TWINO AI Overview on 09/2025

TWINO Investment Platform Overview 🚀

TWINO is a Latvian-based alternative investment marketplace connecting retail investors with consumer lending opportunities and other assets. Founded in 2015 (as part of the TWINO Group established 2009), the platform allows Europeans to invest in loans issued by TWINO’s own lending subsidiaries and, more recently, in short-term rental real estate projects.

Investors fund fractions of unsecured personal loans – primarily in Poland – and earn interest typically around 8–12% per annum. TWINO operates under a fully regulated structure: it obtained an investment brokerage license in August 2021 and is supervised by Latvia’s Financial and Capital Market Commission (now under Latvijas Banka).

Key Advantages: The platform offers high-yield, short-term investments with a low entry barrier (minimum €10) and features like auto-invest and a buyback obligation that can protect investors from borrower defaults.

Main Risks: Despite the safeguards, investors face credit risk of TWINO’s loan originators (the lending companies), regulatory risk (as seen with recent legal changes in Poland), and concentration risk because TWINO’s current loans are largely from a single market. Past challenges – such as loan losses in Russia and Asia – underline the importance of due diligence and cautious optimism when using TWINO ⚠️.

TWINO Investment Products and Model 💰

TWINO  Product Offering
TWINO provides two investment products: Loan Securities (asset-backed notes tied to consumer loans) and Real Estate Securities (equity-like shares in rental property companies). The core offering is short-term personal loans, originated by TWINO’s affiliated lending companies in markets like Poland, which are packaged into securities for investors. When you invest in TWINO’s Loan Securities, you are effectively purchasing claim rights to portions of loans that have already been issued to borrowers by TWINO’s microfinance subsidiaries. In practice, this means investors’ money finances the loan originators (who then lend to end borrowers) and in return investors receive interest payments funded by the borrowers’ repayments. Most loans are unsecured consumer credits with typical durations from 1 to 12 months, and advertised annual returns range roughly from 8% up to 14%, depending on loan term and risk. TWINO introduced real estate investments in 2022–2023, allowing investors to buy shares of companies owning short-term rental properties – these pay out rental income and potential capital gains from property sales, akin to an equity crowdfunding model.

How Returns are Generated on TWINO 
For the loan investments, returns come from borrower interest payments on the underlying loans. Borrowers often pay high interest (annualized rates can exceed 40% for short-term credit), which covers the yield paid to investors (around 10–12% on average) and leaves a margin for TWINO and its loan originators. TWINO’s real estate projects generate returns through rental income streams; investors receive periodic dividends or profit share from rental revenues and a portion of any appreciation upon the property’s sale.

Legal & Structural Setup of TWINO 
As a licensed investment broker, AS TWINO Investments issues the financial instruments (notes or securities) to investors. When investing in a loan, the investor buys a note that is backed by a claim against the loan originator for the amount of the loan. All TWINO loan originators contractually commit to a Buyback obligation – if a borrower is overdue beyond a set period (usually 30 days), the originator must repurchase the debt and repay the investor’s principal (often including accrued interest). This mechanism, while not an insurance policy, functions as an internal guarantee of sorts, shifting default risk from the investor to the originator. For real estate deals, investors purchase equity-like securities; legally, this makes them entitled to a share of profits from the property-holding company rather than a fixed interest stream. TWINO’s operations are conducted online via its Latvian entity, and it passports its investment services across the European Economic Area so EU/EEA retail investors can participate.

Focus and Limits on TWINO 
Historically, TWINO’s loans spanned multiple countries (including Latvia, Russia, Kazakhstan, Georgia, Poland, etc.), but as of 2024–2025 the focus has narrowed to Poland and select new markets (earlier expansions to Asia have been wound down). The platform currently specializes in unsecured consumer loans (such as short-term credit lines and payday loans in Poland) and a few real estate rental projects in its home region. By regulation, only investors from approved countries (primarily EU/EEA) can invest, and all investments are denominated in Euro (though TWINO also supports investing via GBP accounts, it converts to EUR internally). The minimum investment is just €10 per loan or per real estate project share, making diversification accessible even with small capital. There is no fixed maximum per investor on the platform, aside from regulatory limits to prevent money laundering; investors can essentially invest as much as the available loan supply allows. Typical loan tenors are short (1–3 months for many Polish credit line receivables), and even the longer installment loans rarely exceed 1–2 years on TWINO, which means your money isn’t locked for long periods. Real estate securities may have longer horizons (e.g. 6–24 months target holding period), but TWINO has introduced a secondary market to provide liquidity.

Risk Considerations on TWINO 
Major risk factors include borrower default risk (mitigated by the buyback obligation – if a borrower doesn’t pay, the originator is supposed to cover it), originator solvency risk (the loan originator might fail to honor the buyback if it becomes insolvent or illiquid, leading to investor losses), illiquidity (especially for real estate investments which can’t be exited until project completion, although a secondary market is now available for those), and foreign market risks (loans are in various countries and subject to local economic and regulatory conditions – e.g. currency fluctuations or legal changes could affect returns). It’s important to note that all TWINO originators are part of the TWINO Group, which on one hand provides a level of oversight and alignment, but on the other hand may pose a transparency and conflict of interest risk since the platform is effectively financing its own sister companies. In a worst-case scenario (e.g. a loan originator or the platform itself going bankrupt), investors could face delays or losses in recovering their funds – including a potential total loss if neither the originator nor TWINO can fulfill obligations. Therefore, while TWINO’s model offers high yields and promises like buyback, it is not risk-free – investors remain reliant on the financial health and integrity of the TWINO Group entities.

TWINO Company Background and Structure 🏢

Founding and Ownership of TWINO
TWINO was founded by Armands Broks, a Latvian entrepreneur who launched the initial lending business in 2009 and then the TWINO peer-to-peer platform in 2015. Broks remains the principal owner and is Chairman of the Supervisory Board, actively guiding strategy. Over the years, TWINO has grown from a small startup in Riga into an international fintech group. The company has stayed largely privately held; there have been no major venture capital rounds disclosed, meaning Broks and insider shareholders maintain control. In the late 2010s, there were attempts to restructure and improve finances (after early rapid expansion led to losses), but no change in ultimate ownership occurred – the founder continues to back the platform.

Management Team of TWINO
TWINO’s leadership combines fintech experience and risk management expertise. Currently, Nauris Bloks serves as Chief Executive Officer (CEO), focusing on strategic growth, product development, and ensuring regulatory compliance. The Supervisory Board includes founder Armands Broks and independent members like Mārtiņš Mellēns (a former McKinsey private equity expert) who bring global investment perspective. A dedicated Risk Director (Māris Čevers) oversees risk control and compliance across the group, reflecting TWINO’s emphasis on tightening oversight post-licensing. Other key figures include Artūrs Cekuliņš (Head of Legal & AML) and Helvijs Henšelis (Board member with background from Deloitte/PwC). Earlier, the company’s CEO was Anastasija Oļeiņika, who led the push to become regulated – she remains involved on the Board and is often the public face of TWINO’s regulatory success. The relatively frequent management changes and appointments (noted by industry observers) indicate that TWINO has been adapting its leadership as it evolves – for example, adding seasoned professionals in compliance and risk after receiving its license, which is viewed positively for governance.

Partners and Backers of TWINO
TWINO’s expansion has involved strategic partnerships rather than equity investors. In 2019–2020, TWINO entered a joint venture with VIA SMS Group (another Latvian fintech) to launch lending operations in Asia (the Vamo brand). This 50/50 partnership combined resources to test emerging markets like Vietnam and the Philippines. While the venture initially signaled strong collaboration between two leading Baltic lenders, it was ultimately dissolved in 2024 due to regulatory clampdowns in Vietnam (more on that in “Negative Publicity”). TWINO has also collaborated with industry organizations: it has engaged with regulators via the local fintech association and even ran a startup pitch competition in 2021 with a VC fund (Expansion Capital) to foster innovation. As a result of its regulated status, TWINO now partners with banks and payment institutions for operational needs (for example, Fincard in Poland, detailed below, which is effectively part of the group). It does not rely on external guarantors or insurance companies; instead, the platform’s “partners” are mainly its own subsidiaries and the infrastructure supporting its investments (like property management firms for real estate projects).

