A bilingual witness statement describes an alleged “pay-to-borrow” mechanism at First Investment Bank (FIB): a €9.5 million loan tied to a forced €2 million purchaseA bilingual witness statement describes an alleged “pay-to-borrow” mechanism at First Investment Bank (FIB): a €9.5 million loan tied to a forced €2 million purchase

“The Price of the Loan”: A Witness Statement Alleges a €2M Kickback Structure at Collapsed Bulgarian FIB

7 min read

A bilingual witness statement describes an alleged “pay-to-borrow” mechanism at First Investment Bank (FIB): a €9.5 million loan tied to a forced €2 million purchase of a seemingly unrecoverable claim. An insider draft frames the transaction as a deliberate leverage tool in the broader Stoyan Staykov and Regent Capital ecosystem. We map what is alleged, what is verifiable, and what regulators should now demand.

Key Points

  • The witness alleges a loan condition: a €2m “cession purchase” embedded in a €9.5m facility to finance a strategic stake in Terminal Tiger AD.
  • The claim allegedly sold by the bank is described as economically worthless and linked to companies that were insolvent / non-functional; the witness says a senior bank representative allegedly warned: “there is nothing to collect.”
  • After distress and enforcement, pledged assets reportedly ended up at auction with buyers including INSA OIL and AA Consult Ltd;
  • Public context: FIB’s history includes the 2014 bank-run and liquidity-support episode reviewed by EU institutions and the state-aid framework.
  • FinTelegram has previously reported on Stoyan Staykov’s Vienna-centered network, including patterns of sub-10% stakes, nominee layers, and cross-border flows.

The Strategic Investment

The witness statement received by FinTelegram provides a granular look at how First Investment Bank (Fibank), under Executive Director Chavdar Zlatev, allegedly leveraged its position to enforce “extraordinary fraud.”

In January 2018, NSA Bulgaria EOOD (NSA) initiated a formal application with First Investment Bank AD (PIB) for an earmarked loan to facilitate a major cross-border acquisition. The project centered on a capital increase within its subsidiary, NSA Investment EOOD, to fund the purchase of 72% of the shares in Terminal Tiger AD (AO) for EUR 7,350,000. The target company was then held by the Austrian entity E&A Beteiligungs GmbH (E&A).

Regent Capital AD and Logistic Terminal Svilengrad AD (LTS) agreed to serve as co-debtors, pledging their corporate assets as collateral.

According to the witness’s account, the responsible manager at Fibank demanded that NSA Bulgaria take out an additional €2 million loan on top of the loan for the purchase price, which was to be used to purchase an alleged claim from an unknown company. These €2 million then disappeared. The witness assumes fraud and kick-back.

Read our reports on Stoyan Staykov here.

Extended Analysis

1) The Kickback-Pattern

If accurately documented, the mechanism resembles a classic disguised-fee / kickback pattern: the bank conditions credit on a separate purchase of an asset the borrower neither wants nor can value—effectively embedding an extra “charge” into the loan proceeds. That raises immediate issues under basic banking conduct and internal control frameworks (credit committee independence, conflicts of interest, related-party considerations, and audit trail integrity).

From an AML/CFT standpoint, forcing an economically irrational purchase can function as a value transfer whose ultimate beneficiary is opaque—especially if the receivable traces to shells, insolvent entities, or politically exposed structures. The witness explicitly states it remained unclear who economically benefited from the payment.

2) The enforcement endgame: why auctions matter

The witness describes a progression: the borrower struggles; the bank does not substantively engage; then enforcement proceeds via a private enforcement channel (named in the statement), and assets are auctioned. The witness names alleged buyers and links them to broader political/legal networks—exactly the kind of downstream “asset capture” pattern compliance teams should scrutinize: who financed the auction bids, which accounts were used, and whether any counterparties were screened as PEP-adjacent.

