Last week I was quick to jump into conclusions based on the lack of information available about Dena Invest. I apologize if I jump to rash statements with my initial post, but as a P2P investor currently participating in multiple judicial processes against fraudsters and without any serious attempt either by P2P platforms or regulators to truly protect investors from such criminal activity every single red flag is concerning and should be shared with fellow investors.
On the same day Arber Blakcori, CEO of Dena Invest reached out to me sharing his legitimate concerns with the impact of the publication and making himself available to answer any questions. I removed the publication and shared my questions. Below you can find the answers I received today and my comments.
We as investors need to ask this questions. And we need clear answers! In a era of fraud and crony capitalism the key for the industry success is to share among the community reliable and verifiable information. Only this way P2P platforms can be successful.
Dena Invest: My Initial Concerns
Dena Invest is a very recent real estate investment platform that promotes opportunities in the Balkan countries (Kosovo, Albania, Northern Macedonia, Serbia, Montenegro, Croatia, Bosnia, Slovenia, Bulgaria and Romania). The initial discussions in P2P investor groups raised concerns associated to the initial registration address of the company and that triggered a number of message exchanges that are explained in the text below.
I appreciate the quick reply of Arber and I welcome your comments on this information. Let me know if you have further questions that you want answers to.
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My Questions to Dena Invest
1 – Personal Information & People
I was not able to find significant information about you online. That is understandable, but something that should change. Reading your LinkedIn profile none of your prior professional activity shows relevant experience to launch and run a Real Estate investment platform.
Can you share light on your personal story and what drove you to start Dena Invest?
Dena Invest was created by Mentor Kazazi, an engineer with experience as a developer in the Real Estate industry and by Arber Blakcori, whose profession is management, with experience in Sales and Marketing, in Entrepreneurship and on top of that with a background in Technology.
Therefore, they decided to combine synergies to create a start-up that gives the Balkans, a region of 50 million residents known for having the greatest economic growth potential, opportunities for financing many residential Real Estate projects. We saw a great potential out of it and also the possibility to combine FinTech and connect European Union investors with developers of Real Estate projects in the Balkans.
Dena Invest’s main goal is to give people all around the world the possibility to invest in Balkans Real Estate, knowing that crowdlending in this region is still an untapped opportunity.Arber Blakcori reply
My comment: The reply does not state any information on Arber professional experience that is so relevant for this enterprise. I requested additional clarification on personal and professional background to start this venture.
Are you leaving in Ireland, if no why stating that on LinkedIn?
No answer was provided.
On your website you present the following people as being associated to Dena Invest:
Ina Andrejeva – Branch Manager (LinkedIn, but no relevant experience in the area)
Mimoza Rraci – Digital Illustration (LinkedIn, but no connection to Dena)
Noli Mati – Creative Director (LinkedIn, experience in the area but no connection to Dena)
Besfort Shehu – Web Developer (LinkedIn, experience in the area but no connection to Dena)
Lina Weber – Investor Relations – German (no LinkedIn profile, is this person real?)
Julia Martin – Investor Relations – French (no LinkedIn profile, is this person real?)
Antonio Gomez – Investor Relations – Spanish (no LinkedIn profile, is this person real?)
Ana James – Investor Relations – English (no LinkedIn profile, is this person real?)
Can you share information on the business relation between each of these individuals and Dena Invest? Are they employees, contractors, shareholders? Any proof of that?
Our Customer Support Team
Denainvest provides Customer Support Services in 4x Languages: English,Spanish,German and French. We are utilizing our local (Kosovo) Partner that has extended experience in this field working with Big European Brands. They provide us dedicated resources that facilitate our needs. Therefore, their names may vary depending on SLA and needs. This is a cost-effective and professional solution.Arber Blakcori reply
My comment: Yesterday it was made public that the photos associated to the customer support team are fake. Why not making public the use of a third-party customer support service provider? And no answer was provided regarding the rest of the “team” and their business relationship to the company. Regarding the people associated with the platform, what type of business relationship they have with Dena Invest?.