TWINO Group Structure and Subsidiaries
The platform is operated by AS TWINO Investments, a joint-stock company in Latvia (registration no. 44103143823). This entity is the licensed investment broker that interfaces with investors. Under the TWINO Group umbrella, there are multiple lending subsidiaries (often referred to as loan originators). Notable ones include: Net Credit Sp. z o.o. in Poland (branded as NetCredit/FinCard), which issues consumer loans and credit lines; TWINO’s former Russian lending arm (which had issued loans in rubles until 2022); and the now-exited Vamo ventures in Asia (Vietnam and Philippines). The holding structure was reorganized around 2021 – TWINO created FINNO as a holding company for its international operations, and FINNO in turn owns entities like FinCard in Poland. All these subsidiaries are ultimately owned by Armands Broks as the Ultimate Beneficial Owner. TWINO’s legal structure ensures the platform itself doesn’t lend money; instead, it distributes investor funds to these subsidiaries by purchasing loan receivables, and those subsidiaries lend to end-users. This separation was crucial to obtain the EU investment firm license, but practically, the group functions as one integrated company offering lending and investing.

Regulation and Licenses of TWINO
TWINO is fully regulated as an investment firm in the EU. It secured its Investment Brokerage Firm (IBF) license on 31 August 2021 from Latvia’s FCMC, after over a year of preparation. This license (No. 06.06.08.720/536) authorizes TWINO to provide investment services such as arranging investments, executing orders, and holding client assets across the European Union. TWINO is supervised by the Latvijas Banka (Bank of Latvia, which merged with the FCMC in 2023) and must comply with MiFID II investor protection rules. The firm has passported its services to at least 11 EU countries as of 2022–2023, meaning it legally can market and accept investors from those jurisdictions. Investors on TWINO benefit from regulatory safeguards like the Investor Compensation Scheme: if TWINO were to fail, clients could claim 90% of any unrecoverable investment losses up to €20,000 under Latvian law. In terms of lending licenses, TWINO’s originator companies are locally regulated as lenders (e.g. NetCredit in Poland is a licensed loan company and now also operates under a Polish National Payment Institution license via FinCard). There is no EU-wide crowdfunding regulation involved (TWINO opted for the investment firm route instead of the ECSP crowdfunding regime). Supervisory Authorities to note: Latvijas Banka oversees TWINO’s investment activities; additionally, in Poland the KNF (Polish Financial Supervision Authority) indirectly influences TWINO by regulating the consumer credit sector and the payment institution FinCard. TWINO has to adhere to anti-money laundering (AML) laws and report to regulators regularly – its compliance and legal teams handle ongoing audits and disclosures.

TWINO Funding Volumes and Performance Metrics 📊

Total Funded Volume of TWINO
Since its inception, TWINO has facilitated a cumulative investment volume of over €1 billion in loans. This milestone was reached around 2020, and the platform has continued growing modestly – by mid-2025, cumulative funded loans likely exceed €1.1–1.2 billion. It’s worth noting that TWINO’s figures often count every loan turnover (the platform historically dealt in many short-term loans, which inflate cumulative totals as loans are reinvested). In the last few years, TWINO’s active loan portfolio (outstanding at any given time) has been in the tens of millions of euros. For example, in September 2025 the outstanding loans on TWINO were around €36.4 million, of which ~€31.3m were current and ~€5.1m in default status (in recovery). This indicates the platform’s active size and the portion of loans facing issues at that time (~14% non-performing).

Investors and User Base of TWINO
TWINO has a broad retail investor base primarily across Europe. As of 2025, it reports over 60,000 registered investors from more than 30 countries. (In early 2022, this figure was ~50k users, showing growth in the past few years despite market turbulence.) Out of these, a significant subset are active investors currently investing. For instance, more than 30,000 investors have actually put money to work through TWINO and earned returns since launch. The average portfolio size per investor is relatively small (~€2,000 average as per third-party data), implying a lot of users are testing the platform with modest sums, which aligns with TWINO’s retail focus.

Returns to Investors on TWINO
The platform’s allure has been high yields. TWINO advertises average annual returns around 10–12%, and many long-time users have indeed achieved returns in this range. Since 2015, TWINO has paid out over €25 million in interest to investors in total. This figure (as of mid-2025) underscores the income generated for users. The typical net return will depend on portfolio composition: Polish short-term loans currently yield ~12% p.a., while any remaining long-term or real estate investments might yield slightly less or include capital gain potential. TWINO sometimes runs promotions (e.g. cashback bonuses) to boost effective yields for new investments. According to the platform, investors have historically earned double-digit returns consistently, though actual results vary. There is no formal “maximum” return cap, but practically interest rates rarely exceed 14% on TWINO these days. Some early investors who took currency risk (e.g. investing in Russian ruble loans in the past) briefly saw higher interest offers (~15%+), but currently everything is EUR-based.

Loan Performance and Defaults on TWINO
Officially, TWINO maintained a very low default rate for investors for many years thanks to the buyback guarantee (defaulted loans were repurchased by originators, so investors didn’t incur loss on those). TWINO’s website shows that the vast majority of loans on the platform are either current or in short-term delay, with only a tiny fraction marked as defaulted at any time. However, this can be misleading because once a loan goes into serious default, it’s taken back by the originator. When looking at the whole TWINO Group’s books, non-performing loans have been significant – for example, at the end of 2017 about 41% of the group’s loan portfolio was past due or impaired. This high underlying default level was covered by group capital and the buyback mechanism rather than passed to investors at the time. In recent stats, TWINO itself revealed about 13.9% of its active loan volume was in “recovery” (default) as of September 2025. This suggests that while investors might not immediately feel those defaults (as long as originators honor buyback), there is a considerable portion of loans that do go bad.

Investor Returns and Losses on TWINO
To date, most investors have not experienced principal loss on TWINO under normal operations, because of the buyback commitments. The platform until 2022 could boast that no investor lost money from a borrower default. However, extraordinary events have led to some losses or frozen funds:

• Russian Loan Freeze (2022): After Russia’s invasion of Ukraine, TWINO’s Russian lending subsidiary was unable to transfer borrower repayments out due to currency controls and sanctions. Around €4 million of investor funds became stuck in Russian loans. TWINO has been unable to fully recover these funds, leaving a portion of investors in limbo (they still see those investments on their account, but can’t withdraw them). This is effectively a loss unless the situation resolves.

• Asian Market Exit (2024): When TWINO exited Vietnam and Philippines, the Vietnamese loan portfolio collapsed. By July 2024, TWINO disclosed that its Vietnamese originator defaulted, causing an estimated €1.3 million loss that would be borne by investors if not recovered. It remains uncertain how much will be recouped from that market wind-down.

Despite these hits, TWINO’s overall investor ROI since inception remains positive on average. Some long-term investors (e.g. those who avoided the problematic markets) report earning 10%+ yearly over 5+ years. TWINO itself highlights success cases of consistent returns even through economic cycles. For instance, many investors stuck to Polish loans only (which have performed as expected with buybacks working) and they did not lose money from the turbulent events elsewhere.

Operational Financial Results of TWINO
On a company level, TWINO’s financial performance has been mixed. It posted heavy losses during its aggressive expansion phase (losing €12.2 million in 2017 for example), and had negative equity by 2018. This prompted cost-cutting and restructuring (closing subsidiaries in Spain, Mexico, etc.). By 2018–2019 the group swung to profitability; the lending operations generated €13 million profit before tax in 2018. More recently, due to war disruptions and pivoting business models, TWINO again faced challenges – its 2023 audited report showed a net loss (the platform was not profitable in 2023 largely due to one-time hits and restructuring costs). However, there was a turnaround: in 2024 TWINO returned to profit, thanks to the booming Poland business. The Polish arm (NetCredit/Fincard) recorded €7.27 million net profit in 2023 and continued strong in 2024, which flows up to the group income. The platform entity itself made a modest profit of around €0.36 million in 2024. These results signal that TWINO’s current model – though highly concentrated – is financially viable for now. It’s crucial for investors to monitor these figures, as a platform’s profitability affects its sustainability and ability to cover guarantees. TWINO publishes annual reports on its site and provides key figures in its blog/news to maintain transparency for investors.

TWINO’s Approach to Risk Management 🛡️

TWINO emphasizes a multi-layered risk management approach, given the inherent risks of unsecured lending. Here’s how the platform manages and mitigates risk:

Loan Selection & Underwriting
All loans available on TWINO are originated by its sister lending companies, which apply their own credit scoring models and underwriting criteria. TWINO’s originators focus on short-term consumer loans with relatively small principal amounts, which spreads risk across many borrowers. For example, in Poland the NetCredit/Fincard operation uses advanced algorithms and customer data to assign credit limits and interest rates to borrowers – only those meeting certain creditworthiness thresholds receive loans. TWINO’s management has stated that they continuously monitor and adjust credit issuance rules to maintain a healthy portfolio. In 2023, the Polish lender tightened lending criteria and improved automation, resulting in lower default rates and an award-winning credit product (indicating robust underwriting). Borrowers typically need to have stable income and pass identity and affordability checks, and lending in each market must comply with local responsible lending regulations (e.g. interest caps, debt-to-income limits where applicable).

