Verdict
Afranga is not a fraud: a real ECSP licence, funds segregated at Lemonway, a direct claim. But the yield rests on an underlying credit model (Stikcredit) whose practices are directly challenged as to their legality. The Bulgarian consumer-protection commission (KZP) identified 14 abusive clauses in Stikcredit's terms, and several courts have voided its contracts for concealed cost of credit: in a case ruled in Pazardzhik in 2024, a court expert put the real APR at 603.85% against 42.58% advertised, the no-guarantee penalty causing the cost to explode. The underlying portfolio is heavily impaired (~37%) and equity is falling. Marked conflicts of interest on both sides: Afranga is 100%-controlled by S. Sabev (around a dozen related companies), and Stikcredit is owned by S. Topuzakov, linked to 20-30 companies in north-eastern Bulgaria (gambling, pawnshop, thermal power plant, real estate, media). Solid regulatory wrapper, yield base under heavy regulatory and judicial pressure. Score capped at 40 by the consumer-protection authority's action.
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