What Branch is managed by Ina?
We are in the final process of incorporating Latvian SIA for Backoffice Operations. Latvia has a lot of talented people in the sphere of P2P/Crowdfunding. Therefore, we are planning to expand our Team in Latvia: Marketing, Finance, IT.
Therefore, main duties of Branch Manager: Office Management, Incorporation of Latvian SIA, Hiring Process, Administration.Arber Blakcori reply
My comment: I assume Arber is describing Ina responsibilities in the company. The answer also makes clear that the Latvian branch is still not registered.
Who among the team is an expert in real estate?
Denainvest shareholder/co-owner Mentor Kazazi with the help of local (Balkans) Real Estate specialist conducting Due Diligence of projects that are placed on Denainvest.
Mentor Kazazi has 7 years’ experience in Real Estate and was involved in several successful projects implemented in Kosovo, prior to launching Denainvest platform. Therefore, Mentor has extended experience in the Balkans and realistic understanding of Risks associated with Real Estate Project in this region.Arber Blakcori reply
My comment: Quite a responsibility for someone that was invisible on the platform website. How many hours per week does Mentor Kazazi dedicates to Dena Invest to ensure the success of such business model?
Who among the team is an expert in legal due diligence?
No answer was provided.
Who among the team is an expert in financial analysis and debt collection?
No answer was provided.
Who among the team is an expert in Albania, Northern Macedonia, Serbia, Montenegro, Croatia, Bosnia, Slovenia, Bulgaria and Romania real estate markets?
My comment: No answer was provided but I assume Mentor Kazazi is the right person to answer. And if Dena Invest is hiring local experts, how?
2 – Company Structure
Who are Dena Invest shareholders and beneficial owners? Can you share records?
My comment: It would be important to state the real distribution among the shareholders. And essential to justify the reason why Mentor Kazazi was totally invisible on the platform. No records were shared.
Why is Dena Invest registered in Ireland?
When we were scanning on best jurisdiction for our Platform, we short-listed Ireland as the best match. Several reasons behind that:
1) Income tax is charged at a progressive rate in Ireland.
2) In order not to lose a competitive advantage (if we were registered in Latvia as an example) we should not act as “tax agent” meaning that we don’t have obligation on holding taxes from interest rate for investors, as in Ireland it is an obligation of clients.
3) Simplicity of opening an Operational Center. As for OPEX purposes, Ireland is relatively cost-effective and all procedures for incorporating a company in this country is straight-forward.Arber Blakcori reply
My comment: This is one of the topics that triggered my initial post. Below Arber explains the coincidence of having the same registration address as Grupeer.
Who are the legal entities / individuals that supported your company registration process in Ireland? Why share publicly a business address different from the actual registry (that is the same address as Grupeer)?
Company was incorporated with the help of reputable Irish Company – CBF who have 23 years’ experience in this field with great reputation.
CBF owns address:
The Black Church,
St. Mary’s Place
Republic of Ireland
Therefore, by default they are offering for Incorporation to utilize their address. Which was initially used to incorporate DENARIUS INVEST LIMITED (CRO code: 677077). After that we requested address to be moved to our new address:
51 Bracken Road
Sandyford Business Park
Process of changing address (due to COVID 19) takes longer, but soon will be updated in CRO as well.Arber Blakcori reply
My comment: No actual document was shared to sustain this statement. This can be a simple coincidence, but what to conclude from this?
What is the actual company structure between Ireland, Kosovo and Latvia? Different companies? If yes, can you please share the registration and stakeholders/beneficial owners for each organization and the relations among them?
My comment: No answer was provided, but I assume Mentor Kazazi is the right person to answer.
What are the funds legally deposited as Dena Invest capital for the different organizations under such umbrela? Can you share records?
No answer was provided.