Due Diligence on Projects
Since TWINO largely funds its own loan books, “project selection” is about which loan portfolios to offer to investors. The platform performs due diligence on any new loan originator before adding them – in practice, all current originators are within the TWINO Group, so this is an internal vetting process. In the past, TWINO did onboard third-party loans (for instance, in 2019 it listed some loans from external partner lenders), but now it sticks to affiliated originators to maintain control. Before launching the real estate investments, TWINO vetted those property projects for viability: for instance, Dainas (a rental apartment project introduced in 2024) was carefully reviewed for rental yield potential and was offered only after meeting TWINO’s criteria for asset-backed deals. While detailed credit risk metrics are not public, TWINO likely requires that each loan originator maintains certain portfolio quality standards (e.g. maximum default rate or sufficient equity buffer) to continue listing loans. The platform’s risk team, led by the Risk Director, oversees these standards and can halt new funding to an originator if concerns arise. We saw this in action when TWINO stopped offering loans from its Vietnam and Philippines originators in early 2024, once regulatory changes increased risk – a proactive risk decision to protect investors.

Internal Risk Scoring
TWINO does not present a simple risk score for each loan to investors (unlike some P2P sites that grade loans A, B, C, etc.). Instead, virtually all loans on TWINO come with a Buyback commitment and are considered similar in risk profile (backed by group affiliates). However, the platform indirectly signals risk by interest rate – higher rates imply higher risk markets or products. For example, Polish short-term loans currently around 12% are considered moderate risk, whereas in the past a Russian or Kazakh loan yielding 15%+ indicated a higher risk (and indeed those carried currency and geopolitical risk). TWINO’s team monitors macro and regulatory developments closely and will adjust availability or rates accordingly. They also track each originator’s financial health. It’s known that TWINO Group had to recapitalize or shut down some underperforming lending units in 2017–2018 – since then, they impose stricter oversight. The platform might not share a numeric “risk score” with users, but it shares monthly performance updates for each major loan originator (for instance, updates on NetCredit’s portfolio growth, default levels, etc.), which helps investors gauge risk.

Diversification and Limits
To help investors manage risk, TWINO provides auto-diversification tools. The Auto-Invest feature can spread your investments across all available loans, ensuring you’re not overly exposed to a single loan. However, given TWINO’s current concentration (mostly one originator in one country), diversification on-platform is limited. TWINO does enforce some limits per loan or borrower – an investor cannot put more than a certain amount into one loan (usually capped at €50 or €100 per loan piece, depending on loan size). This way, even large investors end up holding a granular portfolio of many small loans, reducing the impact of any single default. At the originator level, historically investors could choose which countries to invest in. Now with mainly Poland loans on offer, diversification is more about mixing loan terms (some 1-month, some longer) or including real estate projects for asset mix. TWINO’s advice to users is to utilize auto-invest and reinvest interest to maximize compound returns while managing exposure. The platform’s FAQ and help center also educate investors on not putting all funds in one project and being mindful of their liquidity needs.

Monitoring and Reporting
TWINO maintains an active communication with investors regarding risk. They publish portfolio quality reports and financial results on their blog (for instance, quarterly updates on NetCredit’s performance and any changes in local regulations). This transparency allows investors to see trends like default rates, recovery rates, and profitability of the originators. The company’s risk management team monitors collections and buyback fulfillment daily – if a loan originator were to fall behind on honoring buybacks, TWINO would likely freeze new investments for that originator (similar to how other marketplaces handle troubled originators). There is evidence TWINO took action during crises: e.g., when war broke out, they segregated Russian assets and ceased new funding to contain the issue; when Vietnam’s regulatory environment turned hostile, they decided to exit rather than accumulate further risk. Additionally, TWINO as a regulated entity must report risk metrics like capital adequacy to the regulator. As of 2024, TWINO had a capital adequacy ratio of 196%, well above requirements, meaning it has a strong capital buffer for its size. This is a reassuring sign that the platform can absorb some shocks.

Summary
TWINO’s risk management has improved with regulation – there’s greater transparency and a formal structure. However, external reviewers note that some risk management choices have been questionable (e.g. staying in very high-risk markets too long). The lesson for investors is to leverage TWINO’s data and diversify not just within TWINO but also across different platforms and markets. TWINO provides the tools and information, but each investor should remain vigilant and update their strategy if risk signals change 🚨.

TWINO Platform Functionality and Features 🖥️

TWINO offers a modern, user-friendly platform with a range of features designed to make investing easy and efficient for retail users. Here are the key functionalities:

Account Dashboard
Upon logging in, investors see a dashboard summarizing their portfolio – total invested, available cash, interest earned to date, and a breakdown of investments. The interface is generally intuitive, showing current loans, any delayed loans, and amounts scheduled to be repaid in the coming days. Investors have reported that the platform is relatively simple and easy to navigate, though a few have found it somewhat clunky or dated in design. Over the years, TWINO has made improvements (e.g. client profile enhancements in 2023 for a better user experience). The website is available in English, German, and Latvian languages for both the interface and customer support, catering to its diverse user base. Account statements and detailed loan lists can be downloaded for personal record-keeping or tax purposes.

Auto-Invest Tool
One of TWINO’s most popular features is Auto-Invest, which allows truly passive investing. Users can set up an auto-invest strategy by specifying parameters like minimum/maximum interest rate, loan term, and portfolio share per loan. Given the current limited loan selection, many investors simply enable auto-invest to grab any available loans (to avoid idle cash). Auto-invest can be toggled on/off easily, and TWINO executes orders in real-time as new loans come to the market. This ensures high funds utilization – investor money isn’t sitting uninvested for long. For instance, as soon as a borrower in Poland takes a new loan, the platform automatically allocates it to investors via their auto-invest queues. This feature is crucial because loans can be short-term and repay quickly; auto-invest helps reinvest returns and maintain the target yield without constant manual intervention. The minimum investment per loan is only €10, so even €100 can be split across 10 loans with auto-invest for diversification.

Secondary Market
In August 2023, TWINO introduced a Secondary Market for its real estate backed securities. This was a significant addition because real estate projects might last many months, and investors wanted a way to exit earlier. Through the secondary market, investors can list their Real Estate Securities for sale to other users, potentially providing liquidity before project end. The secondary market is peer-to-peer: sellers set a price (often at par or slight discount/premium relative to remaining claim). Buyers can browse available offerings and purchase them similarly to any investment. There’s currently no secondary market fee for investors, making it a flexible exit route. As for Loan investments, TWINO historically did not offer a secondary market because loans were so short-term (and previously structured as assignment agreements). However, since the transition to securities, TWINO has indicated it may extend secondary trading to loan notes as well. Some evidence suggests that internally TWINO can facilitate loan note transfers, but for now the public secondary marketplace is mainly for real estate deals. The liquidity on the secondary market depends on other investors – given TWINO’s moderate size, larger sales might take time to find buyers. Nevertheless, having this feature is a plus for those who value flexibility.

Automated & Mobile Access
TWINO provides both a web platform and mobile apps. There is an official TWINO mobile app for iOS and Android (introduced around 2022). The app allows investors to monitor their portfolio on the go, receive push notifications for incoming payments or new available loans, and even execute investments or withdrawals. User feedback on the app is mixed; it covers basic functionality well, but some advanced settings (like detailed auto-invest configuration) might require using the web interface. Still, the presence of an app puts TWINO on par with larger platforms and caters to today’s mobile-first users.

Portfolio Reports and Analytics
The platform includes simple analytics showing your portfolio distribution (by loan originator, by country, by remaining term). For example, an investor can see that 100% of their loans are currently in Poland, or that X% are due within 1 month, etc. TWINO also provides transaction history and profit calculations. At any time, you can see accrued interest, interest paid, and your account’s net annual return. This helps investors track performance. Additionally, TWINO sends out monthly newsletters and account summaries to keep investors informed of platform news and their own progress.

