Why the authorities in Belgium are not answering? Is there something to hide? The omndusman was the only who wrote an answer, that this is not their "topic" (see attached), which is not true. ________________________________________ Zsolt Ruszin FairConto 2026.05.28. 10:48 keltezéssel, FairConto - Ruszin Zsolt írta: > We still need urgent answer. > ________________________________________ > Zsolt Ruszin > FairConto Zrt. > > 2026.05.14. 16:04 keltezéssel, FairConto - Ruszin Zsolt írta: >> We need urgent answer. >> ________________________________________ >> Zsolt Ruszin >> FairConto Zrt. >> >> 2026.05.07. 18:28 keltezéssel, FairConto - Ruszin Zsolt írta: >>> We need urgent answer. >>> ________________________________________ >>> Zsolt Ruszin >>> FairConto Zrt. >>> >>> 2026.05.05. 15:06 keltezéssel, FairConto - Ruszin Zsolt írta: >>>> >>>> Subject: Urgent supervisory request – Wise Europe SA, Hungarian HU IBAN accounts and risk of asset flight from Hungary >>>> >>>> Dear Sir or Madam, >>>> >>>> I am writing again because my previous request sent to the FSMA press address on 25 October 2025 remained unanswered, while the matter has now become urgent from an anti-money laundering, tax enforcement and public-interest perspective. >>>> >>>> In recent days, serious concerns have emerged in Hungary that assets allegedly deriving from corruption, abuse of public procurement and other criminal conduct are being transferred or prepared for transfer outside Hungary. The concern is not theoretical. International press reports have described alleged attempts by persons linked to the outgoing Hungarian power structure to move substantial wealth abroad before the new government takes office. >>>> >>>> Reuters reported on 28 April 2026 that Péter Magyar stated that bank accounts of several “front men” linked to the outgoing government had been frozen and that banks should tighten their compliance departments and report suspicious activity. Reuters also quoted him as saying: “Let me signal now, that anyone — be it an authority or a bank — not acting in line with the letter and the spirit of the law will have to face the Hungarian justice system.” >>>> >>>> The Guardian reported on 26 April 2026 that Péter Magyar alleged that “Orbán-linked oligarchs are transferring tens of billions of forints to the United Arab Emirates, the United States, Uruguay and other distant countries.” The same report stated that some of the wealth accumulated in Hungary during the past 16 years was connected to public procurement and EU-funded contracts. >>>> >>>> Reuters also reported on 5 May 2026 that Gyula Balásy, a major media entrepreneur close to the outgoing Orbán government, offered to hand over his companies and investments to the Hungarian state after the election defeat, while the incoming government has pledged to review state contracts, curb corruption and “reacquire stolen state assets”. The same report refers to Transparency International’s statement that Balásy-related companies won HUF 295 billion worth of state contracts in 2019–2021. >>>> >>>> Against this background, Wise Europe SA represents a material supervisory blind spot in Hungary. Wise provides Hungarian HU IBAN business accounts to Hungarian users, but, according to the information available to me, these accounts are not reported to the Hungarian Tax and Customs Administration and the Hungarian company registry as domestic payment accounts, and Wise has not opened the technical communication and enforcement interface required in practice for Hungarian electronic enforcement procedures. >>>> >>>> This creates a Trojan-horse effect. From the user’s and the Hungarian market’s perspective, the account functions as a Hungarian HU IBAN business account. From the enforcement and reporting perspective, however, the account is not effectively reachable by the Hungarian authorities in the same way as accounts held with Hungarian banks or other domestic payment account providers. This asymmetry may allow assets of suspected corrupt or criminal origin to be moved from Hungary to other, less cooperative jurisdictions before Hungarian authorities can identify, freeze or enforce against them. >>>> >>>> This is particularly serious because a significant part of the suspected corrupt wealth in Hungary may originate, directly or indirectly, from EU funds, EU-financed procurement or state contracts financed by Hungarian and EU taxpayers. If such assets are transferred abroad through payment-service channels that are not properly visible to Hungarian tax and enforcement authorities, the financial loss is not only Hungarian; it is also an EU-level rule-of-law and financial-protection issue. >>>> >>>> My specific concern remains the same as in my previous letter. Wise Europe SA is a