Founder Sylwester Suszek, reported missing since March 2022, is said to be the only person holding the private keys. Kral publicly points to these reserves but cannot prove access. In addition, there is the allegation of a transfer of 76 million zloty to another exchange, which the CEO denies. Furthermore, Polish Olympic athletes are still waiting for 1.1 million zloty in token-based medal bonuses.
Until 1 July 2026, the Sejm has just under seven weeks to produce a bill that Nawrocki can be persuaded to sign. If that fails, the largest crypto market in Eastern Europe will continue to operate in a regulatory grey zone, while EU competitors under MiCA have long since completed their licensing procedures in Frankfurt, Paris, or Vilnius.