Multi-Currency Support
While all investments are denominated in EUR, TWINO supports funding your account in multiple currencies. Notably, they allow UK investors or others to deposit and withdraw in GBP – the platform has a conversion mechanism or separate account for GBP which then converts to EUR for actual investing. There are no extra fees for currency conversion beyond the exchange rate (TWINO’s terms indicate they provide FX as an ancillary service, likely at a fair rate). This is convenient for British investors avoiding exchange charges externally.

Security and Account Protection
As a regulated platform, TWINO implements security features like two-factor authentication (2FA) for logins and withdrawals (investors can activate SMS or app-based 2FA to protect their account). Funds are held in segregated client accounts. When you deposit money, it goes into a client bank account designated for TWINO investors, separate from the company’s own funds, in compliance with MiFID regulations. Withdrawal requests are processed typically within 1–2 business days back to your linked bank account.

Investor Tools and Guarantees
TWINO’s hallmark feature for loans is the Buyback Guarantee / Payment Guarantee. Specifically, loans come with an obligation that if a borrower is more than 30 days late, the originator will buy back the loan and the investor receives their principal plus accrued interest (Payment Guarantee means the investor doesn’t lose out on interest for the delay period). This effectively shields investors from individual loan defaults – and in practice, investors see very smooth returns as long as the originator honors these guarantees. The platform clearly labels which loans have these guarantees (currently, all consumer loans on offer do). It’s a passive feature, so investors don’t need to do anything; any delayed loan automatically triggers a buyback credit to the investor’s account when due.

Value-Added Features
TWINO periodically launches promo campaigns – e.g., a Cashback Bonus (in May 2023 they offered a €20 bonus for investing €500 within a period). There’s also an affiliate referral program where inviting new investors can earn you bonuses. For more savvy investors, while TWINO doesn’t have in-depth third-party research on each loan, it does share loan originator financials. The platform’s Financials page provides annual reports and key ratios, so those wanting to assess risk can delve into those documents. Furthermore, external sites (like independent blogs and P2P rating services) provide analysis which TWINO often acknowledges or responds to.

User Experience and Support
Investing on TWINO is meant to be straightforward – one user described it as “simple, understandable, and investor-friendly, with multiple levels of protection mechanisms.” Onboarding (KYC verification) is done online by uploading ID documents, and account creation takes only a few minutes. Customer support is available on business days in multiple languages, and users can contact them via email or an in-platform message center. Support responsiveness is generally good, although a few investors noted that complex queries (especially during crises like the Russia issue) took longer to get a response or resolution. Overall, TWINO’s platform functionality covers all the basics expected from a top-tier P2P lending site: automation, liquidity options, clear reporting, and a decent user interface. The addition of new features like the secondary market and mobile app in recent years shows that TWINO is continuing to enhance its service to meet investor needs.

TWINO Fee Structure and Pricing Transparency 💡

One of TWINO’s attractive aspects is its low fees – in fact, for investors the platform is essentially fee-free. TWINO follows a common P2P marketplace model where the borrowers/originators pay the fees, not the lenders. Here’s a breakdown of the pricing:

Fees for Investors

• Account Opening: Free. There is no charge to sign up or create an account on TWINO.

• Deposits: Free. Adding funds via bank transfer (or other supported methods) costs nothing – TWINO does not levy any deposit fee. (Do note that if you send a non-EUR currency, your bank’s FX conversion might apply, but TWINO itself doesn’t charge a conversion fee on incoming funds beyond possibly a small spread).

• Investing/Buying Loans: Free. There are no transaction fees or commissions taken from investors when they invest in a loan or securities. If you invest €100, the full €100 goes to work earning interest, with no cut taken.

• Platform Service: No ongoing fees. TWINO does not charge account maintenance or management fees. Whether you have an active portfolio or not, there’s no monthly charge.

• Withdrawals: Free. You can withdraw your available cash balance back to your bank at no cost. TWINO processes withdrawals swiftly (usually within 1–2 days) and doesn’t impose any fee or percentage on the amount.

• Secondary Market Selling: Currently free. If you sell an investment on the secondary market, TWINO does not charge a fee for that transaction either (some platforms charge ~0.5–1% for secondary sales, but TWINO’s secondary market is free for now, encouraging liquidity).

In summary, retail investors on TWINO can effectively use the platform without any direct costs eating into their returns. This means the gross interest rate you see on loans (e.g. 10% p.a.) is what you earn, aside from any applicable taxes.

Fees for Borrowers/Originators
TWINO makes money from the borrowers and loan originators. When a borrower takes a loan via a TWINO originator (e.g. €300 short-term loan in Poland), they are charged interest and possibly fees as part of their repayment. These costs for the borrower can be quite high (annual percentage rates often in the dozens of percent). From those proceeds, the originator pays a commission to TWINO for raising the funds. According to TWINO, the commission from originators is sufficient to cover all platform costs and profit, allowing them to provide services free to investors. The exact commission structure isn’t publicly disclosed in detail (since it’s internal), but independent analysis suggests that roughly 30–40% of the borrower’s interest might go to TWINO. For example, if a borrower pays ~42% APR on a loan, an investor might get ~12%, while TWINO (and its owner via the originator) retains the remaining ~30% as revenue and profit. This split covers operational expenses (tech, support, licenses) and risk (buyback obligations) and yields a margin for the company.

For the newer real estate projects, TWINO likely charges the project company a fee or takes a profit share for facilitating the investment. The platform might take an arrangement fee from the property developer or a small cut of rental income before distributing to investors, but again, investors see their returns net with no additional fees.

Transparency of Pricing
TWINO is upfront about its no-fee policy for investors – its Fee page explicitly lists all investor activities as free. It also transparently states that it earns commissions from the issuers (loan originators) instead. However, the platform does not publicly break down the interest margin or how much each originator pays TWINO. For most investors, this isn’t a critical detail, but advanced users might like to know how sustainable the model is (e.g. if TWINO takes too large a cut, could originators struggle?). According to 2023 financial data, the Polish originator (FinCard) had a 22% profit margin after paying all expenses including TWINO’s share, indicating the fee arrangement still left it profitable.

There are no hidden fees like subscription costs, and TWINO doesn’t charge performance fees either – you keep all interest earned. If an investor’s loan defaults and triggers buyback, there’s no fee for that process; if anything, that cost is indirectly borne by the originator. TWINO also doesn’t charge currency exchange fees on its end – if you choose to invest in GBP and they convert to EUR, the rate is given and is likely close to market (with any small spread being standard). They even list foreign exchange service as an ancillary service they provide under their license, which implies they handle it in compliance with regulation.

Fees for Fundraisers
Since TWINO’s fundraisers are its own sister companies, we don’t have a public schedule of charges. Typically, a third-party loan originator might pay a 3–5% funding fee plus a servicing fee. In TWINO’s case, one part of the company pays the other. Effectively, the loan originator pays TWINO a fee for each loan funded. Additionally, because TWINO now issues securities, there could be costs for preparing prospectuses or information documents – these costs are likely absorbed by TWINO (and thus indirectly by the originators as part of the commission). When TWINO launched asset-backed securities in 2022, it mentioned additional documentation and compliance, but it did not introduce any investor fees, indicating the costs were built into their business model.

Tax Considerations
(Not a fee, but related to net returns) TWINO, being based in Latvia, is required to withhold a withholding tax (WHT) on interest earnings for investors. This is not a platform fee, but it does affect what you keep. For EEA residents, the WHT is only 5% (a reduced treaty rate), whereas for others it could be up to 25% by default. Investors can reclaim or reduce this by providing tax residency certificates. It’s important to be aware of this so you’re not caught off guard by a tax deduction on your interest – again, this isn’t TWINO charging you, it’s Latvian tax law. TWINO’s FAQ and support assist investors in handling the paperwork to get the lowest applicable tax rate.

Comparison to Competitors
Compared to many P2P and crowdfunding platforms, TWINO’s fee structure is very favorable to investors. Some competitors charge an annual management fee (say 1%) or take a cut of interest or have fees for selling on secondary markets – TWINO has none of those for the end user. This means more of the yield stays in your pocket. The trade-off is that TWINO and its originators make their money from borrowers, who pay relatively high costs. As an investor, one should consider that the high borrower APRs, while common in short-term lending, are part of the model that enables our returns and TWINO’s revenue – it’s sustainable as long as borrowers can and do repay.

Overall
TWINO’s pricing model is transparent and simple: “No fees for investors”. The platform clearly communicates this and has stuck to it over the years. This transparency builds trust – investors know that TWINO only makes money when their money is actively invested and generating returns, aligning the platform’s incentives with the investors’.

