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investors
TWINO is a Latvian investment platform run from Riga. Its lending group started in 2009 and the investor platform in 2015. The platform's own charts show €1.18 billion invested since launch (24 October 2026), and its 2025 annual report counted about 21,000 registered users at the end of 2025. Today it sells one main product: short-term notes backed by Polish consumer loans.
You pay in euros (first deposit €10) and buy notes from €1, by hand or with auto-invest. Notes run for 3, 6 or 12 months and pay a fixed rate each month. A flexible wallet, FLEXI, pays 6% a year with daily access, from €10 up to €10,000. The notes are issued by SIA TWINO Investments Poland, a small company with €2,800 of share capital, and are paid from consumer loans made in Poland by Fincard (brands Net Credit and Halvo). Fincard, the issuer and TWINO all have the same owner. There is no choice of lender: every note depends on Fincard.
The 12-month notes issued in October 2026 carried an average rate of 11.68% a year (€3.57 million of notes); 6-month notes pay 10% and 3-month notes 8.5%. The home page advertises up to 12%. These are the rates written into the notes, before Latvian tax (5% for most EU investors), not a measured result: TWINO publishes no figure for what investors actually earned. The 12-month rate has eased slightly, from about 12.2% on average in 2024 to 11.4% to 11.7% between June and October 2026. Independent tracking of investor portfolios points to about 11.6% a year (August 2026).
TWINO publishes only one loss-related figure: 4% of the money out on loan was in "pending payment" and 96% was current (24 October 2026). The page does not define "pending payment", and the figure is not a loss rate. Fincard buys loans back from the issuer after 60 days, so late loans leave the figure quickly. In September 2025 the share not performing was about 14%, but that included old Russian and Philippine loans that have since been cleared.
Investors have lost money here before. About €1.3 million invested in Vietnamese loans was lost in 2024 and not covered by the group. Repayments on Russian loans were stopped in March 2022 and the matter took about four and a half years to resolve; the only early way out was a voluntary buyback at 80% of principal, with about €200,000 of cash against €0.8 to 1.0 million of demand, which closed on 27 February 2026. TWINO publishes no default rate, recovery figure or realised loss.
Nothing secures the notes. They are unsecured and limited-recourse: they repay only what flows in from the Polish loans. The offer document states that no collateral, pledge or other guarantee is available to noteholders. Fincard's promise to buy back loans 60 days late runs to the issuing company, not to you. The loans themselves are unsecured consumer loans and credit-card balances. Fincard's own loan losses were 37.1% of its book in 2025. In plain words: you are lending to a company with €2,800 of capital that depends on one Polish lender owned by the same person; payments have been made so far, but you carry that one lender's risk.
One more risk sits with that lender: on 16 June 2026 Poland's consumer protection authority (UOKiK) opened proceedings against Fincard, alleging that its card fees are hidden interest above the legal cap. A fine of up to 10% of turnover is possible.
AS TWINO Investments (Latvia, registration no. 44103143823) holds an investment firm licence from Latvijas Banka, the Bank of Latvia, since 31 August 2021. The notes are offered under a base prospectus approved by the Bank of Latvia on 13 May 2024. TWINO is not a crowdfunding service provider under the EU crowdfunding rules. Your notes are kept apart from TWINO's own assets, and the Latvian investor protection scheme covers up to €20,000 if TWINO itself fails to return them; it does not cover losses on the notes. The platform, the issuer and Fincard share one ultimate owner, Armands Broks.
Registering, paying in, investing, selling to other investors and withdrawing are free. If you make no investment for more than six months, TWINO takes €10 a month from your cash balance (terms of 29 June 2026). Payouts to a non-SEPA account or in another currency carry a commission. Latvian tax is withheld at source: 5% for most EU investors, 20% for Latvian and non-EEA residents.
You get money back as notes mature after 3, 6 or 12 months. Before that, you can sell notes to other TWINO clients on its own market, at a price you set; TWINO is the only place to sell them, and a sale needs a buyer. FLEXI gives daily access, but its terms let it turn into a fixed 12-month lock in a crisis, extendable to 21 months. The Russian loans show how long money can be stuck: four and a half years.
Return: High — new 12-month notes carry 11.68% a year (October 2026), though no measured return is published. Risk: Medium (higher means more risk) — only 4% of the book is pending payment, but we rate it one step worse because every note depends on one related lender now facing a regulator's proceedings, the notes are unsecured and issued by a company with €2,800 of capital, and investors lost money on earlier foreign loan books. Risk-return: High — a rate near 12%, which independent tracking of investor portfolios points to investors actually receiving, for a medium level of risk that rests on one lender.
License / Regulation: AS TWINO Investments holds an investment firm licence (MiFID II) from Latvijas Banka, the Bank of Latvia, valid since 31 August 2021 (register reference 27-55/2025/7). The notes are issued by SIA TWINO Investments Poland under a base prospectus approved by the Bank of Latvia on 13 May 2024. TWINO is not authorised as a crowdfunding service provider. Clients are covered by the Latvian investor protection scheme up to €20,000 if TWINO fails to return their assets; the scheme does not cover losses on the notes.
Yes. AS TWINO Investments holds an investment firm licence from the Bank of Latvia since 31 August 2021, and the notes are sold under a prospectus the Bank of Latvia approved on 13 May 2024. The licence covers how TWINO handles your orders and assets, not whether the loans behind the notes are repaid.
TWINO itself, as a licensed investment firm. Your notes are kept apart from TWINO's own assets, and the Latvian investor protection scheme covers up to €20,000 if TWINO fails to return them. TWINO names no outside bank or payment institution. Uninvested cash earns nothing outside FLEXI.
€1 per note; the first deposit is €10. FLEXI takes from €10 up to €10,000.
New 12-month notes carried an average 11.68% a year in October 2026; 6-month notes pay 10% and 3-month notes 8.5%, before Latvian tax. No realised return is published. TWINO shows 4% of the book as pending payment (24 October 2026) but no default or loss rate. Investors lost about €1.3 million on Vietnamese loans in 2024, and Russian loans were stuck from March 2022 for about four and a half years.
Nothing. The notes are unsecured and repay only what comes in from Fincard's Polish consumer loans; the offer document says no collateral, pledge or guarantee is available to holders. Fincard's 60-day buyback is owed to the issuing company, which has €2,800 of capital, not to you. In practice you rely on Fincard staying able to pay.
Notes repay at the end of their 3, 6 or 12 months. Before that you can try to sell them to other TWINO clients, free of charge, if a buyer is found. FLEXI allows daily withdrawals, but its terms let it switch to a 12-month lock, extendable to 21 months, in a crisis.
None to register, pay in, invest, sell or withdraw in euros by SEPA. After more than six months without investing, TWINO takes €10 a month from your cash. Latvian tax of 5% is withheld for most EU investors (20% for Latvian and non-EEA residents).
If TWINO fails, your notes are kept apart from its assets and the investor scheme covers up to €20,000 of assets it cannot return. If Fincard fails, the notes would repay only what can be collected from the Polish loans, and no guarantee or scheme covers that loss.
All notes depend on Fincard, a Polish consumer lender owned by the same person as TWINO and the issuer, so there is no spread across lenders and no independent party in the chain. On 16 June 2026 Poland's consumer authority opened proceedings against Fincard over its card fees; a fine of up to 10% of turnover is possible.