Belgian-regulated payment institution. Hungarian authorities have been informed that, despite the HU IBAN structure and Hungarian market use, the relevant Wise accounts are treated as Belgian accounts. At the same time, Hungarian public authorities and market participants are left without the reporting and enforcement infrastructure that exists for domestic payment account providers. >>>> >>>> Therefore, I respectfully request that the competent Belgian authority confirm the following: >>>> >>>> Did the Belgian supervisory authority participate in, or provide a position for, the consultation referred to by the Hungarian Tax and Customs Administration, according to which Wise HU IBAN accounts are to be considered accounts held in Belgium despite their Hungarian HU IBAN appearance and Hungarian business use? >>>> If yes, what was the exact supervisory position of the Belgian authority? >>>> Does the Belgian authority consider it acceptable under EU payment-services, AML and financial-supervision rules that Wise Europe SA provides HU IBAN business accounts to Hungarian companies without ensuring equivalent Hungarian account reporting and electronic enforcement accessibility? >>>> Has the Belgian authority assessed whether this structure may facilitate the transfer of assets of suspected criminal or corrupt origin from Hungary to non-cooperative or less cooperative jurisdictions? >>>> Has the Belgian authority assessed this matter in light of the current Hungarian asset-flight allegations reported by Reuters, The Guardian and other international media? >>>> Has the Belgian authority required, or does it intend to require, Wise Europe SA to implement an effective cooperation, reporting and enforcement interface with the Hungarian Tax and Customs Administration and the competent Hungarian enforcement authorities? >>>> If the Belgian authority considers that this issue falls outside its competence, please identify the competent Belgian or EU authority responsible for assessing the AML, payment-services and cross-border enforcement risks described above. >>>> >>>> I request that this letter be forwarded internally to the department responsible for the supervision of Wise Europe SA, payment institutions, AML/CFT compliance and cross-border supervisory cooperation. If FSMA is not the competent authority, please forward it to the National Bank of Belgium or confirm the correct official channel. >>>> >>>> This is not a consumer complaint. It is a supervisory warning concerning a structural enforcement gap that may materially affect Hungary’s ability to preserve and recover public assets, including assets originating from EU-funded public contracts. >>>> >>>> Best regards, >>>> >>>> ________________________________________ >>>> Zsolt Ruszin >>>> FairConto >>>> >>>> Accounting, Tax Consulting, Press Agency >>>> Office: 12-14 Könyves Kálmán krt. Budapest H-1097 >>>> 2/a Nefelejcs str., Zalaegerszeg, H-8900 >>>> Tel: +36 1 238-8023 >>>> Mobil: +36 20 922-8470 (+VIBER, WhatsApp, Signal, etc.) >>>> e-mail: zsolt.ruszin@fairconto.hu >>>> WEB: www.fairconto.hu >>>> >>>> >>>> >>>> -------- Továbbított üzenet -------- >>>> Tárgy: WISE Europe SA business account service in Hungary >>>> Dátum: Sat, 25 Oct 2025 15:47:56 +0200 >>>> Feladó: FairConto - Ruszin Zsolt >>>> Címzett: press@fsma.be >>>> >>>> >>>> Dear Johan Corthouts, >>>> Dear Mathieu Saudoyer, >>>> >>>> There is a court case in Hungary about whether the Hungarian tax authorities consider WISE to be a domestic cash account under the Hungarian Taxation Act or not. >>>> >>>> Only the Hungarian National Bank has the right to interpret the matter (MNB Act, Section 43 (2b)) and according to the MNB, WISE is a cash account held in Hungary (letter with registration number 394186-3/2023, signed electronically by Palasikné dr. Dóra Kirschner). The letter was written to Péter Gervai on 2023.09.26. >>>> >>>> The Tax and Customs Administration is attacking this fact with astonishing lies and it is already becoming unpleasant for the MNB, as all service providers holding cash accounts must report the accounts and provide the interface for enforcement. However, WISE was not obliged to do so, which is in direct conflict with the EU PSD2 Regulation (https://eur-lex.europa.eu/legal-content/HU/TXT/?uri=CELEX%3A32015L2366 Article 35). According to this: >>>> >>>> Payment systems may not impose any of the following requirements on payment service providers, payment service users or other payment systems: >>>> >>>> a) rules restricting the effective participation in other payment systems; >>>> >>>> b) a rule that discriminates between authorised payment service providers or registered payment service providers in terms of the rights, obligations or legal titles of their members >>>> >>>> However, the