Negative Publicity about TWINO ⚠️

Like many P2P lending platforms, TWINO has faced its share of controversies and challenges, some of which could significantly affect investor confidence. Here we compile the major points of negative publicity and issues:

Financial Difficulties and Auditors’ Warnings (2017–2019)
TWINO expanded rapidly into multiple countries around 2016–2017, which led to significant losses. In 2017, the TWINO Group lost €12.2 million, and by September 2018 it had accumulated negative equity of €-3.4 million (liabilities exceeded assets). These troubles were not immediately obvious to investors until the audited reports came out. In early 2019, TWINO’s auditors (BDO) flagged a “material uncertainty related to going concern,” essentially questioning whether TWINO could remain solvent over the next year. This was a red flag: it meant the company’s continuation depended on improved results or new capital. No new equity was injected at that time (instead, oddly, TWINO had lent €1.2m to shareholders). The negative press around this period highlighted that 9 out of TWINO’s 11 lending subsidiaries lost money in 2017 and many had negative equity. TWINO was forced to close or sell several operations – including those in Spain, Czech Republic, Denmark, Romania, and Mexico – essentially admitting that those expansions failed. Investors reading blogs grew concerned that TWINO’s upbeat marketing did not match its financial reality. The company did cut staff (from 76 to 53 in 2018) and reduced the scale of the platform (the funded loan volume on TWINO actually shrank by €4 million in 2018 vs 2017). This episode of financial strain was a significant negative mark and serves as a reminder that P2P platforms can struggle behind the scenes even if investor returns seem fine in the short term.

Misleading Statistics & Transparency Critiques
TWINO received criticism for how it presented statistics on its website. For example, it used to advertise a cumulative investments chart (showing a smooth growth to €500m+ invested) which some analysts called “almost totally irrelevant,” because short-term loan platforms naturally accumulate volume when reinvestment is counted. Meanwhile, more telling metrics like the declining active loan volume in 2018 were not highlighted. Another chart on TWINO showed very low default rates (~4% defaulted loans), but it turned out this only counted loans currently on the platform and not those already bought back by originators. The actual group NPL ratio was ~41% at end-2017 when including loans that had defaulted and been removed from investor view. This gave the impression TWINO was perhaps painting a rosier picture of loan performance. Such practices were called out publicly and pressured TWINO to be more transparent. Since becoming regulated, TWINO has improved disclosures (publishing full financial statements and more detailed performance updates). Still, investors occasionally comment that communication during tough times could be better. For instance, some users in 2020–2022 felt TWINO was slow to update what was happening with Russian loans after the war started, leading to confusion.

Loan Freezes and Defaults in Foreign Markets
The period 2020–2022 brought geopolitical and regulatory shocks that hit TWINO and its investors:

• Russian Portfolio Freeze: TWINO had a sizeable lending business in Russia, and investors were funding ruble loans prior to 2022. When the Ukraine war and ensuing sanctions hit, TWINO had to suspend all Russian operations. About €4 million in investor funds got stuck in Russia due to currency controls (rubles couldn’t be converted or sent out). TWINO announced that these funds were effectively frozen indefinitely – Russian borrowers might be repaying, but the money sits in a Russian bank escrow. This was undeniably bad news for investors with exposure; they could not withdraw that money, turning a part of their portfolio illiquid for an unknown duration. TWINO was criticized for not having contingency plans for such a scenario, though arguably few foresaw such extreme events. Some investors also felt that continuing to list Russian loans up to early 2022 was risky given rising tensions – a hindsight critique of risk management.

• Asia (Vamo) Default and Exit: In April 2024, TWINO announced it would exit Vietnam and the Philippines due to an “increasingly challenging environment.” What initially seemed like an orderly wind-down turned more serious by mid-2024. TWINO revealed that the Vietnamese loan portfolio had defaulted – essentially the joint venture couldn’t recover loans after a government crackdown on non-bank lenders. This led to at least €1.3 million in investor losses because the Vietnam originator could not fulfill its buyback guarantees. Investors who had funded Vamo loans saw those investments marked as default with slim chances of recovery. Additionally, TWINO’s reputation took a hit because it had expanded into a high-risk market and stayed there even as other European platforms pulled out earlier. Some experts commented that TWINO “remained in high-risk markets like Vietnam far longer than competitors, exposing investors to avoidable risk.” The Philippine venture was closed as a precaution (before major issues arose), but it eroded trust that TWINO’s geographic expansion strategy was sound. The Vamo incident was widely discussed in P2P forums as a cautionary tale – an investor on Trustpilot in Feb 2024 mentioned “new products like real estate loans seem very risky” and noted TWINO’s poor handling of some functionalities, possibly alluding to these new ventures.

Poland Regulatory Risks
In January 2024, Poland implemented an Anti-Usury law that effectively banned the traditional P2P lending model (non-banks cannot fund loans with retail investor money). Many platforms immediately stopped offering Polish loans. TWINO, however, devised a workaround using a credit card structure (via FinTech “Fincard” in Poland). While this kept Polish loans on the platform, industry commentators labeled it a form of regulatory arbitrage and warned that if Polish regulators close this loophole, TWINO’s main business could collapse overnight. This scenario hasn’t happened yet, but it’s a looming risk. The publicity around this has been mixed: some applaud TWINO’s ingenuity to continue operations, others view it as skating on thin ice. It’s a negative in the sense that TWINO’s reliance on one country and on a legal technicality adds uncertainty for investors.

Criticism from Investors & Bloggers
TWINO has been discussed extensively on P2P investment blogs and forums. Sites in 2025 gave TWINO rather critical reviews – pointing out “bad risk management (again)” and noting that TWINO has become a “single bet on Polish regulators not closing a loophole.” These reviews highlight the concentrated risk and past investor losses (€5.3M+ confirmed losses from market exits). On Trustpilot, TWINO holds an average rating of 3.0 out of 5 (as of late 2025) with a very polarized mix of reviews. Around 43% of reviewers give 5 stars, praising solid returns, while about 32% give 1 star, often complaining about poor communication or technical issues. One investor’s 1-star review in 2024 stated: “Performance is really poor, as is their reporting. Some functionalities are not working for months. New products… seem very risky. Replies to questions are slow.” This captures the frustration some have had, especially during times when the platform was transitioning its products. Another negative sentiment has been the website’s interface – described as “clunky” by a user in September 2025, who nonetheless liked the returns but was annoyed at having to manually track some missing auto-investment logic. TWINO has responded to many negative reviews (they reply to about 91% of negative posts, albeit often with some delay), usually explaining the situation or noting improvements underway.

Regulatory or Legal Troubles
To date, TWINO has not been publicly sanctioned by its home regulator. In fact, the FCMC/Latvian regulator worked closely with TWINO during licensing and likely keeps a closer watch now. There have been no known frauds or investigations of malfeasance within TWINO. The biggest “official” setback was the Polish law change which wasn’t directed at TWINO alone but impacted the whole sector. We should note, however, that regulatory warnings have been issued to investors in general that investing in unregulated platforms is risky. Now that TWINO is regulated, it’s not on such warning lists. Earlier, in the unregulated days, the potential for platform collapse was a concern (and indeed, the going concern warning in 2019 was an implicit warning sign). Some competitors of TWINO did collapse or get sanctioned (e.g., Envestio, Kuetzal scams in 2019 – unrelated to TWINO but creating negative press around P2P). TWINO occasionally had to distance itself from those by emphasizing its regulated status and longevity to reassure investors.

Delays and Project Failures
In the new real estate segment, TWINO’s performance has been underwhelming. The platform launched a few short-term rental property investments in 2023, but as of 2025, it appears they are discontinuing the Rentals product due to underperformance (according to P2P news). TWINO is exiting those projects and returning capital to investors because the expected returns or investor interest didn’t pan out. While not a scandal, it’s negative publicity insofar as a hyped new product failed to deliver and had to be scrapped. Investors who joined for the real estate diversification may be disappointed.

Summary of Red Flags
The main red flags that any prospective investor should note from TWINO’s negative history are:

• Past financial instability – requiring trust that lessons were learned.

• High reliance on group guarantee – investor safety net is only as good as TWINO’s own finances, which have been shaky at times.

• Concentration risk – now 95%+ of revenue from one country (Poland) and one workaround.

• Investor losses in extreme scenarios – war and regulatory changes did translate to real losses (~€5 million total) for some investors, disproving the notion of “no one ever lost money on TWINO.”

• Mixed customer satisfaction – some complaints about transparency, communication delays, and platform tech issues.