My comment: No records were provided. Based on the information below I assume Mentor Kazazi invested 112 000 EUR, but it is impossible to evaluate.
3 – Operations
Who is funding Dena Invest current operations?
Main investor/shareholder of Denainvest is Mentor Kazazi who secured investment in building Platform of 112 000 EUR.
Apart from that we have a plan of expansion to more regions in the Balkans where we will be taking commission for Placement, DD and Transfers.Arber Blakcori reply
My comment: No records were provided.
Does Dena Invest have any license to operate as a crowdlending platform?
No. But on November 10, 2021 a new European regulation will come into force. According to the requirements of this regulation legal entities only that have obtained an authorization in competent authority will have the right to operate as crowdfunding service providers. Dena Invest intends to obtain such authorization and is working on implementation of the regulation’s requirements in its processes in order to obtain an authorization as soon as possible after the regulation comes into force.Arber Blakcori reply
My comment: In the great majority the New European Regulation will not be applicable to P2P platforms. Additional clarification is required based on this answer.
Can you share light on the activities currently ongoing in the different offices of Dena Invest?
My comment: Based on the information shared, the company is still not operational. Neither the different companies are setup or the Security Agent is operational. What does this mean for investors that already deposited funds in Dena Invest?
Who developed the platform interface? Can you confirm that Dena Invest purchased such service to the same provider of EvoEstate?
Our Platform is built with the help of reputable company UAB RIKANUS that provides us full technical scope. As with all White labels there are constant needs on improvements and updates that we are processing on Daily basis.Arber Blakcori reply
My comment: Based on communications with EvoEstate CEO it become clear that UAB Rikanus is a service provider to Dena Invest. Good to see this information confirmed.
Can you share information about the financial institutions Dena Invest works with and how do you manage investors funds? Can you provide evidence of current bank accounts that are being used for such propose?
No answer was provided.
What type of guarantees you have from real estate developers in the projects you fund? Can you provide evidence for the two projects available on the website? The contracts signed with the developers and a sample loan agreement with investors?
Sample loan agreement with investors
In the near future, the general conditions of the loan agreement, which is concluded with the investor, will be available on the platform itself.Arber Blakcori reply
My comment: No information regarding guaranties was provided. No evidence associated to the two projects available in the platform was provided. No contracts with developers were shared.
Can you clarify if Dena Invest Terms and Conditions are a copy/adaptation of other P2P platforms?
The manner of most crowdfunding/crowdlending platforms’ services is very similar in nature, and this means that general conditions of the user agreement have many equal provisions. But as we try to comply with the new regulation’s requirements we are working to improve the user agreements conditions, for instance:
– knowledge test for non-sophisticated investors (our team is working on development and implementation of this test);
– the maximum amount for non-sophisticated investors they can invest within one calendar year shall not exceed 10 000 (ten thousand) euros;
– the investor has the right without any sanctions to terminate the loan agreement at any time during the funding period, but not later than 5 (five) calendar days prior the expiration of this funding period.Arber Blakcori reply
My comment: The examples presented above are in line with the rules already in place to protect investors in the UK. But it would be nice to know what template was used.
Can you clarify how Dena Invest will liquidate non-performing loans and return assets to investors?
No answer was provided.
4 – Dena Invest Goals
Why launch a new P2P real estate platform in October 2020?
No answer was provided.
Can you disclose Dena Invest goals for the future?
No answer was provided, even if some ideas were described in generic terms over other answers.
I appreciate the quick reply of Arber, but it is clear to me that Dena Invest is available online without making the necessary homework to succeed. I welcome your comments on this information. Let me know if you have further questions that you want answers to.
I will share any additional information made available later on this post over time.
This publication is only possible due to the work of several P2P investors that shared this warning in discussion channels. I believe this to be the only way to avoid further fraudulent activities in the industry.
We need more P2P Whistleblowers
For screenshots of the email exchange, check below.
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