MNB allowed WISE to operate by granting a derogation, meaning that WISE did not have to register the payment account with the Hungarian Tax and Customs Administration and the court of registration, nor did it have to build the interface necessary for implementation. By the way, WISE easily bypasses this if necessary. >>>> >>>> A telephone conversation with Palasikné dr. Dóra Kirschner revealed that she did not understand the directive and the provisions of domestic legislation, she only asked for compliance with the PSD2 conditions, and then with her decision she allowed WISE to enter the domestic market, as a cross-border service provider, but offering a domestic payment account. (In comparison, REVOLUT has a Hungarian branch, but it still provides IBAN accounts starting with LT and the account management does not take place on GIRO's Hungarian servers, unlike the service provided by WISE). >>>> >>>> During the telephone conversation, it also emerged that Palasikné dr. Dóra Kirschner is not aware of the significance of bank account reporting and enforcement, the lack of which may rightfully bother the tax authorities. If WISE had been forced to provide services under the same conditions as domestic market participants, according to the directive, the MNB would have required it to build an interface with the Tax and Customs Administration and the court of registration, thus enabling bank account reporting and electronic enforcement procedures. >>>> >>>> According to the current state of the case - if the scandalous first hearing is not repeated - Judge Dr. László Tóth, who clearly does not have the necessary expertise and does not even know the press rules for conducting the hearing, has refused to turn to the Court of Justice of the European Union. >>>> >>>> For the time being, it does not appear that Judge Dr. László Tóth has understood the well-known fact that the MNB cannot overrule its position set out in an official document, since that would be claiming that the official document contains a false statement or that it would be lyingly keeping quiet about it. What is worrying, however, is that in order to clarify everything, Palasikné Dr. Dóra Kirschner was omitted from being summoned as a witness. >>>> >>>> In the meantime, I pressured the NAV KI Data Collection Department until they organized a meeting, which they also informed about in their letter dated 01.07.2025 with registration number 1704103365. In it, they wrote: >>>> >>>> A consultation was held with the participation of the Hungarian National Bank, GIRO Zrt., and the NAV regarding possible solutions to the problems related to WISE accounts. According to the information provided by the Hungarian National Bank, the WISE accounts – despite having a so-called “virtual” HU IBAN number – as a result of consultations with the Belgian supervisor, they are considered accounts held in Belgium and as such do not meet the requirements for a domestic account. >>>> >>>> Unfortunately, it is not known what exactly was said at this meeting and what lies the NAV brought up in order to push the Brussels bank out of the picture. It is also not known whether the above section of the EU PSD2 regulation even mattered, or whether the negotiating parties were even aware that WISE could not be admitted to the list of providers offering domestic current account (regardless of whether it was cross-border or not), that it had to meet different domestic requirements compared to other market players. >>>> >>>> Incidentally, in this letter the NAV lied that the WISE account was not opened for the purpose of a current account and that WISE did not request the company's documents (it is true). However, WISE did request the documents. The Money Laundering Department has not retracted this lie since. WISE requests documents according to its document corresponding to the GTC, see here: https://wise.com/eu/legal/terms-of-use-business 4.7. >>>> >>>> QUESTION: Do you confirm the (online?) meeting and the position of the Belgian authority, according to which WISE, despite the express provision of the EU regulation, should not comply with Hungarian rules, but can operate its cross-border services in a different way on the market of Hungarian payment account providers? >>>> >>>> Please forward this message to the right persons at the Authority. >>>> >>>> Best regards, >>>> ________________________________________ >>>> Zsolt Ruszin >>>> FairConto Zrt. >>>> >>>> Accounting, Advisory services, Tax Consultancy, TaxNews >>>> Office: 12-14 Könyves Kálmán krt. Budapest H-1097 >>>> 2/a Nefelejcs str., Zalaegerszeg, H-8900 >>>> Tel: +36 1 238-8023 >>>> Mobil: +36 20 922-8470 (+VIBER, WhatsApp, Signal, etc.) >>>> e-mail: zsolt.ruszin@fairconto.hu >>>> WEB: www.fairconto.hu >>> >> >