For balance, it should be said that TWINO has taken steps to address many of these issues (e.g., improving capital buffers, being more open in communications). They have survived challenges that sank some other platforms. However, the negative publicity serves as a caution: investing on TWINO carries not just the usual borrower credit risk, but also platform and regulatory risk, and one must be comfortable with TWINO’s execution of its guarantees. Always approach the glowing marketing (high returns, “same level of safety as banks”) with a healthy skepticism and understand the underlying issues that have been raised in the past 🔎.

TWINO Success Stories and Milestones 🎉

Despite the challenges, TWINO has achieved several notable successes and milestones that highlight its growth and industry recognition. Here are the key positive highlights from TWINO’s journey:

Pioneer in European P2P Lending: TWINO was among the first peer-to-peer lending platforms in Continental Europe. Launching in 2015, it quickly became one of the heavyweights in the European P2P scene, putting Latvia on the fintech map. By 2017–2018, TWINO regularly featured at fintech conferences and even won industry awards for innovation. Its early mover advantage and rapid scaling led to milestones like €100 million in loans funded within the first year, and then crossing €500 million cumulative funded a couple years later. Reaching €1 billion in loans issued (achieved around late 2019) was a major milestone that TWINO often publicized. This demonstrated the platform’s ability to generate volume and serve a large user base, second only to a few top platforms like Mintos in its region at the time.

Obtaining EU Investment Brokerage License: A crowning achievement for TWINO was becoming a fully regulated investment marketplace. On 31 August 2021, TWINO secured its license from the FCMC (Latvian regulator), which was a rigorous process taking over a year. This made TWINO one of the first P2P lenders in Europe to transition into a licensed broker, marking a new era of compliance and credibility. The successful licensing was celebrated by the company and seen as validating TWINO’s business model. It allowed TWINO to broaden its product range (e.g. planning for stocks, bonds, etc. in the future). The CEO at the time, Anastasija Oļeiņika, shared this as a “big day for us… opening many doors for growth and making our business more credible in the eyes of our users.” Indeed, investors have shown more trust in licensed platforms, so this move likely attracted new users and set TWINO apart from unregulated competitors.

International Expansion and Passporting: TWINO successfully expanded its investor base across 30+ countries. By leveraging EU passporting, it could accept investors from virtually all EU countries and beyond, growing to serve tens of thousands of customers. It localized support in multiple languages and built a pan-European brand. For example, TWINO has a strong following in Germany, thanks to providing German language support and marketing there. The platform also made an entry to the Asia-Pacific lending market via a joint venture – launching the VAMO brand in Vietnam in 2019 and later in the Philippines. While the long-term outcome was not as hoped, the initial expansion showcased TWINO’s ambition to operate globally. Few European fintechs ventured into Southeast Asia, and TWINO doing so (in partnership with VIA SMS) was seen as a forward-thinking move to tap emerging markets’ potential. It proved TWINO could deploy its tech and lending know-how in completely new regions.

Top Industry Rankings and Awards: TWINO has earned recognition in the fintech industry. Notably, in January 2024 TWINO was named one of the world’s top fintech companies by a joint report of CNBC and Statista. This “Top Fintech Companies” list highlighted firms making a global impact, and TWINO’s inclusion affirmed its status as a significant player in alternative finance. In Poland, TWINO’s subsidiary NetCredit/FinCard won the “Credit Card of the Year 2023” award from Loan Magazine (a leading consumer finance publication). This award, decided by industry experts, recognized the innovative credit line product (Halvo/NetCredit) that TWINO offers in Poland. It’s a strong vote of confidence in the product’s customer appeal and TWINO’s execution. TWINO Group has also been present in rankings such as the Financial Times’ FT1000 list of fast-growing companies in Europe in past years (owing to its rapid growth).

Product Innovation and New Launches: Over the years, TWINO expanded beyond its initial loan product:

• In July 2022, TWINO launched Asset-Backed Securities on the platform. This introduced the concept of structured notes for loans, aligning with the new regulatory status. It allowed investors to continue investing seamlessly as the legal form changed from assignments to securities – a successful transition that many investors might not even have noticed beyond signing a new terms & conditions.

• In August 2023, TWINO introduced Real Estate Securities and a Short-Term Rental investment product. This diversification into real estate was a significant milestone as it marked TWINO’s move into asset classes beyond consumer loans. They even launched a Secondary Market alongside it, which was a much-requested feature and enhanced platform functionality.

• TWINO has also explored offering a virtual credit card to Polish consumers (through FinCard) as a new lending product, which shows their innovative approach in lending tech. By pivoting to credit cards to circumvent regulatory hurdles, TWINO demonstrated agility in product development.

Strong Performance of Core Business: A success story within TWINO is the turnaround and growth of its Polish lending operation. After restructuring, NetCredit Poland (FinCard) has shown robust growth: in 2023 its loan portfolio grew 80% to €28.3m and it achieved €32.5m in revenue, exceeding targets. It also turned impressively profitable (net profit €7.27m in 2023). This performance underscores that TWINO’s core lending model can be very profitable when done at scale in a stable market. Investors benefit indirectly, as a profitable originator is more reliable for buybacks and continuous flow of new loans. The fact NetCredit received a prestigious award in 2023 shows customer satisfaction and brand strength in its market. For TWINO investors, seeing the primary originator healthy and lauded is a positive sign.

Investor Returns and Longevity: It’s a success in itself that TWINO has been operating for over a decade (if counting the lending business, and 8 years as a platform) and has consistently paid investors high returns. Many early investors have used TWINO for 5+ years and earned the promised returns, which builds trust. Some investors have publicly shared that they “have always had a good return from TWINO” over many years. Unlike some P2P platforms that imploded or never gained traction, TWINO has maintained a sizable loyal investor community of around 20–30k active users at any time. This speaks to TWINO’s ability to adapt and survive through fintech industry ups and downs (including the COVID-19 pandemic, which TWINO weathered by implementing payment deferrals but ultimately came through without major losses).

Recognition as a Fintech Leader: TWINO often appears in media stories as a leading Baltic fintech. In 2020, for example, the platform was highlighted alongside companies like Monzo and SolarisBank as an example of innovative European fintech benefiting millions. It has been featured in Euromoney and other financial publications for its approach. In Latvia, TWINO is considered one of the “hottest startups,” which is evidenced by it being included in rankings and reports by organizations like Labs of Latvia and Fintech Latvia. The company’s executives have also been recognized – e.g., Armands Broks is often invited to speak on fintech in emerging markets, and Anastasija Oļeiņika was listed among influential women in fintech in the region.

Platform Awards: While specific platform awards (like “Best P2P Platform”) are fewer in recent years due to the shift to regulated models, TWINO did receive positive rankings on P2P comparison sites historically. For instance, in 2017 TWINO won a People’s Choice Award on a P2P conference (as per some blog references), and in 2019 it was rated among the top 3 platforms in Continental Europe by some independent bloggers based on user voting. These informal accolades, plus a high Trustpilot rating in earlier years, show that TWINO had built a good reputation among users prior to the troubles.

Conclusion: TWINO’s story isn’t just about challenges – it also showcases resilience and innovation. The company turned around a near-insolvency into profitability within a couple of years, secured a coveted license, expanded product lines, and kept investors on board with competitive returns. Achieving regulatory compliance in a strict EU framework is perhaps the most reassuring success from an investor perspective, as it ensures better oversight and future stability. For a retail investor reading this report, TWINO’s successes mean that the platform has a proven track record and industry standing – it’s not an overnight startup, but a mature player that has reached key milestones (like 1 billion funded, 10+ years in business, etc.). As TWINO moves forward, one hopes it will build on these successes (such as possibly re-expanding into new markets once conditions allow, or introducing new asset classes under its license) and continue to deliver positive outcomes for its investors 🎊.

TWINO Loan Originators and Lending Partners 🤝

TWINO operates on a model where investors are effectively funding loans issued by various loan originator companies. Unlike marketplaces that host external third-party lenders, TWINO’s loan originators are predominantly affiliated with the TWINO Group (often wholly owned subsidiaries). Here’s a rundown of the key originators, their operations, and risk profiles:

1. NetCredit (Poland) / FinCard:
   Overview: NetCredit is the flagship loan originator for TWINO, active in Poland since 2011. It offers short-term consumer loans and lines of credit to Polish borrowers. In 2019, TWINO integrated NetCredit’s lending under a new structure: FinCard Sp. z o.o., a 100% TWINO-owned company that operates as a Polish National Payment Institution with a credit license. FinCard issues a revolving credit line (a “virtual credit card” product under the brand names NetCredit and Halvo). This clever setup allows TWINO to continue funding loans in Poland despite strict regulations (because technically, investors are buying receivables from a payment institution’s credit product).