3) Regent Capital: The Strategic Lever

The role of Regent Capital AD and its ultimate driver, Stoyan Staykov, is central to this architecture. Regent Capital acted as a co-debtor and “hinge” in the transaction. Our analysis suggests Regent Capital was not a mere participant but a “pressure amplifier” used to secure the loan’s approval while simultaneously burdening the borrower with the €2 million “fee”. This aligns with Staykov’s established reputation as a “power broker” who operates in the grey zones between Bulgarian banking interests and international financial structures.

4) Why this lands harder in the FIB context

FIB is not a random small lender: it has a long public history that includes the June 2014 bank run and subsequent state liquidity support reviewed under EU state-aid rules.
And while this does not validate the witness allegations, it increases the public-interest threshold for transparency about governance and credit practices.

Notably, FIB disclosed that Chavdar Zlatev was dismissed as Executive Director and Management Board member effective October 2024.

The Vienna Connection: Alpha Bulgaria and Vienna Privatbank

Stoyan Staykov’s activities are not confined to Bulgaria. FinTelegram has previously exposed his deep-rooted ties to Vienna and Cyprus, often linked to suspected money laundering operations.

  • Alpha Bulgaria & Wiener Privatbank: Staykov was a key figure behind Alpha Bulgaria, which famously sought to acquire a significant stake in Wiener Privatbank (report here). This move was viewed by compliance experts as a strategic attempt to gain a foothold in the EU banking system, potentially to facilitate the movement of “grey” capital from the Balkans.
  • The Pattern: The Fibank “kickback” scheme fits the broader pattern of Staykov’s operations: using corporate vehicles (like Alpha Bulgaria or Regent Capital) to interface with established banks, creating complex layers of debt and receivables that obscure the true destination of funds.

Conclusion and Risk Assessment

The testimony is an “exceptional” piece of evidence. It describes a “kickback mechanism” where €2 million of loan tranches were immediately diverted into a pre-signed, illegitimate cession agreement. The fact that the eventual beneficiaries of the subsequent public sale of the pledged assets were entities linked to Delyan Peevski and Aleksandar Angelov further suggests that this could have been a coordinated “asset-stripping” operation enabled by the bank.

Summarizing Table

The following table summarizes the key individuals and legal entities identified in the witness statement and the analysis of the Stoyan Staykov and First Investment Bank (Fibank) case.

Entity / IndividualJurisdictionRole / Description
Stoyan StaykovBulgaria / AustriaAlleged central power broker and “ultimate driver” behind the corporate network.
First Investment Bank (PIB)/FibankBulgariaThe lender accused of enforcing an illegitimate “cession agreement” as a condition for a loan.
Chavdar ZlatevBulgariaExecutive Director of Fibank; allegedly dictated the extortionate loan conditions.
Regent Capital ADBulgariaA company linked to Staykov; acted as a co-debtor and strategic “hinge” for the loan.
NSA Bulgaria / NSA InvestmentBulgariaThe borrowing entities forced into the EUR 2 million “kickback” transaction.
Terminal Tiger AD (AO)Russia / BulgariaThe target company of the acquisition financed by the loan.
E&A Beteiligungs GmbHAustriaThe parent company of Terminal Tiger AD and seller of the shares.
PST Group EADBulgariaOne of the “insolvent” companies from which the borrower was forced to buy a claim.
Patishta Stara Zagora EADBulgariaThe second insolvent company involved in the allegedly fraudulent claim purchase.
Logistic Terminal Svilengrad (LTS)BulgariaA co-debtor for the bank loan.
Stoyan YakimovBulgariaPrivate enforcement agent (bailiff) who handled the public sale of the pledged assets.
AA Consult Ltd. / Aleksandar AngelovBulgariaWinners of the public sale; Angelov is noted as a lawyer for Delyan Peevski.
Alpha BulgariaBulgariaA vehicle used by Staykov in an attempt to acquire a stake in Vienna Privatbank.

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Call for Information

If you have information regarding Stoyan Staykov, Regent Capital AD, or the inner workings of First Investment Bank (Fibank), we want to hear from you. Help us expose the networks facilitating money laundering between Sofia, Vienna, and Cyprus.

Share your information safely and anonymously via our whistleblower platform, Whistle42.

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