Scale and Volume: NetCredit Poland is by far the largest originator on TWINO. It constituted roughly 95% of TWINO’s new loan volume in 2024. In 2023, NetCredit/FinCard had an outstanding loan portfolio of €28.3 million (gross). The platform has processed over €36 million in loans through FinCard via TWINO up to mid-2024. The originator has served a large customer base, issuing over 100,000 credit cards as of early 2024. This indicates tens of thousands of Polish borrowers use the service.

Financial Performance: NetCredit Poland is a success story for the group. In 2023, it generated €32.5 million in revenue and €7.27 million in net profit (22% profit margin). This surpassed its targets and demonstrated strong profitability in its first full year under the new credit card model. By Q1 2024, it continued with €10.5m revenue and €1.5m profit in that quarter. These numbers show that NetCredit is well-capitalized and self-sustaining, which bodes well for investors since it means this originator can comfortably honor buyback guarantees. Notably, NetCredit won “Credit Card of the Year 2023” in Poland, reflecting its product’s strong market positioning.

Ownership and Risk: NetCredit/FinCard is wholly owned by FINNO (TWINO’s holding) and ultimately by Armands Broks. As such, its interests are aligned with the platform’s. The key risk here is regulatory: the Polish Anti-Usury law prohibits peer-to-peer funding, but FinCard circumvents this by being a payment institution issuing credit. If the Polish regulator (KNF) decides this arrangement is not acceptable or changes rules, NetCredit could be forced to halt its current funding model. That would impact TWINO’s supply of loans dramatically. However, as of now, FinCard is fully licensed in Poland (license #62/2024) and in compliance. Credit risk wise, Polish consumer loans have historically moderate default rates, and FinCard’s credit scoring seems effective given the profitability and relatively controlled non-performing levels (FinCard’s non-performing loans are not publicly broken out, but group data suggest default rates around 10–14% which are manageable with high APRs). Country risk for Poland is relatively low (stable economy, EU member). Currency risk is minimal since loans are in Polish Złoty but all investments are handled in Euro – FinCard likely hedges or absorbs FX fluctuations (which haven’t been severe). NetCredit’s bonds or external fundraising: There haven’t been public bond issues by NetCredit Poland – it relies on TWINO investor funding and retained earnings. Its strong financials suggest it doesn’t need external financing for now.

2. Vamo (Vietnam):
   Overview: Vamo.vn was a joint venture consumer lending operation in Vietnam, launched in late 2019 by TWINO and VIA SMS Group. It provided short-term unsecured loans to Vietnamese borrowers via an online platform. This venture was part of TWINO’s expansion into Asia-Pacific, and Vietnamese loans were funded through TWINO for a time (denominated likely in local currency, but investments were effectively in EUR with currency conversion).

Scale and Volume: The Vamo Vietnam portfolio was growing through 2020–2021. However, by early 2023 it remained small relative to Poland – perhaps a few million euros outstanding. Vietnam loans on TWINO offered high yields (~14%+) to compensate for currency and emerging market risk. In total, several million EUR worth of loans were financed via Vamo on TWINO before suspension. Unfortunately, due to the sudden regulatory intervention in 2023 (Vietnam authorities cracked down on online lending without proper licensing), Vamo had to cease operations.

Outcome and Risk: In March 2024, TWINO decided to permanently cease Vietnam operations following a shift in regulatory attitude and difficulty continuing legally. This meant the Vietnamese originator (a local entity likely in partnership with VIA SMS) could not recover many outstanding loans. The result was a default on the obligations to TWINO investors – at least €1.3 million was left unpaid to investors as the originator couldn’t buy back all defaulted loans. Essentially, Vamo Vietnam went insolvent or was unable to function due to the clampdown. This marks a failure in that originator. Investors holding Vamo-backed notes suffered losses (some reports indicate recovery efforts are ongoing, but prospects are uncertain). Thus, Vamo Vietnam’s risk profile turned out to be very high: political/regulatory risk manifested, plus currency risk (devaluation of the Vietnamese dong could also have affected values). This originator is now defunct, and TWINO no longer offers any Vietnam loans as of 2024. The joint venture’s closure is a stark reminder that foreign ventures carry significant risk.

3. Vamo (Philippines):
   Overview: Following Vietnam, TWINO and VIA SMS expanded the Vamo brand to the Philippines in mid-2022. The Philippines venture was similar – short-term online loans in an emerging SE Asian market. It started a bit later and was even smaller in scale than Vietnam’s.

Scale and Volume: By late 2023, the Philippine loan volume on TWINO was modest. TWINO introduced Philippine loans (likely in Philippine Peso) with high interest rates to attract investors. It never grew large, partly because it launched when TWINO was already facing regulatory licensing stuff and perhaps didn’t push it strongly to investors.

Outcome and Risk: In April 2024, alongside the Vietnam decision, TWINO exited the Philippines venture as well. This was portrayed as a strategic decision to focus resources elsewhere, likely influenced by the Vietnam issues and a general re-evaluation of APAC strategy. The good news is that the Philippines exit was pre-emptive; there was no noted default event like in Vietnam. TWINO seems to have managed an orderly wind-down, presumably ensuring Philippine borrowers continued to repay and investors were paid back. By mid-2024, no new PH loans were on offer and existing ones were running off. Risk-wise, Philippines had similar risks to Vietnam (regulatory uncertainty, currency, and higher default rates). TWINO and VIA likely saw the writing on the wall and chose to pull out before anything went awry. From an investor standpoint, those who had Philippine loans got their returns as expected, albeit the offering was short-lived. The originator entity in Philippines would be closed; since it was also part of the JV, it’s also gone from TWINO’s roster.

4. TWINO Russia (Twino.ru and related brands):
   Overview: Russia was once a major market for TWINO’s lending business. TWINO’s Russian subsidiary issued short-term loans (often payday loans to individuals) and for a period these loans were available to invest on the platform. Brands like “EkspressCredit” or simply Twino.ru operated there.

Scale and Volume: Before 2022, Russian loans comprised a significant portion of TWINO’s platform volume – possibly around 20–30% at times. The loans were in Russian Rubles. TWINO investors could invest in them and typically got higher interest (around 12–14% plus sometimes currency exchange bonuses). The group had issued hundreds of millions of EUR worth of loans in Russia since 2009 (as part of the wider total).

Outcome and Risk: The venture was profitable for a while. However, due to geopolitical risks, it ultimately became problematic. After the 2022 invasion of Ukraine, TWINO suspended its Russian operations. The ruble plummeted and repatriating funds became impossible. About €4m of loans remained unpaid to investors because the money was trapped in Russia. The Russian subsidiary essentially cannot fulfill its obligations under buyback because transferring euros out is restricted. TWINO had to write off those amounts from an investor perspective (though they still legally attempt recovery if ever possible). So, while not a “default” in the traditional sense (the loans might have been repaid in rubles, but uselessly sitting in a Russian account), for investors it’s a loss/frozen asset situation. This originator is effectively inactive now. Risk profile was high: heavy currency risk, political risk (sanctions), and typical high default risk for payday loans. TWINO no longer lists Russian loans.

5. Other Past Originators:
   Latvia: TWINO itself started in Latvia and did issue some loans to local borrowers early on. However, Latvia’s market is small and highly competed (plus interest rate caps came in), so it wasn’t a major volume. Now, no Latvian loans are on TWINO (it’s just the home of the platform, not the loans).

Kazakhstan: TWINO operated in Kazakhstan at one point (a brand like “Loan.kz”), which might have been available on platform around 2016–2017. These were high-interest loans in KZT. TWINO wound this down when economic conditions and regulation shifted. They sold or closed that unit during the 2018 consolidation.

Georgia, Denmark, Spain, etc.: TWINO had a presence or pilot in these countries. For example, Denmark and Spain originators were started but then exited by 2017–2018. Those loans were available only briefly on platform. All these were shut down or sold, often because they weren’t profitable or due to strategic refocus. Investors in those at the time were paid back when operations ceased (no notable losses recorded, they just stopped new loans).

Mexico and Romania: Similar to above, short-lived ventures that didn’t scale and were closed.

Today: TWINO does not use third-party originators like Mintos does. All loans now come from within the group (NetCredit/FinCard). So the list of active originators for investors is essentially one (plus any real estate SPVs for property projects). TWINO has communicated that they could onboard external loan originators if they meet standards, but none are on the platform currently.

Volumes by Originator: As of 2025, essentially 100% of new volume is from NetCredit Poland. In 2023, Polish loans replaced Asian loans completely. A small residue of older originators’ loans might still be in investor portfolios (e.g. some Russian or long-term loans from earlier times), but new investments all go to Poland.

Ownership and Alignment: All originators are ultimately owned by TWINO’s founder, which means incentives are aligned to keep them solvent and investors confident. But it also means if one goes down (like Vietnam), it directly hits TWINO’s reputation and finances. In contrast, a platform like Mintos can drop a failing third-party originator with less direct impact. TWINO’s model is more “skin in the game” – it’s their own lending business, so they presumably underwrite carefully to protect their capital too.

Recent Fundraising or Bonds: TWINO’s originators have generally not tapped public bond markets because they rely on the platform. However, it’s worth noting TWINO did consider raising funds via an equity crowdfunding campaign in 2022 (to sell a stake of TWINO itself to the public). This was postponed or shelved likely due to market conditions. There was also mention in Estonia’s financial register of a base prospectus for “TWINO Investments Poland” – possibly to offer securities in the EU, but that might be just the note issuance program documentation. No standalone bond issuance by NetCredit has been reported; given its profitability, it might not need one, but if TWINO wanted to diversify funding, it could issue bonds or institutional debt in the future.

Loan Originator Risk Profiles:

• NetCredit/FinCard (PL): Moderate risk. Profitable, regulated, but concentrated regulatory risk.

• Historical originators (RU, Asia): High risk. Shown by outcomes – geopolitical and regulatory failures.

• Potential new originators: If TWINO were to expand again, likely targets could be other EU countries or nearby emerging markets, but they would tread carefully after past lessons.

Does TWINO Use Loan Originators like Mintos?
In summary, TWINO’s structure is more vertically integrated. It doesn’t list a variety of external microfinance companies; instead, it is itself the lender through different brands. So you won’t find a long list of partner companies on TWINO’s site – just the ones under its roof (which as of now, are NetCredit Poland and any associated product variations).

For an investor, this means when you invest on TWINO, you are mostly taking exposure to TWINO Group’s lending portfolio rather than a diversified set of independent lenders. This can be good (control and alignment) or bad (less diversification). The key originator to watch is NetCredit Poland – its health and performance essentially dictate TWINO’s overall health in the current setup. Fortunately, recent data on NetCredit are strong, but one must keep an eye on Polish regulatory developments affecting it.

Is TWINO a safe and regulated platform?

TWINO is regulated and operates under an EU investment brokerage license, which adds a layer of safety compared to unregulated platforms. It’s supervised by Latvijas Banka (the Bank of Latvia) and must follow strict investor protection rules. For example, client funds are segregated and there’s an investor compensation scheme (up to €20,000) in case the platform becomes insolvent. Being regulated also means regular audits and oversight of TWINO’s operations.

That said, “safe” is relative – while the platform itself adheres to regulations (no Ponzi scheme risk, etc.), investing in loans carries inherent risks. You rely on TWINO’s loan originators to repay as promised. The platform has had issues (like war or regulatory events affecting loans) which are not fully eliminated by it being regulated. So, TWINO is as safe as a compliant P2P platform can be, but investors should still do their due diligence and not equate regulated with risk-free. Use the platform’s tools to diversify and stay informed on any developments.

Overall, TWINO has a solid track record and tens of thousands of users, indicating a level of trust earned in the market.

What returns can I expect on TWINO?

You can expect annual returns around 10–12% on TWINO, assuming you invest in the current mix of loans. TWINO’s consumer loans (mainly from Poland) typically yield about 12% per annum. This has been quite consistent; the platform often advertises “~12% ROI” and many investors indeed report returns in the 10-12% range. If you use Auto-Invest and keep your funds continuously invested in available loans, you’re likely to hit those numbers. In the past, when more markets were available, some loans had higher rates (up to 14-15%) and some lower, but now the offerings are fairly uniform. Real estate projects on TWINO might have slightly different return profiles – for example, a rental property might project ~8% annual yield from rent and maybe some uplift on sale. But as of now, that part of the platform is small and reportedly winding down due to underperformance (so most investors are just in loans). It’s worth noting that these returns are gross before any applicable taxes. Also, if an extraordinary event happens (like the Russia freeze), it could drag your effective return lower because some money might be stuck not earning interest. However, those are rare cases. Most investors who diversify across all TWINO loans continuously have seen double-digit returns historically. Keep an eye on TWINO’s monthly statements which often tell you your personal XIRR (internal rate of return) – a useful metric to see what you’re actually earning.

What are the main risks of investing with TWINO?

The main risks include:

• Loan Originator Default Risk: When you invest, you’re lending to TWINO’s loan originators indirectly. The biggest risk is that a loan originator (like the one in Poland, or any other market) fails financially and cannot honor its buyback guarantee or payments to investors. If that happens, you as an investor could face losses. We’ve seen this with the Vietnam originator default – investors bore the loss. So, despite buyback, you’re relying on the company behind it.

• Borrower Default Risk: While individual borrower default is supposed to be covered by buyback, a high level of borrower defaults can strain the originator. If an economic crisis hits and many borrowers default (say, during COVID or a recession), the originator must still pay investors. If defaults exceed their reserves, that loops back to originator risk. So, underlying credit risk is there; buyback just shifts it one layer up.

• Platform Risk: This is the risk that TWINO itself could become insolvent or shut down. If TWINO the platform were to fail, your investments could be at risk even if loans are still being repaid by borrowers. However, because TWINO is regulated, there are mechanisms (the investor compensation scheme up to €20k, and presumably an administrator could take over servicing the loans)twino.eu. Still, it could be messy and you might not recover 100% in a platform failure scenario. Always keep an eye on TWINO’s financial health (they publish annual reports) to gauge this risk.

• Regulatory Risk: As noted, laws can change. The Poland example shows that a law can suddenly make the P2P model unworkable. TWINO managed a workaround this time, but regulators could close that too. If TWINO can’t operate in a key market due to regulation, that’s a risk to getting new investments and even to existing ones if, for instance, they had to suddenly stop business in a country. Regulatory crackdowns in places like Vietnam essentially caused investor losses. So, changes in law in any country where TWINO lends (or in Latvia affecting platforms) is a risk to watch.

• Currency Risk: TWINO deals in EUR for investors, but some loans are in local currencies (PLN for Poland, previously VND, RUB, etc.). Currency swings can impact the originators. For example, if PLN devalued sharply against EUR, the originator’s obligations in EUR terms become more expensive. TWINO originators typically hedge or manage this, but extreme moves can cause stress. For investors, TWINO now largely shields you from FX risk (you invest in EUR and get EUR out). But earlier, investing in RUB loans had direct currency exposure. Currently currency risk is indirect – affecting originator stability rather than your account balance directly.

• Liquidity Risk: While TWINO is relatively liquid, it’s not as liquid as cash. If many investors rush to withdraw or if new loans supply dries up, you might experience delays deploying cash or exiting. There was a time in late 2019 where TWINO’s loan volumes dropped and some investors had idle cash (cash drag). And in crisis times (like war announcement), secondary markets or payouts could slow. You should be aware that you might not be able to convert all investments to cash instantly, although within a few months generally yes.

• Operational Risk: As with any online platform, there’s risk of operational issues – e.g., technical outages, cyberattacks, errors in interest calculation, etc. TWINO has not reported major incidents of hacking or data breaches, but it’s a risk in fintech. They do have proper IT security measures. Another operational aspect is management risk – key people leaving or making bad decisions. TWINO did see quite a turnover in management historically, which can be a risk factor if not managed well.

• Macro Economic Risk: If economies go into recession, borrower default can rise. Also, during COVID-19, many P2P platforms had to allow borrowers grace periods which delayed payments to investors. TWINO did navigate COVID fairly well, but it’s a general risk that broad economic downturns affect loan performance and investor returns (perhaps temporarily).

In short, the primary risk is that you could lose money if TWINO’s loan partners fail to pay. Everything else – regulatory, platform, economic – feeds into that outcome. This is why diversification and not putting all your money in one platform is wise. On TWINO, you can’t diversify across many originators now, so you’re heavily betting on one (Poland). Consider balancing that by investing on other platforms or assets as well. Understanding these risks is crucial; TWINO provides high returns because these risks exist. By being aware of them, you can better decide how much of your portfolio to allocate to TWINO and what precautions to take (like regularly reading platform updates and adjusting settings if needed).